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Page 1 Page 2 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY. FLORIDA CASE NO. 50 2009CA040800XXXX/45 AG Complex Litigation. Fla.R.Civ.Pro. 1201 JEFFREY EPSTEIN, Plaintiff, VOLUME I OF II SCOTT ROTHSTEIN, individually. BRADLEY J. EDWARDS. Individually, and L.N. individually. Defendants. VIDEOTAPED DEPOSITION OF BRADLEY J. EOSARDS, ESQUIRE Tuesday. March 23. 20010 10:00 - 5:01 p.m. 2139 Palm Beach Lakes, Boulevard West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, PPR Notary Public, State of Florida Prose Court Reporting Job No.: 1333 PROSE COURT REPORTING AGENCY. INC. Page 3 2 INDEX 3 4 5 EXAMINATIOR DIRECT CROSS REDIRECT 6 BRADLEY J. EDWARDS, ESQUIRE 7 BY MR. CRITTER 5 8 9 10 11 EXHIBITS 12 13 14 EXHIBIT DESCRIPTICei PAGE 15 PLAINTIFF'S EX. 1 /JARED° RODRIGUEZ 211 16 CRINIIL11.02MPLAIM PLAINTIFF'S EX. 2 COMPLAINT 239 11 PLAINTIFF'S EX. 3 JULY 22. 2009 276 FRCS/OLE 18 19 20 21 22 23 24 25 APPEARANCES: 2 On behalf of the Plaintiff: 3 ROBERT D. CRITTER, JR., ESQUIRE BURMAN, CRII1XNI, LAPITIER 4 COLEMAN. LLP 4 303 Banyan Boulevard Suite 400 5 Nest im 33401 Phone: 6 7 and JACK AWt GOLEBERGER. ESQUIRE ATTERBURY, GOLEBERGER 4 WEISS. 9 250 Australian Avenue South 10 Suite 1400 West Palm Raze rl ride 33401-5012 Phone: 11 12 and 13 On behalf of the Plaintiff: 14 ALAN M. ECASHOWIT2, ESQUIRE HARVARD IA/I SCHOOL 15 Hauser 520 Cashridiass iatts 02138 16 Phone: 17 On behalf of the Defendant: 18 JACK SCAROLA, ESQUIRE SEARCY, DENNEY, SCAROLA, 19 BARNHART a SHIPLEY, P.A. 2139 Palm Beach Lakes Boulevard 20 West Pa de 33409 Phone: 2) 22 ALSO PRESENT: Jeffrey Epstein 24 Joseph Kozak. Videographer Prose Reporting Services 25 PROSE COURT REPORTING AGENCY, INC. Page 4 PROCEEDINGS 3 Deposition taken before Cynthia Hopkins. 4 Registered Professional Reporter and Florida 5 Professional Reporter, and Notary Public in and for 6 the State of Florida at Large, In the above cauee. 7 - - - B THE VIDEOGRAPHER: We are now on video 9 record. This is Media Nusber One in the 10 videotaped deposition of Bradley Edwards in the 11 matter of Jeffrey Epstein versus Scott 12 Rothstein, Bradley J. Edwards, and L.M. 13 Today is Tuesday, March 23rd. 2010 et 14 10:00 a.m. We're here in the law offices 15 Of Searcy, Denney, scarola, Barnhart 4 16 Shipley, 2139 Palm Beach Lakes Boulevard, 17 West Palm Beach, Florida. 18 Hy name is Joe Kozak. I am the 19 videographer. The court reporter is Cindy 20 Hopkins from Prose. Prose Court Reporting 21 Agency. 22 Will counsel please introduce 23 yourselves, and then the court reporter 24 will swear in the witnesses. 25 KR. CRITTER: Bob Critton on behelf of the PROSE COURT REPORTING AGENCY. INC. PROSE COURT REPORTING AGENCY, INC. EFTA01100749 Page 5 Page 6 1 Plaintiff, Jeffrey Epstein. 2 I . GOLDBERG: Jack. Goldberger on behalf 3 of the Plaintiff. Jeffrey Epstein. MR. DERSHOWITZ: Alan Dershowits on behalf S Of the Plaintiff, Jeffrey Epstein, of counsel. 6 MR. SCAROLA: The record should reflect 7 that Mr. Epstein is also personally present. My name is Jack Sterol.. I am counsel on 9 behalf of the Defendant/Counter-Plaintiff, Brad 10 Edwards. 11 Thereupon, 12 'BRADLEY J. E0WMDS, ESQUIRE' 13 having been first duly sworn or affirmed, was 14 examined and testified as follows: 15 THE WITNESS: Yes. 16 DIRECT E)U1IIINATICII 17 BY MR. CRITTON: 18 O. Would you please tell us your full nave 19 and ix" your home address. 20 A. Bradley James Edwards, 21 22 O. Bete of birth, please. 23 A. 24 O. Mr. Edwards, have you ever had your 25 deposition taken before? PROSE COURT REPEOTING AGENCY. INC. Page/ 1 A. I—don't understand the question. 2 O. For whom do you work at the current time? 3 Are you an employee? 4 I as a partner In the law firm of Farmer, 5 Jaffe, Weissing, Edwards, Fistfni I Lehrman. 6 O. Is that a professional association? 1 A. Yes. 8 O. Md you said you're a partner. DO you 9 have your own P.A. or Is the only the Farmer -- what 10 was the second name. Jaffe? II A. Correct. 12 O. And I will refer to it as Former, Jaffe. 13 if that's all right with you. Is Farmer, Jaffe 14 itself a P.A.; that is, are you a partnership of 15 P.A.'s? 16 A. Yes. 1? Q. Do you have your own professional 18 association? 19 A. Yes. 20 O. Okay. What's it called? 21 A. Law Office of Brad Edwards, LLC. 22 O. You are the sole member of that LW? 23 A. Yes. 24 O. Md then your LLC is a partner of the 25 Former. Jaffe firm? 1 A. No. 2 O. okay. But you've counseled, you've 3 obviously taken a number of depositions both as a 4 Plaintiff and as a Defendant. You're familiar with 5 all the rules? 6 A. I know the rules. O. All right. Again if I ask you a question 8 you don't understand, if you would ask me or if yOu 9 want me to rephrase it, I will be happy to do that. 10 A. Yes. 11 NR. SCABOLA: Mr. Edwards, Mt. Edwards, 12 knows the rules. You can skip the 13 preliminaries. 14 MR. CRITTCN: Is that a form objection? IS MA. SCAROLA: No. 16 MR. CRITTON: Just a talk. 17 red. SCAROLA: It's a. it's a request that 18 you not waste our time. 19 HR. CRIT70N: I am not wasting your tine. 20 And if we hadn't gone through that, we would 21 have been done with them. Jack. 22 BY M. CRITTON: 23 O. Mr. Edwards, are you currently employed? 24 A. Yes. 25 O. Md by whom are you currently employed? PROSE COURT REPORTING AGING,, INC. Page 8 1 Correct. 2 And do you hold yourself out to the public 3 as being a partner of that fire; that Is you 4 individually? 5 A. What do you mean by hold myself out to the 6 public? 7 O. If I got your letter would your letter say. if I received a letter from you would It say 9 Brad Edwards. partner, or something to that effect? 10 A. I don't think so. 11 Okay. What does your card say? DO you 12 have a business card? 13 1 do. 14 O. Okay. Mar doss your business card-- 15 A. Attorney. 16 O. -- reflect? And when you introduce 17 yourself to clients or other attorneys for the first 18 occasion, do you Introduce yourself as a partner of 19 that firm if asked? 20 A. If asked are you a partner; is that your 21 question? 22 O. Correct. 23 A. Mould 1 say yes? The answer is yes. 24 Q. When did you Start -- I want to strike 25 that. DO you consider yourself an employee of the PROSE COURT REPORTING AGENCY, INC. PROSE COURT REPORTING Aar', INC. EFTA01100750 Page 9 1 partnership? 2 A. What do you mean by that? 3 Q. Do you understand what an employee Is? 4 A. I work for the firm. 5 O. You are certainly not -- 6 I am employed there, to. yes. 7 0. When did you start your esaociation with the farmer. Jaffe firm? 9 A. Sometime during the month of November, 2009. 10 O. And IS that when the firm was incorporated 11 as a professional association? 12 A. I believe so. 11 Q. The attorneys who are In the current firm, 14 are they all former Rothstein Rosenfeld[ Adler 15 attorneys: that 1s, the professional staff? 16 A. Yes. 17 Q. Is there anyone -- Let me strike that. 18 Do you have paralegals as well that 19 work there? 20 A. Yes. 21 Are any of the paralegals former, and if 1 22 refer to Rothstein Roaenfeldt Adler as AM. or PRA, 23 is that all right with yov? 24 . A. I understand what you mean. 25 Q. Are there any other, are any of the PROSt cOURT IMPORTING AGENCY. INC. Page 11 1 O. She's your current eecretery/paralegal, or 2 do you have a secretary as well? 3 A. I don't understand your question. 4 O. Do you have -- is Beth Williamson your 5 paralegal? 6 A. She's a paralegal at the law firm of garner. 1 Jaffe, weissing, Edwards, ?limos a Lehrman. 8 Q. Does she primarily work for you? 9 A. No. 10 Do you have a Secretary as well? 11 The law firm? Yes. 12 The secretary who works primarily for 13 II 15 O. You jest use whoever is available from a 16 secretary standpoint? 11 A. No. 18 Q. Who do you primarily use for secretary 19 services? 20 A. There is nobody who could fall into the 21 category of who I primarily use. 22 Q. Ma. Williamson. who, by whom, who, who was 23 the attorney at AAA with wham she primarily worked? 20 A. I believe it was several attorneys, and 25 can't tell you who the attorneys were that she worked Page 10 1 paralegals that are Currently employed by Farmer, 2 Jaffe in any capacity whether they are independent 3 contractors -- well. let me strike that. 4 As employee's, 1 probably should ask this question: Does the firm. Farmer, Jaffe have 6 employees -- 7 A. Yea. O. -- separate and apart from the partners? 9 A. Yea. 10 O. And they are actually employed by the 11 P.A., correct? 12 A. Correct. 13 Q. Does the firm have any paralegals that 14 came over from the BAA firm, RM? 15 A. Yes. 16 Q. WhO are they? 17 Marla and Seth. 18 O. Does Maria have a last name? 19 A. Yes. 20 O. What is it. Please? 21 A. I believe it's pronounced Kelljian. 22 Q. Can you spell it? 23 I can give it my best shot. 24 Q. And Beth's last name is what, please? 25 A. Willlamson. MOLE COURT REPORTING AGENCY, INC. Page 12 1 for or with. 2 Did she work with you at all at BRA? 3 A. In some limited capacity. maybe. 4 Q. Did she ever work on any of the -- you 5 have three cases that you ever filed -- or let me 6 strike that. 7 There are three cans that are in 8 existence at the current time. One is Jane 00* 9 versus Mr. Epstein which is, is a federal court case 10 and the Plaintiff's name is Jane Doe. That is one 11 of your cases, correct? 12 A. Correct. 13 Q. Or one of the firm's cases at the Current 14 15 time? Correct. 16 There le another case versus L.M. Versus )7 Jeffrey Epstein and a third called C.M. versus IS Jeffrey Epstein. correct? 19 A. Yes. 20 0. And as a result all three of those cases 21 currently now are firm , the farmer, Jaffe firm 22 cases? 23 A. Yes. 24 Q. Did Mrs. Williamson work on any of those 25 cases? PROSE COURT ILEICItTING AGCMCY, INC. PROSE COURT ItUVRTING AGENCY, INC. EFTA01100751 Page 13 1 A. In what time period? What's your question? 2 Q. I'm sorry. During the time that you were 3 associated with KM. did Mrs. Williamson work on 4 those cases? S A. Without you needing to ask 20 different 6 question to pet to your answer, I will tell you her involvement was that after federal motions were drafted, 0 she was the person to literally file the motion. That 9 is her only involvement with the cases while at RIM 10 She basically filed them through the Pacer 11 system? 12 A. Exactly. 13 0. Prior to you working at Farmer, Wee by 14 whoa were you employed? And by employed I mean In. 15 in a broad sense. You could have been an 16 independent contractor. You could have been a 17 partner. You could have been an employee. 10 A. The law firm of Rothstein Rosenfeldt Adler. 19 0. When did you start working for RM? 20 A. 1 believe April of 2009. 21 O. Beginning of April? 22 A. Yes. 23 O. 1 saw a pleading that was filed yesterday 24 and it was either E.N., I am sorry, L.M. or E.N. 25 that looked like there was a change of -- I'm sorry, PROSE COM' REPoRTING AGENCY. INC. Page 15 1 substitution of counsel. Did you, were the 2 substitution of counsel's filed the exact date that 3 you started with RRA? 4 A. I don't remember. 5 O. When did your association with MA 6 terminate or end? 7 A. The end of October 2009 or the beginning of 8 November 2009. 9 O. And Now did it terminate? Now did your 10 relationship with RM terminate? 11 The fine closed. 12 Q. Did you get, notification -- when you say 13 closed. meaning what? 71 A. Meaning what everybody in this entire roan 15 knows Is that the firm went from operating to no longer 16 operating. 17 Q. And how did you receive notice: that is. le did you receive some sort of notice that told you 19 that MA now is a defunct firm? Did you receive 20 notification that was in bankruptcy? What, if 21 anything, did you receive? 22 1 didn't receive anything. 23 And then how did your relationship with 24 RM end? 25 A. Came to work on a Monday morning, and there Page 14 notice of appearance or something by RIM would 2 that. in any way, If I asked you to assume that 3 that's correct, would that refresh your recollection 4 that it may have been at the end of March? 5 A. I don't understand that question at all. 6 Q. I paw a pleading that was filed or -- 7 Yesterday you said. -- a paper that was filed. 1 was looking 9 at a pleading filed in either E.M. or L.M., and 1 10 saw a paper that was basically a notice of 11 appearance on behalf of RM And it looked like it 12 was dated around march 30 of 2009. 13 A. Okay. 14 Q. Is it possible that you started your 15 association with BRA at an earlier date than April 16 of '09? IT A. Misusing that what you said is true, if that 18 document says that, then it's possible that is an 19 accurate reflection of when I beam. 20 O. Did you start working with RM before you 21 filed any documents representing that RRA or that 22 you had now an affiliation with RRA? 23 No. 24 Q. where the -- again, I don't remember. . 25 whether there was a notice of additional counsel or MEM COuRT ItteoliTim AGENCY, INC. Page 16 1 was a meeting that was held informing all the employees 2 including myself that the firm no longer was financially 3 able to survive and therefore would be immediettly 4 doming down. 5 Q. Mho was the spokesperson at the meeting, 6 the min individual who advised those assembled in the room that that's what was going to occur? 8 A. I don't remember. 9 O. Was it -- did Rosenfeldt speak at all at 10 that meeting? 11 I, I can't remember. 12 0. Do you remember the date Of the meeting? 13 A. I remember that it was a Monday. 14 O. Do you temealier it being in October or 15 November? 16 Either the very end of October or the very 17 beginning of November. 18 Q. Did anyone -- well, let me strike that. 19 Do you remember whether the person -- let me strike 20 that. 21 At the meeting who was present, and I 22 don't mean individual names. Who did it, by groups, 23 who did it include? 24 A. The meeting was held in a cafeteria type room 25 in the building where RRA maintained its offices. And PROSE COURT REPORTING AGENCY, INC. PROSE COURT REPORTING AGENCY. INC. EFTA01100752 Page 11 1 the room was completely full to capacity with as many 2 employees of the Rothstein. Ronnfeldt Adler firm as 3 were in attendance at work that day. Q. And included lawyer.. paralegals, support 5 staff. investigators? 6 A. Literally -- 1 O. everyone, 1 mean everyone who obviously showed up at the meeting? 9 A. I don't know. 10 Q. Did you see other lawyers there? 11 A. Yes. 12 Q. Did you see staff there? 13 Yes. 14 Did you see paralegals there/ 15 Yes. 16 O. Did you see investigators there? 1? A. 1 Can't necessarily remember whether or not I IS saw investor -- investigators there. 19 O. And did more then one person speak et the 20 meeting? 21 A. I don't remember. 22 Q. Okay. what else were you advised at the 23 meeting. If anything? 24 It was -- I stayed for very little of that 25 meeting. I don't know what was advised to others, but PROSE COURT REPoitnIC AGOICY. INC. Page 19 2 A. I don't believe so. • 2 O. Okay. Mae anyone preventing you from 3 taking anything? 4 A. No. 0• Okay. Did you print Out any documentation 6 from your server or from the flrn's server that day to take with you? 0 A. Not that I recall. 9 O. Do you recall taking anything free 10 RM•offin that day, that day being that same 11 Monday? 12 A. No. 13 Q. Obviously Scott Rothstein was not there? 14 A. Correct. 15 Rave you ever spoken, excuse me, have you 16 ever seen Mr. Rothstein since that Monday at the 1? meeting? 10 A. What do you mean have I seen him? 19 Seen him in person, I'm sorry. 20 A. No. 21 Q. Okay, have you spoken with him at any time 22 since the Monday meeting at which time you were 23 advised that the firm was shutting down? 24 25 0. Have you spoken on any. with anyone on his Page 16 1 what I heard was, tins is closing down. That's all I 2 needed to hear and I left. 3 O. Did you subsequent -- well, let me strike 4 that. Did you, were you able to gain. pain access 5 to the building that day? 1 am sorry, access to 6 your, to the offices of the Rothstein firm that day? 7 A. Yes. 6 Q. And were you able to access any of your 9 files or your e-mail at that time? 10 What time? 11 That same day, that Monday that you were 12 advised that the fine was shutting down. 13 A. Yes. 14 O. And were you able to print documents? 15 Well, let me strike that. Were you able to take 16 documents relating to matters on which you worked 17 from the firm? 16 A. What do you mean by was I able to/ 19 Were you able to access and take with you 20 documents that related to files on which you were 21 working the preceding Friday when you were at RRA? 22 A. I believe so. 23 Q. Did you take, did you actually remove 24 documents, papers that were related to tiles that 25 you had on which you were working from PRA that day? PROSE COURT REPORTING AGENCY. INC. Page 20 1 behalf: that is, who purpOrte to represent 2 Mr. Rothstein since you left the firm that day? 3 A. No. 4 O. DO you know Mr. Malt? Yes. 6 O. Do you recog -- are you aware that he 7 represents Mr. Rothstein? 0 A. Yea. 9 Okay. have you spoken with him since that 10 Monday? 11 Me called me on a morning before a hearing to 12 ask me where Judge Crow's courtroom was. And I told 13 him, and that was the extent of that conversation. 24 Otherwise. I have had tero communication with Marc 15 Pura. 16 Q. With regard to the firm being advised that 11 the firm was shutting down on that Monday. did you IS subsequently return to the firm's offices? Let me 19 Stalks that. Now long did you stay at the fine that 20 day? 21 A. 1 don't remember. 22 0. Did you stay all day? 23 I believe so. 24 Were you able to work on your files? 25 I don't understand the question. PROSE COAST Unwell.; AGENCY. INC. PROSE Ord REPORTING AGENCY, INC. EFTA01100753 Page 21 1 0. Were you able to do legal work on the 2 matters that wherein you represent individuals? 3 Was 1 able to? Yes. I was physically able to do that. 5 Did you work on legal matters that day? 6 A. No. 7 Did you subsequently. after that date, did you return to the PRA offices? 9 A. Yes. 10 O. And where are those offices or where were 11 those offices located? 12 Las Olas. 13 Q. The address, please? 14 A. I don't remember. 15 O. With regard to the -- 16 A. 401. 17 O. Las Oles? 10 A. Oneness nods head.1 19 O. Did you, did you after that Monday did you 20 return to the offices at 401 Las Dlas. the RPA 21 offices? 22 Yes. 23 And did you return every day thereafter 24 for a period of time? 25 A. No. PROSE COURT RESORTING AGENCY, INC. Page 23 1 entry to the office? 1 don't know. O. Well, who would, who would monitor whether 4 you came In or couldn't go into the office? 5 I don't know. 6 Q. Was there someone there? 7 A. Was there someone where? O. The Ispression I got Is that there was 9 some limitation on your ability to access the PM 10 offices after the Monday at which time you were 11 advised that the firm was shutting down. Did 1 12 misunderstand you? 13 No, that's correct. 14 Okay. Wh0 then, if you know, Or whet, if 15 it was an entity, placed any restrictions On your 16 access to AAA offices? 17 A. I don't know. IS O. When you would go to the office -- well. 19 let as strike that. After how many days -- well. 20 let ne strike that. 21 The very day, the same day that you 22 were advised that the office was closing down, were 23 there any individuals that were monitoring whit, if 24 anything, was to be removed or not removed from the 25 office, like a security force. Steward County Page 22 1 O. Was there a point in time that you were 2 prevented from entering your office or the offices 3 of AAA? 4 yea. 5 At what point in time were you prevented 6 from going into the offices? 7 A. I don't remember. B O. Mow many days were you able to access the 9 officer before you were prevented? 10 A. I don't remember. 11 O. YOu don't know whether it was a day or 12 three days or five days that you were allowed to go 13 into the office? 14 A. The period of time that I was able to go into 15 the office encompasses all of them things that you just 16 did. one day, three days, five days, yes. I can 17 definitely say with certainty 1 was able to do that. 16 O. During the month Of October were you 19 allowed to go into the office more than ten days? 20 A. Yes. 21 O. Did they put -- well, let me strike that. 22 Did someone put restrictions on what your access was 23 to the office, the MA office? 24 A. Yes. 25 0. Okay. Who put the restrictions on the PAOSt COURT REPCeTne AGEACT. INC. Page 24 1 Police, U.S. Marshals. 2 A. From my recollection there were at some point 3 in time, there were people In the office monitoring 4 activity in the office. 5 O. Was that the first week after the Monday? 6 A. I don't recall. 7 O. Did you ever, did you receive any guidelines either at the Monday meeting or 9 thereafter es to what you could or could not remove 10 from the file, from the, I'm sorry from the Pith 11 offices? 12 A. I believe so. 13 Q. And who put those guidelines out, do you 14 recall? IS A. No. 16 O. Were they in a written form? 1? 16 Okay. Was given in what fora. how did you 19 learn what you could and could not take from the 20 office? 21 A. More rumor than anything else is what I 22 remember. 23 O. Old you discuss that with other 24 individuals or other attorneys who were working et 25 RIM? PROSE COURT REPORTING Meier. INC. PROSE COM/ REPORTING AGENCY. INC. EFTA01100754 Page 25 Page 26 1 A. Possibly. 2 Q. Did you ever attempt to remove something 3 from the office of the /MA offices and someone 4 prevented you? 5 A. NO. 6 Q. Old you ever -- and when 1 say remove I 7 mean an the sense of physically remove: that Is. I tate Oct boxes or take out files or something of 9 that nature. 10 A. 1 understand the definition of remove. 11 O. With regard tou there were also, 1 12 understand you had an e-mail server at the office? 13 A. Okay. 34 O. Is that correct? 16 A. Yes. 16 0. And I have seen something, there is 17 something that's called Otask. Ate you familiar Is with Qtask? 19 A. Yes. 20 O. And what do you understand Otask or what 21 did you understand that Otask did: that Is, as an 22 electronic service? 23 A web based network to Stott files and other 24 mat OOOOOO 25 Q. In terms of electronic storage, or PRIME Cain mmaTING AGENCY. INC. Page 27 1 wanegenent system: that is, did you utilize the 2 software that was available? 3 A. yes. 4 O. And had you ever used a system like that 5 before you came to the PM firm, PM? 6 A. I don't understand. 7 O. Okay. Mad you ever used an electronic 8 case management software system before you cane to 9 PM? 10 A. Yes. 11 O. Was yours the system that you had used 12 before was that were you able to integrate that with 13 ARA, with the BRA file or system when you got there, 14 or did your files have to be put on the new AAA 15 system? 16 A. The latter. 17 O. In addition, so we had the e-mall server, 18 Otask, and electronic case management system. Was 19 there any other type of electronic storage or system 20 that was available for communication or 'torso, at 21 ARA? 22 A. Not that I recall. 23 O. With regard to the s-mall States. well, 24 with regard to the e-mail system, Quist. and 25 electronic case management. did you require. was 1 electronic date at the RR. firm. in addition to, 2 excuse mom. the 6-mall server was and Octet. wee 3 there anything else from an electronic storage or 4 communication means through AM? 5 A. Yes. 6 O. What else was there? 7 A. That stored electronic materials? 0. Pint. or that you could communicate with 9 someone elm either Inside or out of the firm. YOu 10 heel the server, e-mail server. You had Qtask. What 11 else did you have? 12 A. To communicate with others, e-mail and Otask. 13 O. And how about within the Confines of the 14 firm, was there another electronic mail system Or 15 electronic system either for storage or for 16 coamunication? 17 A. To the best of my recollection, none for la communicetion. Storage, yes. There were electronic 19 paperless storage case management systems in place. 20 And with regard to the electronic case 21 management system, were yOur files, including the 22 three cases involving Kr. Epstein, were those cases 23 on the electronic case management system? 24 A. Yes. 25 Q. And could you access the electronic case PROSE COURT RETORTING AGENCY. INC. Page 28 there a password required to use or access each one? 2 A. No. 3 Q. Was there a password required to use any 4 of the three? 5 A. I don't believe so. 6 0. As 1 saw in an order that with the Otask system that there was some sort of access code that o was required co get into Qtask. 9 A. I saw that too. 10 Q. Did you ever have, did you Over have such 11 a code or a password with regard to Qtask? 12 A. I don't remember. 13 O. Was the receiver and/or it's, Ns. Seton or 14 hie attorneys asked for you to provide any passwords 15 or information to access any of your filet? 16 A. I don't think so. 17 Q. DO you understand that you have a 18 requirement or you're required to give the password 19 If requested by Mr. Secon? 20 A. I don't know the password to elm to anybody. 21 I never know there was a password. 22 O. Did you -- 23 A. I don't believe. 24 O. Did you use Qtask? 25 A. I have used otaek. PROSE COURT REPORTING AGENCY, INC. PROSE COURT REPORTING AGENCY, INC. EFTA01100755 Page 29 Page 30 1 Q. With regard to your, the tiles 2 specifically, specifically the -- well, let me 3 strike that. During she time you were at RRA, of 4 the three files. Jane Doe, and C.Y. or in 5 addition to those throe files, did yOu represent any 6 other individuals who were potential claimants 7 against Mr. Epstein? 0 1 don't believe to. 9 All right. I received notification from 10 you as to a Ma. N.R.? 11 A. N.A. 12 O. N.R. and Na. D.F. I believe is her name? 13 A. Correct. 14 O. Were either of those individuals, had 15 either of those individuals contacted you Prier to 16 leaving the MA firm? 17 I don't believe so. IS Is it your testimony then that none. 19 neither Ma. N.P. nor Ma. D.F. would have had a fee 20 agreement or representation agreement with the RRA 21 firm because they hadn't contacted you prior to your 22 departure from that firm; is that correct? 23 A. I'm not sure. 24 O. Is it possible that Ms., either Ns. N.A. 25 or Ns. D.F. contacted you before you left the RAA PROSE COURT REPORTING AGENCY, INC. 1 2 3 5 6 8 9 10 11 12 13 14 15 16 17 at some point did you get full access to all of your 16 e-mail that, that existed at least, that you had not 19 removed -- let me start again. 20 Under an e-mail server you, you have 21 the ability, obviously, to delete whet you, what you 22 choose, correct? 23 A. As do you. 24 Q. As do I, right. And were you using like • 25 Microsoft Outlook program? Page 31 either just before or just after I do believe 1 spoke with one or maybe both of them on at least one occasion before the disbandment of AM And I know for a fact I signed each One of the clients up after the disbandment of AAA I can't tell you with any degree of certainty whether they signed a fee agreement with RRA prior to the disband•ent. O. Have you been able to do any transfers of your, of -- let me strike that. Mich regard to the e-mail server at ARA. have you had occasion to access that since that Monday: that Is, the Monday meeting that you referred to in either late October or early November of '09? A. Yes. O. All right. And have you had full access, 1 firm but you just didn't sign them up before you 2 left? 3 MR. SCAROLA: Objection, calls for 4 speculation. 5 THE WITNESS: Yes. 6 AY MR. CIOTTON: 7 O. la there a reason that you would not have 8 signed them up during the time you were with -- or 9 let me strike that. Prior to the implosion, prier. 10 prior to that Monday when you were advised that the 11 PM first was closing down, had you made any plans to 12 leave that firm, that is the ARA firm? 13 A. NO. 14 0. okay. Had you discussed with any other 15 attorneys in RPA departing from PRA or the RPA firm 16 prior to that Monday meeting at which time you were 17 advised that the firm was shutting down? 10 A. NO. 19 O. You indicated it's possible that Na. N.P. 20 or Ms. D.F. may have contacted you prior to your 21 departure or prior to that Monday meeting. what 22 makes you believe that? 23 A. I don't remember exactly the timing of any 24 communications between myself and Ms. O.F. Or Pls. N.R. 25 And it seems to me that it was around the time period PROSE COURT REPORTING AGENCY, INC. Page 37 I don't remember. 2 Okay. 3 A. I am now. 4 0. Nell, with the program that you did have, 5 could you delete it and then you would have to go 6 into the delete It and further delete it to Clean It out? B A. I don't remember. 9 Q. You don't remember back to October or 10 September of '09 et this point? 11 A. That's just not what I do. I mean, 1 don't 12 just delete ♦-ails. So I don't know what you had to 13 do. You take me for somebody more e-mail savvy than 14 am about that. 15 O. DO you basically save all your e-malls or 16 had you in the past when you were at PRA/ 17 A. I don't intentionally save or delete. They 10 are just there. 19 O. And when you, when you, at some point 20 after the Monday meeting, were you able to transfer 21 whatever e-malls you had from RRA to your current 22 program? 23 At Farmer. Jaffe, Weissing? 24 Q. Correct. 25 A. No. PROSE COURT REPORTING AGENCY. INC. PROSE COUNT REPORTING AGENCY, INC. EFTA01100756 Page 33 Page 34 1 7 5 6 7 9 10 11 12 13 14 15 IA 17 16 19 20 21 22 23 24 25 O. Were you at some point given access to all your e-malls so it could be downloaded either on a disk, hard disc, floppy disk, or some other storage medium so that you had access to all your prior e-mails when you were at ERA? A. 1 don't know. Q. Did you ever make that request to someone, either the receiver or anyone else associated with MA? 0. 1 don't remember if I made that request. I thought you indicated earlier, Hz. Edwards, that you had access to some of your e-mails. A. I had access to all of my e-malls on that Monday of the meeting, on the neat day, on that Tuesday, right, the immediately following the meeting. 32:46 at soma point In time it was cutoff and since that time, when it was cutoff. I don't believe I have ever had access back to my entire e-mall System. Q. Okay. Nave you had scout to portions of your e-mail system? Not that I remember. Nave you attempted to obtain access or requested that you obtain.access or information from your e-mail, Ire the AAA e-mail PROSE COURT REPORTING AGENCY. INC. 1 2 3 5 6 7 9 10 11 12 13 14 15 16 11 16 19 20 21 22 23 21 25 'paralegals, other Staff et PM? Yes. And would you see, receive, if it was 0. Page 35 something from one of the other partners at ERA would you receive: that Is, did you get fire-wide e-mails from time to time about Specific topics? A. Yes. Q. All right. When you, during the time that you want back to AAA, did you printout, and up until the time you were denied access to the e-mail server, did you ever print, printout any e-malls or transfer any a-mails that you can recall? A. Not that I can recall. Q. All right. With regard to the Otask system, have you been, since that Monday have you been able to use that system in any fashion? What do you mean by that? Have you been able to access Otask either to look to see whet was there or in the alternative pull information from so that you could printout information from Otask? I don't know. Probably. Okay. Have you attempted since that Monday -- well, after that Monday meeting -- let me strike that. 1 2 3 4 5 6 7 6 9 10 11 12 13 14 15 16 17 le 19 20 21 22 23 24 25 . A. I don't remember. 0 - You say yOu don't remember. Would there have been a reason that you either requested or didn't request access to your prior e-mail? When say prior 1 mean at ERA A. Usually you read all of your e-nails and there shouldn't be anything that I had not read. However, there are some 4-nalla that you would like to keep around. So there may have been reason for me to have requested. However. I don't believe I was ever granted access to those e-mails, and I can't specifically remember requesting the a-malls. Q. Within, within the e-mails you would have corresponded with or communicated with people outside of the firm and as well as people within the firm, true? A. Ever, yes. Q. During the time you were ERA A. Did I ever communicate with somebody outside? I connunicated with you. 0. Correct. A. So you know that to be true. Yeah, of course. I know that to be true. And my question is as well within the server or e-mail system with ARA, did you ever also communicate with other PROSE COURT REPORTING AGENCY, INC. 2 3 5 6 Page 36 Since the meeting that occurred on that Monday et which time you were advised the firm was shutting down, have you accessed Otask for any reason? A. 1 don't believe so. 0. What kind of -- you said, you described 7 earlier that (Malik was a web based network of files A for files and other materials. And in what fashion 9 did you use Otask during the time you were with AM, 10 11 12 13 14 IS 16 AM? A. Qtask is a project centric web-based Program. So projects could be created. The project would normally be a case, and that use discussed with lawyers the way that you may gather around a table end discuss it. And at times I was invited to projects on various Cases and utilized that system. 17 IS that the only fashion that you would 16 have used Otask during the time you were with ARA? 19 Yes. 20 And when you say a project, as an example. 21 Jane Doe versus Jeffrey Epstein, if that had been 22 put, just this is hypothetically end then I will ask 23 you later whether that was in the system but if you 24 wanted or let me strike that. 75 Could Jane Doe versus Jeffrey Epstein PROBE COURT REPORTING AGENCY, INC. PROSE COURT REPORTING =ACT. INC. EFTA01100757 Page 37 1 been put in the Otask program for, for purposes of 2 creating a project? 3 Repeat it again. 4 Okay. Could a case like Jane Doe versus 5 Jeffrey Epstein been put in the Qtask system as a 6 project so that you and others <Quid look at It7 1 A. You mean is. 1s, is the project capable of 0 holding such a project? 9 Ye.. just generically. 10 A. Yee, yes. 11 0. And in terms of the RRA system, did the 12 PRA system ever nave as. as a project Jane Doe 13 versus Jeffrey Epstein? 14 A. 1 don't believe so. 15 Q. Dld you ever look fn the Qtask, Qtask 16 system to determine whether you or anyone on your 17 behalf or any other person In the firm had ever put 10 Jane Doe versus Jeffrey Epstein Into the Otask 19 system? 20 A. Yes. 21 O. Okay. And what did you find or not find? 22 I, I don't remember if that was the name of 23 any project in the system. It could have been, but it 24 may not have been. 1 don't remember that as a specific 25 project in the. system. MISS COURT REPORTING AGENCY. INC. Page 39 1 Fortis spites before you cam* to Rothstein -- 2 A. Had 1 ever used Fortis before I came to ABA? 3 0. Yes. 4 A. Mo. 5 0. Mow, back to Otask. Did you, do you have 6 a recollection -- let a strike that. Did you ever 7 personally ever put any information into the Qtask e system for a project -- 9 A. Yes. 10 Q. -- on your cases? 11 A. Yes. 12 Q. Did you ever put, and 1 think you just 13 testified as to the best of your recollection, Jane 14 Doe versus Jeffrey Epstein was never put into the 15 Otask system, correct? 16 A. As the name of a project? 17 Q. Yes, sir. NO. I don't believe so. 19 Well, was, when you say the name of • 20 project, could, could information about Jane Doe 21 versus Jeffrey Epstein have gotten into the system 22 but not identified as a, quote. unquote, Project? 23 MA. SCARO/A: Calls for speculation. 24 MR. CAITTOM: Do you understand the 25 question, sir? Page 31 1 Q. When you say a specific project, sf 1 2 understand you correctly, Mr. Edwards. that would 3 hive been, as an example. it could be any case. It • could be a real estate case, it Could be a labor 5 case. it could be Jane Doe versus Jeffrey Epstein. 6 but someone could, someone whether it was you or 7 someone else could put In facts and information • about the case? 9 Similar to any case management system that's. 10 it just happens to be web based, but you have the right 11 concept. 12 O. Is the concept the same concept for en 13 electronic, for the third electronic system, you had 14 the electronic case management system? 15 A. 1 suppose at full capacity it. It may. 1 Jost 16 wasn't that adept at °task to know all of the 17 capabilities of Qtask. le 0. With regard to the third item which I am 19 going to COM back to (Mask In lust a minute, the 20 electronic case management software, what was the 21 name of that software? 22 I believe ft's called Fortin. 23 Q. F-o-r-t-1-$7 24 A. I think so. 25 O. 1 may have asked you, have you ever used a PROSE COURT REPORTING AGENCY. INC. Pager 40 THE WITNESS: 1 don't'understend. 2 MR. SCAROLA: Are you asking whether that. 3 that capability existed? 4 MR. CR1TTON: Sure. THE WITNESS: Did the capability exist? 6 MR. CRITTON: Right. Again Mr. SCarOle 7 didn't want to let me go through the 8 explanation because he thought you understand 9 it and I know you did, Brad. I know you 10 understand. 11 THE WITNESS: 1 don't know that 12 understand that question. I want to make sure 13 that 1 answer your question accurately. 14 MR. CR1TTON: See, cut me off too early, 15 earlier. 16 MR. SCAROLA: No, too late. 17 BY MR. CRISTO*: le Hz. Edwards. what 1 am trying to get is 19 you described the Qtask as being project centric. 20 And as 1 understoOd St. the project may be given s 21 label or a title? 22 A. Correct. 23 Q. So, it could be Jane Doe versus Epstein: 24 It could be Jane Doe; it could just be assault case: 25 is that correct, whatever you wanted to cell or NOSE COURT REPORTING AGONY, INC. PROSE COURT REPORTING AGMs. INC. EFTA01100758 Page 41 1 someone wanted to call the project? 2 A. You have the right idea. 3 O. And if I understand it correctly Is In 4 terms of the project, is if it was, If it was as an 5 example the Jane Doe case, you could, you or anyone 6 else could put Information in about Jane Doe. might 7 not call it Jane Doe, but whatever amount of 8 information you or anyone else wanted to put in, 9 could put it into the Qtask so that other attorneys. 10 staff, investigators, paralegals, anyone whO could 11 access the (Mask system, could see that project• is 12 that correct? 13 A. So that the people that were invited to the 14 project could see the project and those people only. 15 Q. And when you say invited to the project. 16 is. would, would, assuming you're the person who 17 created the project -- 18 A. Okay. 19 -- would you then set the parameters as 20 to, or the guidelines as to who could come into the 21 project? 22 A. Maybe. 23 Okay. If. again. If It wasn't you, who 24 else could have set the parameters: that is. who 25 else can access the file? PROSE CCORT REPORTING AGENCY. Page 43 1 O. Would I only aim pictures or would I see • 2 names as well? 3 A. 1 don't remember that. 1 Q. Would it be a correct statement that 5 during the time you were at R . you did use ;Mask? 6 A. Yes. 7 0. And did you ever put projects; that is, B did you ever es the lead create projects through the 9 Otask system? 10 A. Yes. 11 O. Would someone else, would, assuming that 12 you were the lead and you created the project, would 13 only you be able to add information to Qtask? 14 A. No. 15 0. Okay. Wee, was any invitee Or person 16 allowed access. was he or she allowed to add to 1? (Mesa? 16 A. Correct. 19 Q. Okay. Would he or she also be able to 20 delete from (mask If they were an Invitee? 2) A. I don't know that. 22 O. Were you ever, did you ever -- In any -- 1 23 assume that you were not only the lead but from time 24 to time you were invited into (Mask: Is that 25 correct? Page 42 1 A. let's say 1 an the lead on a project: I 2 believe that is what It was called the. I believe that 3 was the title given to the person that initiates the 4 project, If I want to then Invite one or two or three or 5 100 other attorneys to that project to help work on 6 various aspects. I could do that. 7 And if I didn't choose to add somebody, and another attorney said make me a lead 9 so that I can add somebody, that's another way that 10 that other lead could have invited somebody else co 11 the project. 12 And when you open up the interphsse 13 of (Mast, you're Immediately shown a portfolio of or 14 a photograph of the people that are invited CO the 15 specific project and those people can access It. )6 Q. So, if it was, as an example. If It was. 11 if you were the lead person and you invited 18 Kr. Adler and you invited Mr. Seeger in and 19 Kr. Rothstein in, there, when you punched up the 20 Otask on the screen, 1 would see Mr. Rothstein's 21 picture. I would see yours. I would see 22 Mr. Berger's and Mr. Adler's? 23 Correct. 24 Q. As an example. 25 A. Yes. PROSE COURT REPORTING AGENCY, INC. Page 44 1 A. That's correct. 2 O. And during the time that you did, you, 3 when you were the lead. sae you the one who chose 4 what went into the file, to the (Mask file? 5 6 O. Who would have mSde that decision? 7 A. Everybody in the, anybody that's invited can 8 add. I'm not the one that does It. Nobody has to roan 9 to me to insert anything in the (Mask. You can add if 10 you're Invited. 11 O. Well, let's assume that you are, you're 12 the lead but you don't invite anyone: that is, you 13 create the 45:01 time project. You're the person 14 doing the adding, not scant/Ise but you're the 15 person that puts the information in. 16 A. 1 understood the question until you added the 17 segment about maybe some Staff member helps you add the 18 (mask. That just doesn't make sense with the program. 19 Q. Nell. with (Mask, If you're the lead and 20 you don't Invite anyone in because you're creating 21 the project itself, are you the person who chooses 22 exactly what goes in? 23 A. I am the person who puts in what gees in. 24 Q. All right. Are you, are you responding to 25 questions within Otesk where you put, you describe PROSE COURT REPORTING AGENCY, INC. most Com REPORTING roomy, INC. EFTA01100759 1 2 3 4 5 6 7 B 10 11 12 13 14 IS )6 I7 18 19 20 21 22 23 21 25 Page 45 the case. You describe the facts. You describe the witnesses, thing, Of that nature. or are you actually, can you -- well, first of all can you do that? A. Can you describe the case and describe the facts? Yes, you can. Q. And is that, when you say project centric. Is that what you're doing very much like the electronic, much like the Portia program? A. It's not very much like the fortis program in my mind, but it's, It is whit you are doing, you're inputting information about a specific project. O. Can you put in the facts about a case, again lust generically, can you put in facts about a particular case and then ask someone In your invitees to comment on what they think, might think the value of the case is or is not and give suggestions as to OleCOVery and things of that nature? Is that all true? A. Yea. O. And with regard to -- and once those invitees show up and they're photographed, then each of those Individuals can have access to the file and add their thoughts or opinions -- - A. Repeat lt. PROSE COURT REPORTING AGENCY, INC. 1 2 3 4 5 6 B 10 11 12 13 14 15 16 11 18 19 20 21 22 23 24 25 Page 47 Q. And why do you believe that to be true? A. It's not how the system works. O. Well, at least as you understand the system? A. Well, if you want to tell me that it works a different way, then maybe you can persuade :re but that's how I understand the system. I am not, I'm not arguing with you. PEA. SCAROLR: Actually you are. THE WITNESS: Assuming you had boon on Qtask, it would help to get past all of these questions. If you had been on Qtask it would help to get past all of this and you would see exactly what I am trying to describe to you. MR. cRITTCH: I would like to get on Otask. TUE WITNESS; Qtask.com. BY NR. CRITTON: Q. Okay. I'll remember that. With regard to, so as to whether or not Mr. Rothstein could have accessed It or Hr. Rosenfeldt or anyone else who was not an invitee at least from your knowledge, you believe they cannot access it? A. Correct. O. Can you as wall on (Mask, can you as well 2 3 1 5 6 1 8 9 10 11 12 13 14 15 16 17 )8 19 20 21 22 23 24 25 Page 46 -- or suggestions. Let me strike that. With regard to the Otask, once, once -- assuming that You're the lead, you Create the project and then you. you say. okay, now it's in a form that I want to get SOM. Invitees involved. Do you then fend that project; that is. you then on Otask you list the invitees end those people would be. get some sort of cue that they had been invited to the project up to the Qtask system? A. I don't remember the exact process for inviting, but there is a way to invite. And to the test of my recollection, they do receive a notification that they have been invited so that they con accept. Q. Okay. Can, can someone who has not been Invited also access the system) A. 0. A. 0. No. Okay. And how do you know that? That's Just not how the system works. Nell, ix may not be how the system works, but say if Hr. Rothstein wanted to access when he was the heed person at the KRA firm, he wanted to access the Q. Otask system, do you believe that he would have been able to access the system whether you Invited him or not? PROSE COURT REPORTING AGENCY, INC. 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 /6 17 IS 19 20 21 22 23 24 25 Page 48 post documents like an attachment? I believe it has that capability. I think the answer is yea. O. Now, with regard to the three cases that you -- well, with regard to Jane Doe versus Jeffrey Epstein. 1 think you already told me you don't recall whether you put that in Mask: 1$ that correct? I didn't tell you that. Okay. Let Me ask you then: Did you ever use °task, you personally create a project as it related to Jane Doe's case against Mr. Epstein? A. No. Q. To your knowledge did you direct anyone -- well, let me strike that. Did you direct anyone to crease a project on Ocala for the Jane Doe case against Hr. Epstein? A. No. O. Okay. Do you know have you ever have looked at the °Can system -- let me strike that. Prom what you were able to access Of the Quist system, did you ever go online on the Qtask system to determine whether anyone else had ever put the Jane Doe case against Hr. Epstein OA Otask? PROSE COURT REPORTING AGENcY, INC. PROSE COURT REPORTING AGENCY, INC. EFTA01100760 1 2 3 5 6 6 9 10 11 12 13 14 15 16 17 IS 19 20 21 22 23 24 25 Page 49 O. And therefore as you sit here today. you don't know whether someone else, whether it was another attorney, whether it was an investigator or a staff person ever put the Jane Doe versus Epstein case on Qtask] Or whether it was you, right. Q. Right. As to L.M., did you ever put L.M.'s case or direct -- well, let me strike that. Did you ever create a project for L.M. on (Mask? No. Q. Did you ever direct that someone else create a project in °task for the L.M. case, L.N. versus Jeffrey Epstein case? A. No. Do you have any knowledge as to whether -- let me strike that. Did you eve: goon Otask or have you been able to determine whether anyone else within the RM firm put the L.M. versus Jeffrey Epstein Cale or any aspects of it on °test? Nave you looted or do you know? A. I don't know. Q. Nos anyone told you that the L.N. case against Jeffrey Epstein was on °task/ PROSE COURT REPORT/NG AGENCY. INC. 1 2 3 5 6 1 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 51 regard to E.N. would be- any different than the answers given with respect to the other two cases. HR. CRITTON: I would have rather have it specific. Oftentimes judge want to see that. SO I understand that if I want something broad later on, 1 would be glad to accept that, but thank you. Do you remember my question. sir. THE WITNESS: No. BY M. CRITTON: Okay. With regard -- HR. SCMOIA: For the record let me observe I believe that your Insistence upon asking the individual questions that 20o have now asked twice with regard to the, other claims, and your refusal to ask the blanket question in the way in which I have suggested is an annoyance and embarrassment and a harassment of this witness which does nothing but unnecessarily consume his time. BY M. CRITTOW: Q. Mr. Edwards, with regard to C.R., did you ever put any aspects of that case/ that is, not just the pleadings but any aspeCta of the E.Y. Jeffrey Epstein case onto (Mask? Did you ever Page 50 1 Q. Okay. And so it's your testimony as In 2 as you know the L.N. versus Jeffrey Epstein case was 3 not ever on the Otask system: is that correct? 4 A. To the best of my recollection today. 5 0. When 1 describe both the Jane Doe versus 6 Jeffrey Epstein case and the L.M. versus Jeffrey 7 Epstein case being on Otask. I don't necessarily mean just the pleadings. I mean any aspect of it, 9 not necessarily the pleadings or the fact that the ID case was there but the factual circumstances 11 surrounding either case. 12 A. I em not going to get into what my 13 work-product privilege, I am not going to allow you to 14 pierce that privilege. I am not going to tell you what. 15 regarding those cases, was or was not on Otask. 16 O. Well, let me ask a specific question. So 17 if you want to claim some sort of privilege so the le record is clear. 19 A. Sure. 20 Q. With regard to. and let me go first to 21 the. finally to the E.Y. case. With regard to the 22 E.M. versus Jeffrey Epstein case or any aspect of 23 it, did you ever put E.M. into the Qtask system? 24. MR. SCAM:ILA: Let us save you scale time. 25 Why don't you ask whether the answers with PROSE coURT anCeTING AGIUKY, INC. 1 2 3 4 5 6 a 9 10 11 12 13 14 15 16 11 18 19 20 21 22 23 24 25 Page 52 create a project? KR. SCARO1A: You nay answer. THE WITNESS: There was never a project entitled to my recollection E.M. versus Jeffrey Epstein, L.M. versus Jeffrey Epetein, Jane Doe versus Jeffrey Epstein. And you're asking was any information about those cases ever put onto Otask? . CRITTON: I didn't ask that question. THE WITNESS: Okay. HP. CRITTON: But i will in just a minute. THE WITNESS: And my answer Is no, those titles are not, I don't believe were ever on Ot BY HR. CRITTON: Q. Now, separate and apart from -- let me strike that. Let me just stay with E.W. with regard rola Old anyone else at your direction put any information regarding C.Y. into the Otask system, en attorney, staff person, or secretary or another lawyer? O. system? A. I don't remember. what do you moan by information? My information about E.Y. into the Otask PROSE COURT REPORTING AGENCY. INC. PROSE COURT REPORTIM Aral. INC. EFTA01100761 10 11 12 13 24 15 16 11 10 19 20 21 22 23 24 Page 53 1 0. Okay. Sow* don't -- you gave a broader 2 response to a question or that is you rephrased the 3 question. So, let me ask it in a brooder sense. 4 was any information about the. your 5 three clients put into the Otask, about your three 6 clients, Jane Doe, E.N., and L.M. versus Jeffrey Epstein, or against Jeffrey Epstein, was any information ever put into the Otask system? I don't 9 want to know the information, just whether you put Information Into the Otask system. Yes. 0. Did you do it yourself or did you do it in conjunction with someone else? A. Explain to me what you mean by did 1 do it in conjunction with somebody else. 0. Noll, is, you ma y have typed in the information yourself. A. 1 strike one key; somebody else strikes another? O. No. you may have input all the information you want, whatever Information you want to put into Otask, you may have made the decision to do that. All right. My question is someone else, a secretary, or a paralegal may have helped you, an 25 investigator may have put some information in. at PROSE COURT REPORTING AGENCY, INC. • 2 3 4 6 6 9 10 11 12 13 11 15 16 11 18 19 20 21 22 23 24 25 Page 55 by Kr. Edwards unless we expressly tell you Otherwise. MR. CRITTON: All right. MR. SCAROLA: So, when 1 instruct him not to answer, he will follow that instruction. MR. CRITTON: And you will do that, correct/ THE WITNESS: That's correct. BY KR. CRITTON: O. With regard to the, the generic, and If understood you correctly that there was generic or there was information put in on one, two, or three of your clients' claims again Mr. Epstein, did you have or identity individuals who were invitees to that Otask filo? A. I'm sorry, what's your question? O. Did you designate individuals who could be invitees to that file? A. Did I Invite anybody Into the project? Sure. A. Yes. O. Okay. Who did you invite Into the Otask? And let me ask you this first. Ms. Edwards: With regard to the claims against Mr. Epstein, the only three -- well, and I probably need to step back. 1 2 3 I 6 7 6 9 10 11 12 13 14 15 16 11 28 19 20 21 22 23 21 25 Page 54 least at your direction regarding these three individuals' claims against Mr. Epstein? A. Information that I put into Otask le Information that was inputted into Otask by me. O. Did you ever direct anyone else to put any additional information in with regard to those three claims against Mr. Epstein? A. 1 don't believe so. O. And what type of information Old you put into Otask regarding the claims against Mr. Epstein? MR. SCAROLA: Read that back, please. Mu requested portion Of the record was reed by the reporter.' MR. SCARDLA: we're going to Object and that I will Instruct you not to answer on the basis Of both ettorney-client and work-product privileges. MR. CRITTON: I new.* if Mr. Scarola aaaaa ts an objection, you're adopting that end you would assert it. So. we don't have to do that as A repetitious project here? MR. SCAROLA: MR. CRITTC44: MR. SCAROLA: Correct. And that's Correct. You can, you can assume that my instructions to Mr. Edwards will be followed PROSE COURT REPORTING AGENCY. INC. 1 2 3 5 6 7 8 9 10 11 12 13 14 15 16 11 18 19 20 21 22 23 24 25 Page 56 Would it, would it be a correct statement during the time that you with PRA that the only claims that you had against Mr. Epstein were Jane Doe, E.M. end L.M.? The only clients I represented, yes. Q. And not necessarily In a lawsuit but those ate the only people that, that you and RRA represented In any. in any existing or potential claims against Mr. Epstein during the time you were with war? I believe so. Q. By the way. could. could an outside person, that is a person outside the firm access Otask as well? A. YOu can access it right now. O. Can -- did you ever allow someone who was not associated with RM to access the 0teak file relating to Mr. Epstein? A. No. O. Okay. Was there more then one file that was created associated with the claims against Mr. Epstein? I don't remember. Did anyone to your knowledge -- well, let me strike that. Did anyone other than you create a PROSE COtreT REPORTING AGENCY, INC. MSC EctrAT REPORTING AGENCY. INC. EFTA01100762 3 4 S 6 1 8 9 10 11 12 13 14 I! 16 11 18 19 20 21 22 23 24 25 Page 5? 1 Qtask file relating to claims again Mr. Epstein? 2 A. To the best of my knowledge, no. 1 take that 3 back. I don't know who treated the project. but 1 am 4 Only aware Of the project that I participated In related 5 to Mr. Epstein and has molestation of many children. 6 period. 1 how it was identified on the Otask system? 9 A. I don't remember. 10 Q. Do you recall when it was created? 11 A. No. 12 Q. Do you recall whether it was created 13 within a month of your coming to RNA? 14 A. I don't remember. 15 O. Do you recall whether it was, 1 think you 16 said approximately the beginning of April of '09 yOu 11 Came to PM. Correct? 18 A. Correct. 19 0. All right. And Is it, just so the record 20 is clear it's, your testimony is you don't recall 21 whether you created the project in April. May, June. 22 July, August, September or October relating to the 23 claims against Hr. Epatain? 24 A. I don't remember if 1 created the project.. - 25 PeriOd. Q. And what Old you call the project: that is PROSE COURT REPORTING AGENCY. INC. Page 59 1 SY NA. CRITTON: 2 O. During the time that you were at ARA did a number of people have access to the Epstein files either, either in a paper form or in an electronic form? A. Either/or, yes. O. And maybe I should get a definition of, with regard to the Epstein files, you had three Cases, Jane Doe, C.X., and L.M., correct? NR. SCAROLA: Excuse me. You used Epstein file as a defined copra earlier. Aro you now using it generically? MR. CRIMP: I am going to use it genitally and when I come back to Mask. I am Off Qtaek (Or just a minute. So that I have an understanding of how your filing was kept. And I will come back to Otask. So, right now I am using the Epstein files an a generic form. Not using Otask. Okay. MR. SCAROLA: Okay. SY MR. GRISSOM: Q. With regard to the Epstein files or matters. I know you had -- we know you have three cases that were filed that we have already identified, Jane Doe? 20 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Page 58 1 O. Separate and apart from whether -- 2 let me strike that. If you didn't create the 3 project, who would have? 4 A. I don't know. 5 Q. Well, do you remember -- let me strike 6 that. Do you know whether with regard to the project, and for purposes of st least this question. 8 let me Just call it the Epstein project, are you 9 okay with that designation? A. Yes. O. Okay. With regard t0 the Epstein project that was created In the Otask system, if I am understanding correctly, you don't remember whether you created It or someone else did, correct? A. Correct. O. Who would have had access to your files that could have created the Epstein project other than you? A. That question makes no Okay. MR. SCAROLA: And it also assures facts not in evidence and does not have a prior proper predicate. THE WITNESS: That's why it doesn't make sense. PROSE COURT REPORTING AGENCY, INC. Page 60 1 A. That's good. 2 0. E.W. and L.M., correct? 3 A. Correct. 4 Q. Were all materials relating to Jeffrey S Epstein kept. kept under, at least for filing, for 6 7 0 9 10 11 12 13 14 15 16 1? 18 19 20 21 22 23 24 2$ filing purposes at RRA, were they kept under the Epstein designation or, or sane other designation? A. Yee. O. Okay. And what wile the designation? A. 1 don't remitter but It was either under Epstein or some other designation. O. And at AM, were there both paper files or paper information as well as electronic information that was stored or kept regarding the Epstein files? A. Correct. 0. Was RDA supposed to be or at least designed to be a paperless office? A. YeS. And would every document that Case that was associated with the Epstein files, again in the generic sense, was that scanned in or put into the ilystem in some fashion at AAA? A. To the best of my knowledge. MR. CR1TTON: Just two minutes. PROSE COURT REPORTINC AGENCY. INC. PROSE COURT REPORTING AGENCY, INC. EFTA01100763 Page 61 Page 62 1 BY HP. CRITTON: 2 O. With regard to the scanned system: that 3 Is, co store the electronic records, was that put in 4 through the, through the Fortis program? 5 Yee, I believe so. 6 0. And did you as well -- let me strike that. 7 Prior to coming to RRA had you ever worked in • 8 paperless file or in a paperless office? 9 A. 7 don't understand. 10 O. Had you ever been working in an office 11 prior to casing to AM that was designed to be 12 paperless? 13 A. No, but as I mentioned earlier. I have worked 14 with case management software that stores electronic 15 OM of tiles. SO therefore there is a paperlees 16 system. 17 Q. Did you as wall when you came to BRA with 18 regard to the Epstein related matters or the content 19 of your Epstein investigation and tiles, had you 20 placed any Of that on a prior, a previous peperless 21 system or did you have the paper itself or both? 22 Both. 23 And during the time that you operated at 24 AAA, did yOu operate both with a, you individually 25 with regard to the Epstein files. did you operate PROSE COURT REPORTING MAINC1. IRC. Page 63 1 it electronically? 2 A. For the most part I would see it 3 electronically, but I can't say that I hove never seen a 4 piece of paper come in. 5 MR. CN1TTON: Okay. Let me take a few 6 minute break. 7 MR. SCAROLA: Well, wait a second. Do you R want to break at this point? 9 THE WITNESS: Not really. 10 MR. SCAROLA: Okay. We would like to keep 11 going. 12 MR. CRITTOR: Can I just go to the rest 13 room for two minutes? 14 MR. SCAROLA: Yes. 15 THE VIECEGI4APRER: we're now off video 16 record. The time is 11:21 a.m. 17 (A brief recess was held./ IS THE VIDEOGRAPRER: We're now cm video 19 record. The time is 11:28 a.m. 20 ST MR. CAITTON: 21 O. Couple, few more questions in ()task. Old 22 you ever allow Hr. Rothstein, was he an invitee on 23 the Epstein-related projects? 24 A. I don't believe 40. 25 O. With regard to the third electronic, the 1 both in a paper and a papules, manner? 2 A. No. 3 O. Did you operate only in a -- well, in what 4 way did you operate? S A. Paperless. 6 O. Okay. So if, if as an example I sent you 7 correspondence or answers to Interrogatories or a 8 response to a pleading and it cane in the mail. 9 would that document be scanned and then you would 10 toss away the paper? II A. I don't know. 12 Q. So, you may well have had paper in 13 addition to -- well, let me strike that. Do you 14 even know whether the document was scanned? 15 A. If you're telling me you sent correspondence 16 in the mail and I would later see that correspondence In I? my virtual mailbox, 1 make the logical assumption that 18 it was scanned. I never observed anything being 19 scanned. 20 O. Okay. And do you, if something came to 21 you by mail, whether it was some form of discovery 22 or request, and I will be In the State Case.. where, 23 which is not a paperless system and you don't file 24 through Pacer, would you ever see the paper that 25 actually came to your office or would you only see PROSE COOT REPORTING AGENCY, INC. Page 64 1 Marti, system where you, if I understand you 2 correctly, you input various information into that 3 Epstein regarding Epstein files: is that correct? 4 A. No. 5 You never used those system, with regard 6 to Epstein files? 7 A. I used the systems. 1 never input anything 8 into the System. I think it gets 'Canned in. 9 O. And could anyone in the firs access the 10 Fortis system? 11 I don't know. 12 Could you access other tiles that weren't 13 necessarily yours within the Fortis system it you 14 wanted to? 15 A. I don't know. 16 0. Hr. Edwards, with regard to your 17 employment with ARA, did you know any of the BRA 10 pertnere prior to coming to that firm in 19 approximately April of '09? 20 A. What do you mean by knew them? 21 Did you know them? 22 Yes. 23 O. As either an acquaintance or a friend? 24 A. Yes. 25 O. Did you have any friends at the RNA firm PROSE COURT REPORTING AGENCY. INC. PROSE COURT REPORTING AdOCY, INC. EFTA01100764 Poise! Page 66 before joining them? 2 People that I would consider to be my friend, 3 yes. 4 Q. Who. 5 A. Russell Adler. 6 Q. And how did you know Hr. Adler? 7 A. We worked out at the sage gym for about, approximately four Or flee yfars. 9 Q. What were you doing, prior to your 10 association with AM, what was your employment? 11 What? 12 Were you working as a solo practitioner? 13 Were you working with another firm prior to coming 14 to ARA in April of 09? 15 A. Solo practitioner. 16 Q. How long had you been a solo practitioner? 11 A. Approximately two years. 18 Q. During the time you were a solo 19 practitioner, did you ever have any associates 20 working for you. solo imply that you're the only 21 one, is that true, or did you have associates that 22 actually worked for you? 23 A. Various times I had clerks, law school clerks. 24 but that was it. 25 Q. Out no other lawyers? PROSE COURT REPORTING AGENCY. INC. Page 6? 1 Q. How did it, how did it happen that you 2 came to be employed by AM? 3 I was offered a job. 4 And how did that coos, how did that coma 5 about? 6 Talking with Russell Adler. Had you ever had a case against Mr. Adler 8 or with Mr. Adler, either you were on the same side 9 or against? 10 A. Yee. 11 O. On how many Occasions/ 12 A. I can't recall. 13 Q. Okay. Did Hr. Adler approach you or did 14 you approach him? 15 A. We worked out at the same gym. It wasn't 16 about approaching •omebodY. 17 Q. How did the topic come up? 16 A. He works at this law firm Rothstein Roaenfeldt 19 Adler. end would talk about it in a positive way for 20 years before I joined the firs. 21 Q. And how did It come up that you would be 22 Interested in possibly working there; that is did he 23 say gee. Brad. you should corm talk to me or did you 24 say I am interested in working for the firm? 25 A. He would ask if I would be interested in 1 A. Right. 2 Q. Did you ever have an Investigator work for 3 you? 4 A. Yes. 5 0. Okay. Do you know an Individual by the 6 name of risten, P-1-s-t-e-n? I know an Individual whose last name is 8 Platen. 9 0. All sight. What's his first name, the one 10 you know? 11 Mike. 12 Q. Michael Platte? 13 A. Yes. 14 Q. Mike Piston ever do any work for you when 15 you worked as a solo practitioner at any time prior 16 to you joining PM? 1? No. 15 Q. Did you know of Michael Platen or Mike 19 Piston prior to joining AM? 20 A. Mo. 21 Q. With regard to the investigators that you 22 used prior to joining AM, did you use, or were any 23 of those Individuals over employed by ARA during the 24 time you were there? 25 PROSE COURT UPDATING AGENCY, INC. Page 66 1 joining the firm. 2 Q. Okay. And what happened then? What 3 ultimately happened that you. that you went from 4 just having an interest to actually contemplating or 5 being offered a position? 6 A. I didn't say 1 had an Interest. So, what happened? Now did you then end 8 up at ARA? 9 A. Numerous conversations with Russell Adler and 10 him telling me about some of the other people there that 11 I hollowed to be good lawyers, respected, ethical 12 lawyers, and that this Is a good place t0 work, great 13 comradely. you have a team, I know you handle big cases; 14 this will be something that will be good for you. And 25 that wall something I talked to him about seriously for 16 four months maybe before joining AM before finally I? agreeing to meet Scott Rothstein. 20 Q. All right. Had, did Mr. Adler ever 19 discuss with you parameters or potential Inoue or 20 salary Or whatever the compensation package would 21 22 A. Not specifically. 23 Q. -- before you first met with 24 Mt. Rothstein? 25 A. NOt Specifically. PROSE COURT AtromTIPG AGENCY, INC. PROSE COURT MPoRTMC AGENCY. INC. EFTA01100765 Page 69 Page 70 1 Now many tines did you meet with Scott 2 Rothstein prior to accepting a position with ARA? 3 A. Once. Q. Where did the meeting tate place? 5 A. The restaurant BOVA. 6 0. Old you understand Mr. Rothstein had an Interest in BOVA? A. At the time? 9 Yee, sir. ID A. No. 11 Did you learn that during the time that 12 you worked for BRA 13 A. Yes. 14 0. Okay. who was present other than 15 Mr. Rothstein when you met with him at BOVA? 16 A. Nobody. 17 O. Mho had set up the meeting? IS A. Russell. 19 Q. And had anything been discussed at least 20 as of that time with regard to what your opportunity 21 was or an terms of compensation? 22 A. Specifically, no. 23 Q. Wow long did the meeting with 24 Mr. Rot/Mein lest? 25 A. Ten minutes. PROSE COURT REPORTING AGENCY, INC. Page 71 of the meeting if you had no interest in considering 2 an opportunity with Rah? 3 FOf the most part placate Russell Adler. 4 Did Mr. Adler know the type of cases YOU 5 had? 6 A. Of course. And was he aware as of that date you had filed the three cases against Mr. tpatein? 9 A. I don't believe so. 10 Had you -- is it your belief that the 11 three eases against -- well, let me strike that. Do 12 you recall when the first meeting was or the only 13 meeting that you had with Mr. Rothstein prior to 14 joining the firm? 15 A. It was prior to joining the firm. 16 O. All right. When was that? 17 A. I don't remember. IS O. Was it within a month Of your joining AM, 19 two months, three months, six months? 20 A. Definitely within six months of joining the 21 firm. Definitely within three months of joining the 22 firm. Within that three month period, I don't recall. 23 Q. So. sometime between January and April of 24 '09, you would have met with Mr. Rothstein for ten 25 minutes? Q. Did you have lunch with him or you just 2 sat down and talked with him et the table at the 3 restaurant? 4 A. Sat down and talked to him. 5 O. Had you submitted any kind of a resume co 6 Mr. Adler as to what your experience was? 7 0. SO, you, at that time you are a solo 9 practitioner. Mr. Adler cells you and says, or you 10 express an interest. Mr. Adler Says we have an 11 interest in talking to you, and you set up a meeting 12 with Mr. Rothstein. Is that pretty much It? 13 A. You're now making things up that Is totally 14 Inaccurate, end doesn't reflect what 1 have been telling IS you at all. I didn't express any interests. I wasn't 16 looking for a job. I wasn't seeking him out. In fact, 17 that is the exact opposite of what I have just gone 18 through explaining to you about conversations at the gym 19 that ultimately lead to him convincing me this is a good 20 place to cash into and me agreeing to this meeting with 21 Scott Rothstein. 22 O. Okay. When you went to meet with Mr! 23 Rothstein did you have any interest or was this just 24 a throw-away meeting. Maybe I misunderstood. What 25 did you -- let me strike that. Whet was the purpose PROSE COURT REPORTING AGENCY, IXC. Page 72 1 A. I believe so. 2 O. Okay. What did you talk about: that is, 3 what Was the substance of the meeting? Russell Says you would be an asset to the 5 firm. I will treat you fairly. Now, how much 60 you 6 expect to make? Okay. 1 can't do that, but as soon as you *hew your worth here, your salary is exponentially increased because at this firm we operate under a system 9 of fairness. That was the gist of the mating. 10 Q. Did he ask you how such you were making at 11 that time or how much you had made the preceding 12 year. '08? 13 I believe so. 14 what did you tell him? 15 MR. SCAAOLA: Objection. InstruCt you not 16 to answer on the basis of economic privacy. 17 BY M. CAITTON: IS O. Did you tell him what you had made, total 19 campensation for the year 2006? 20 A. I don't remember. 21 Q. well, if I, If I understood you correctly, 22 1 thought he said is I can't meet that Salary Of 23 that level of compensation, so you must have told 24 him something. 25 A. Yeah. I answered his gueStion, what did you PROSE COURT REPORTING AGENCY, INC. PROSE COURT REPORTING AGENCY. INC. EFTA01100766 Page /3 Page 14 expect. 2 Q. What did you tell him that you expected? 3 MA. SCMOLA: Objection, economic privacy. 4 BY HR. CRITTON: 5 Q. All I em interested now, not necessarily 6 what yOu were earning but what you told him. i.e., 1 Mr. Rothstein that you wanted to get or expected to earn if you considered a job at PRA 9 MA. SCUOLA: Objection. Economic ID prIvaCy instruct you not to answer. It's 11 neither relevant nor materiel nor seasonably 12 likely to lead to relevant material information 13 and invades the *concede privacy of the 14 witness. 15 MA. CRITTON: Is that tone? 16 BY I . CRIMP: 17 Q. Mr. Edwards, you gave him a nuMber, is 18 that correct? Ills meaning Mr. Rothstein. 19 I believe so. 20 O. And was the number that you gave him more 21 than you had earned for the year 2008 or less? 22 MR. SCAAOLA: Sane Objection. 23 M. CAITTON: Or the same? 24 MA. SCAPULA: Sane objection. same 25 instruction. PRoU Celan' UPORT1NG AGENCY. INC. Page 75 Possibly. 2 O. Do you recall what he said? 3 A. What do you mean by benefits? 4 O. 1 mean would you get health insurance and 5 those types of things as well? 6 I believe that was discussed. I'm not sure. 1 I can't tell you I got them but I don't know. 0. Did you discuss any of your cases that you 9 had with him? 10 A. No. 12 Okay. Did you sign an employment 12 agreement at any time with ARA? 13 14 O. After the -- let me go back. Did you say 15 you did or did not discuss any of your current cases 16 with him? 17 A. Did not. 18 Q. Okay. Were you aware, had you discussed 19 your cases -- I think you said you had discussed 20 your cases or Russell Adler had an idea of the type 21 of cases you had? 22 A. Over the years Puss and I are friends: we 23 talked about cases. 24 Did you say you had discussed the Epstein 25 cases with him? Him. meaning Adler. I BY HR. CRITTON: 2 Q. Old you tell him that you -- did you tell 3 him that you wanted to make more money than you had 4 In the proceeding year? MA. SCAROLA: Saw* objections and 6 instructions. BY MA. CRITTON: O. Did he tell you how such you would be paid 9 if you came to work at ARA: that is. did he mention 10 a number: This is what your Salary would be if you I/ come and work here? 12 A. I believe so. 13 O. And what number did he say to you? 14 MR. SCAROLA: Objection and same /5 instruction. 16 BY HR. CRITTON: 11 O. Did he also tell you that you would get an 18 economic incentive: that is, at the, at sometime 19 during the course of the year based upon your 20 produetiOn2 21 A. I would be compensated fairly. 22 Q. And that was it? 23 A. That was the gist. 24 Q. Okay. Old he talk about any benefits that 25 you would receive? PROSE edger REPLAYING AGENCY. INC. Page 76 1 1, I don't believe I discussed the Epstein 2 cases with Russell Adler until after I was employed at 3 RRA 4 O. Did you mention Mr. Epstein at your meeting with Mr. Rothstein? 6 A. No. 7 O. Did you mention any of your three clients who were suing Mr. Epstein at the meeting with 9 Mr. Rothstein? 10 11 Q. With regard to the, did you, did you 12 discuss with him if you came to work with PM that 13 the cases -- well, let me strike that. Did he 14 mention that If, if yOu Cam and worked for the firs 15 that those cases would become the property of AAA? 16 A. No. Il Q. Did you understand that to be true? 18 A. I mean, I suppose so. 19 O. okay. Did -- 20 A. 1 understood that I was going to be an 21 employee of the firm, of course. 22 O. Nell, did, did you, at the conclusion of 23 the meeting did you say, yes, 1 would like to work 24 here or how did you leave it? 25 A. Think about IT. PROSE COURT REPORTING AGENCY, INC. PROSE COURT REPORTING AGD4CY, INC. EFTA01100767 Page ?? Page 70 1 O. And how long did you think about it? 2 A. I don't reaarber. 3 Did you, and who did you contact? well, 4 let me strike that. At some point did you make 5 decision -- 6 Yes. 7 to go work for AM, correct? S Correct. 9 Q. Did Mr. Rothstein at the Initial meeting 10 tell you whether you would be a partner? 11 A. NO. 12 Q. Did he describe that you would be at least to the public at large you would be described se 14 partner? 15 A. No. 16 Q. Did you understand who the partners 17 were -- well, let me trick that. Is AM, was BRA a 10 PA? 19 I don't know. 20 Did you ever find out during, up through 21 today's date do you know whether AM was a PA or an 22 LLC or an LLP? 23 No. 24 Did you ever go online to look at who the • 25 offices" and directors were or had members if it was PROSE COURT REPORTING AGENCY, INC. Page ?9 1 2 3 S 6 9 10 11 12 13 14 15 16 1? ID 19 A. Yes. 20 Was he the referring lawyer on all three 21 of those cases? 22 We was at least the referring lawyer directly 23 on one. 21 Which one? I'm sorry. I didn't moan to 25 interrupt you. ended up at AAA, how much timed passed? A. I don't know. Prior to starting at RAA, did you have any further conversations with Mr. Rothstein: that is. up until the day that you showed up at that office? A. No. Q. And in terms of the cases; that Is. the Cases with L.M., with L.M., Jane Doe and E.M. those are cases that you had signed up when you were a sole practitioner: Is that Correct? Correct. And with each of those cases there was a, there is also another lawyer that was Involved -- well, let me strike that. In one or more of those cases is Nr. Nowell Involved. or was he at the time you were a solo practitioner? A. What do you moan by involved? Involved, was he a referring lawyer? 1 2 3 4 5 6 0 9 10 11 12 13 14 15 an LLP? A. During the Initial. Initial meeting with Scott Rothstein. he told me there are only two equity partners of this law firm, and it will always be that way: myself and Stuart Rosenfeldt. Period. 0. And did he say that they each own 50 percent, or did he say, they were Just partners? Did not say. Prior to your -- let me Strike that. I think as yOu said at scam point you made a decision to Join AM? Right. Q. And who did you convey that to? A. Russell. O. And what happened thereafter? That is, 16 how did you go from then being a solo practitioner 17 Into PM? Row did YOU integrate yourself? What wee 18 the timing and what did you do? 19 At some point in time I was no longer working 20 in my Hollywood office and was working at AM on Las 21 Olas. So, physically I sheared up to work at a different 22 location. 23 Q. And did someone -- well, let me strike 21 that. From the time that you announced that you 25 would go, you told Kr. Adler up until the time you PROSE COURT REPORTING AGEWcY, 11(c. Page 60 1 A. I'm finished. 2 Q. Which case was he the referring lawyer, 3 Mr. Nowell? 4 5 Q. And he nay be the referring lawyer on Jane 6 Doe, and L.N., you lust don't know as you sit here. 1 or he is? 6 A. He referred E.W.'s case. 9 0. And the other two cases is he is shown as 10 the referring lawyer? 11 Yea. 12 There Is also a person named Cassell who I 13 think is an attorney from Utah? 14 A. Okay. 15 Q. DO you recognize the name? 16 Yes. 17 0. Okay. And what's hie first name? 111 A. Paul. 19 Q. All right. Is he in any way a referring 20 lawyer, considered a referring lawyer with regard to 21 any of the three cases against Mr. Epstein? 22 A. No. 23 Q. What's hie role? 21 A. handles certain appellate issues. 25 Q. Okay. Is he. is he involved in as pact PROSE COURT RAPORTING MERCY, INC. PROSE COURT REPORTING PRICY, INC. EFTA01100768 Page el 1 of. as a potential recipient of any contingency fee 2 or Is he paid On an hourly basis. either when you 3 Wire a sole practitioner during the RRA stages or at 4 the current time? 5 A. Contingency. 6 Q. Does he get part, at least as it was set 7 up as a sole practitioner was Mr. Cassell also on the Contract with each of the three individuals? 9 A. I don't believe so. 10 You don't -- he Is not on any of the 11 contracts, Mr. Cassell? 12 A. There is a contract that he le on but your 13 Question is when the cases were first signed up. was he 14 on the initial contract. And I believe the answer to 15 that is no. 16 Q. Prior to the time or during the time that 17 you were in sole practice before you went to RRA was 1$ Mr. Cassell ever en any of the contracts with the 19 three Plaintiffs? 20 A. Yes. 21 0. Okay. When you moved to RRA, was a new 22 fee agreement signed with each of the Individuals. 23 each of the three Plaintiffs? 24- A. No. 25 Q. Was there some form of an assignment? PROSE COURT REPORTING ACIPCV, INC. Page 83 1 or Mr. Nowell. assuming there had been some 2 resolution? 3 A. RRA would be standing In my shoes. 4 And if I understand it correctly, there 5 was never an assignment of your contracts: that is, 6 as a 4010 practitioner to RRA: is that correct? 7 Correct. 0 Okay. And It was your Intent just 9 whatever the contract said when you went from solo 10 practitioner to RRA. Lf those cases had resolved 11 during that tine period, RRA, you would have paid 12 ARA chat portion to which you were been entitled and 13 Nowell and a Cassell would have gotten their le percentage? 15 A. Correct. 16 0. And with regard to. with the new firm, the 17 Farmer. Jaffe firm, where those new fee agreement• 10 have been signed with your three clients? 19 Yea. 20 And ere Mr. Cassell and Ms. Nowell still 21 on those contracts? 22 Yes. 23 Sas the receiver made a claim against the 24 proceeds of these three cases. that is, he filed, 25 Mr. Seton on behalf of or as trustee, has he filed a Page 02 1 A. well, not co my knowledge. I don't want t0 2 say no. but I don't know of any fee agreement that was 3 signed with the client. 4 0. As a -- from the time that the original -- 5 let me strike that. If I understood you correctly 6 is as an example E.M. was your first case? 7 A. First client. 8 Q. First client, right. Mr. Novell would 9 have referred the came, so he would have shown up as 10 a referring order. And at seal point Kr. Cased') 11 also came on the contractor er a contract: is that 12 correct? 13 A. A contract, yes. 14 Q. So, there was at least two contracts with 15 regard to EN.? 16 A. That 1 remember. 11 Q. And with regard to C.M.. Jane Doe, and 10 L.M., you don't recall any new contract being signed 19 between those individuals and ARA; Is that correct? 20 A. That is correct. 21 Q. And with regard to the, whatever the 22 contingency fee was in each of those three 23 contracts, was that to be split? When you went to 24 AAA, haw was it to be determined what Rite would 25 receive versus what you would receive or Mr. Cassell PROSE COAT *SKATING ARMY, INC. Page 84 1 lien again those cases? 2 A. No. 3 0. Nes he sent you any correspondence 4 indicating that he intends t0 assert a lien against. 5 for attorney fees and/or costs that were incurred 6 during the time those cases were at ARA? A. Not specifically related to those cases, but a in general, that concept is something that has been 9 communicated by a receiver or a trustee to us at Threat. 10 Jaffe, weissing. 11 Q. Nave you at any time: that Is. have you 12 acknowledged, has anyone at Farmer, Jaffe 13 acknowledged their responsibility to repay monies to 14 RRA? 15 1 don't understand the question. 16 Q. If the case Is settled, does Farmer, Jaffe 17 intend to repay the receiver a portion of the fees 18 at coats? 19 A. That issue has not been resolved. 20 Q. With regard to, with regard to the 21 third-party -- 22 ?Interruption at the 000r./ 23 BY KR. CR1TTON: 24 O. Other than the attorneys Is there -- with 25 regard to the, other than the attorneys, is there MGR coon? sznerrlieg AGENCY. INC. PROSE COURT REPORTING Katy, INC. EFTA01100769 Page 05 1 anyone else other than, on any of these three Cases: 2 that is, potentially RRA, potentially your new firm, 3 Mr. Cassell. Mr. Nowell and the Plaintiff, does 4 anyone else stand to benefit from • recovery in any 5 of those cases? 6 NO. 7 Has anyone, has any interest in any of the 8 three cases been assigned to a. to a third party 9 other than a law firm or a lawyer or a law firmu /0 that is, to an outside service? 11 A. 12 O. Okay. Have any of the potential 13 settlements -- I'm sorry. Have any of the potential 14 proceeds from any settlement or verdict been 15 assigned or sold to anyone to your knowledge? 16 No. 11 O. seas E.M., Jane Ddt, Or L.M. Sold. 18 assigned, exchanged for consideration. money. or 19 promises of money. any portion of their potential 20 settlements? 21 A. No. 22 O. Or recoveries? 23 A. No. 24 If I understood you correctly, 25 Mr. Edwards -- PROSE COURT REPORTING AGENCY. INC. Page 61 1 You understood me correctly. 2 All right. Md when did E.M. retain your 3 services, please? 4 A. Md by first case. Just to clarify, she was my 5 first client -- 6 O. I will rephrase it. 1 A. -- related to the matter that we're all 6 familiar with that relates to things that happened to 9 E.M. when She was young. 10 Let me rephrase the question this way: If 11 I understand your testimony is E.M., and I'm 12 interested in Epstein cases: 1 am not interested in 13 other portions of your practice. You understand 14 that? 15 A. I do. Md 1 think that you understand that 16 this case. E.M.'s case and L.M. case did not begin as I? case against Jeffrey Epstein. You 'mow that and I know 10 that, and that's why it's difficult for ma to ask, 19 answer these questions related to theae clients because 20 this began as a Case against the United States 21 Attorney's Office. 22 Q. All right. with regard to the, at least 23 your first representation of any of your three 24 clients that relate to Mr. Epstein in some fashion, 25 your first client was E.W; is that correct? Page 06 MA. SCAAOLA: Let me interrupt for lust • 2 moment. 1 don't know whether the circumstance 3 applies but I want to be sure, does the crepe 4 of your emotion include a letter of protection 5 to a health care provider? 6 MR. CRITTON: No. MA. SCARCER: 1 don't know whether that S has occurred in any of these cases, but I 9 assume that's not what you're looking for? 10 MA. CSITTOW: I wasn't, but no, I'm 11 looking for -- I think it would not be applied 12 to any of the three. 13 You understand I wasn't talking about It health care providers. I an talking about 15 some Independent person or entity that may 16 have purchased some interest or have been 17 assigned some interest in any of those 18 three lawsuits. Do you understand that? 19 THE WITNESS: I think I understood your 20 question, and my answer was responsive and 21 was not thinking about lectors of protection at 22 the time that I gave my answer. 23 BY MR. CRITTOPn 24 Q. With -- if I understood you correctly. 25 E.W. was your first case? PROSE COURT REPORTING AGENCY. INC. Page 80 A. That is correct. 2 O. Co you recall when you first -- well, let 3 me strike that. She was referred to you by 4 Mr. Nowell? That is correct. 6 O. Okay. And how did Mx. Nowell know you? A. 1 have known him for a long time. O. Law school? 9 A. He. I have known him since. I'm Cron 10 Jacksonville Beach. He's from Jacksonville. I have 11 known him when I was probably ten years old. 12 O. Okay. Has Mr. Howell, prior to C.M., had 13 he ever referred to you any other client? 14 A. Yes. 15 Old it involve scare sort of a sexual 16 assault or battery? 17 A. Yes. 18 O. How many clients prior to N.M. had 19 Mr. Howell ever referred you? 20 A. I don't know. 21 More than One? 22 Yes. 23 0. when E.M. was referred to you, what was 24 your understanding as to the nature of the 25 representation. what would it be? PROSE car REPORTING AGENCY, INC. PROSE COURT REPORTING AGENCY. INC. EFTA01100770 Page 89 1 A. I don't understand. 2 O. Why did L.M. come, why did she hire you In 3 the first place? What was the purpose? 4 A. This is going to get into attorney-client 5 privileged information as to why she hired me which 6 would incorporate the things that she told me that 1 related to my representation, therefore, I am invoking 8 the privilege and not answering. 9 O. With regard to G.M. you flied a case -- 30 well, let me ask you this: Do you know how C.W Came /1 to contact Mr. Nowell? Did he ever relate that to 12 you/ 13 M. SCAROLA: If St's in information that 14 you obtained from your Client. I Instruct you IS not to answer. If it's information that you 16 obtained from Hr. Howell. 1 also Instruct you 17 not to answer. Both instructions are on the le beefs of attorney-client and work-product 19 privileges. 20 THE WITNESS: Attorney-Client and 21 work.-product privilege. 22 BY NA. CRITICS: 23 Q. Did you, did mt. Howell -- and I don't 24 want to know the information, at least right now -- 25 did Mr. Howell give you any information about E.W. PROSE COURT REP.:411NG AGENCY, INC. Page 91 1 HR. SCAROLA: Objection, attorney-client 2 privilege and work-product. Instruct you not 3 to answer. 4 BY MR. CRITTCW: 5 O. Your second, your next client was whim 6 relating to Mr. Epstein or to the United States 1 Government? 8 I don't reeember. 9 You ultimately filed a case styled Jane 10 Doe 1 and 2 were petitioners versus the United 11 States of Merle. in July of '08, correct? 12 A. That's correct. 13 Okay. Who was Jane Doe I? 14 A. IS Q. Who was Jane Doe 2? 16 A. 1? O. At the time that suit was filed, were you 18 representing Jane Doe-L.14" I'm sorry, Jane Doe? 19 A. I believe so, but I'm not sure. 20 Q. In terms of the work that you did for. 2] that you have done for all three of the individuals 22 when you were a solo practitioner, did you keep 23 track Of the time; that is, did you keep time 24 records? 25 A. What's your question? Page 90 1 prior to her coming to see you or your seeing her? 2 A. Yee. 3 Okay. And did C.M. for the first. on the 4 first occasion come to your office or did you talk 5 to her by phone or did you go to her place? 6 First time I talked to 5.147 7 Q. Yes, sir. A. was over the telephone. 9 Q. All right. And hew long, how much time 10 transpired before E.M. retained your services: that 11 is. how many conversations did you have with her 12 before she ultimately retained your services? 13 A. One conversation over the telephone and then 14 the next meeting was in person at my office. That IS meeting culminated with her retaining my services. 16 0. And the Initial conversation you had with 11 her, what did she relate to you? 18 A. That's attorney-client privilege information l9 that 1 an not going to divulge. 20 O. During the tine that you have been 21 involved in this case on behalf of C.M. has 22 Mr. Howell participated in the case; that is. has he 23 done work on the case? -24 A. Yea. 25 Q. What kind of -- what has he done? PROSE CODA! REPORTING AGENCY. INC. Page 92 1 Q. During the time that you were a solo 2 practitioner working on C.w, Jane Doe, whichever of the three case, that you had, did you keep time 4 records? 5 A. Some. 6 Co you keep time records on contingency 7 cases generally, or did you during that time period? A It's my Intent to. 9 Okay. Same would be true with, when you 10 were at REA, did they have a time program? 11 A. They did have a time program. 12 Q. Did you Input your tine that you spent on 13 the Epstein related 14 That aa s a r eguirement of the firm. 15 Q. Okay. So, you would have been put down 16 whatever time you spent, whether lc was a 17 contingency fee case or an hourly case: is that 18 correct? 19 A. For the most part: that's correct. 20 Q. During the time that Mr. Nowell has been 21 associated with the case, does he provide you with 22 time records as to the work or the amount of work 23 that he has done on the case? 24 A. No. 25 Q. Okay. Does he kmip track of his time that PROSE COURT REPORTING AGENCY, INC. PROSE COUNT REPCMTING AGIDICY INK EFTA01100771 Page 93 Page 94 1 he hat spent on each of the cases? 2 A. I do not know. 3 4 5 6 7 0 9 10 11 12 13 14 15 16 O. Did you -- has he prepared any pleadings or documents associated with the cases? MR. SCAROLR: You can answer that question. THE WITNESS: Define Prepared. BY KR. SCAROLA: O. All right. Prepared. Prepared, start. ❑rst of ell. started from scratch: that is, has he prepared any of the pleadings or papers that have bean filed in any of the three coves stetting from scratch that he would have been -- net because you said this but he started with the complaint and you may have changed it, but he started the preparation Of the document? 17 A. Your question is has he started the 10 preparation of a document now, right? 19 O. Any document, any paper that's been filed 20 in the cases or I would say passed back and forth 21 between lawyers in any of the three cases? 22 A. HOS he had edited revised, I mean what -- 23 O. Right now I am lust asking did he start 24 the document such as a complaint or a similar typo 25 document? PROSE COIMT REPORTING AGENCY. INC. 1 2 3 4 5 6 6 10 11 12 13 14 15 16 17 1B 19 20 21 22 23 24 25 O. Sure. I we okay with that. Page 95 • Now often do you consult with Mr. Nowell with regard to those three cases prior to the time that you started with your Current farmer. Jaffe association? A. It is an impossible question for me to answer accurately with a percentage that I have spoken with Hr. Nowell about any particular document or anything. O. As to pleadings, do you discuss, do you sand it to him for his review, editing, before you file a pleading? Typically no. How often do you consult or have you Consulted with Mr. Howell during the time you were with RRA? A. What type Of an answer do you want in terms of how often have 17 O. Do you do it once a day] A. Nave I ever? I have. O. Is it a pretty cowmen practice that when you're going to filo or dO SON:thing that you would contact Mr. Howell? A. Not at all. 0. A. 0. So. do you -- Not at ell common I mean. So, during the course of the month. say 2 3 4 5 6 7 9 10 12 13 14 IS 16 1? 10 19 20 21 22 23 24 25 A. That was filed in the case? 0. Correct. A. No. Q. Okay. Has he worked on documents, whether it's editing, adding, deleting from pleadings that you, pleadings or papers that you have prepared? A. Yes. Sob, can you hand me that water? O. Yea. A. Thanks. Appreciate it. 0. You're welcome. Has he COotinued, did he continued to be involved not only when you were a solo practitioner but during the time that you were with ARA with regard to editing or working on the Cases? To an extent. 0. Okay. Do you. how often on the cases have you consulted with Mr. Howell? By that I mean before a decision is made as to how you want to do discovery or proceed with the filing of the pleading or how you're going to respond, does Mr. Nowell. do you consult with Mr. HOuell during the time you were both solo practicer and were at AAA? A. Is your question asking for the answer to be in a percentage? Now often- do I consult? I am lust not sure how to quantify. PROSE COURT REPORTING AGENCY, INC. 1 2 3 5 6 7 9 ID 11 12 13 14 15 16 17 1$ 19 20 21 22 23 24 25 Page 96 during the titre that you were at ARA, how often would you consult with Mx. Nowell regarding the Cases? And I recognize every day or every week might be different. Mould you Speak with him like once a month, or two or three times a month, or generally once every couple of months? A. Depending on what was going on in the cases at the time. at sometimes more then others. O. Now did L.M. Cline to be a client of yours? A. She called me. O. And how did she get your name? KR. SCAROLA: To the extent that your response to that question would require that you reveal either work-product or attorney-client Privileged Information, 1 instruct you not to answer. THE WITNESS: I simply don't know. BY MR. CR1TTON: O. Did Ms. L.M. hire you in the or -- I'm going to strike that. Now many conversations did you have with and/or meetings did you have with Ms. L.M. before you hired her, or before she hired you. I'm sorry. I don't remember. PROSE COURT REPORTING PaZOCY, INC. PROSE COURT REPORTING AGENCY, INC. EFTA01100772 Page 91 Page 98 1 Q. Did she ever come and meet you at your 2 office? 3 A. From the beginning of time until today? 4 No. Back at the time prior to retaining 5 your services. 6 I don't remember. Did you ever meet her at her residence or 0 place of work? Let me ask you this: Have you ever 9 net her at her place of business or a place of 10 business? II A. No. 12 O. Nave you ever met her at her home, whether 13 it's an apartment or home, whatever? 14 A. Now, you're asking from the beginning of time 15 until now? 16 O. No. Up until the time she hired you, did 17 you ever meet with her? le A. Okay. 19 Q. At her Name or apartment. 20 A. To the best of my recollection, no. 21 Q. Did you -- did she sign, to the best of 22 your recollection did she sign a fee agreement? 23 Well, let me strike that. There is a, there is a 24 written fee agreement between L.H. and you and - 25 then -- PROSE COURT REPORTING AGENCY, INC. Page 99 1 information. 2 BY NR. CRITTON: 3 O. When you met W. L.M. at the park was 4 anyone else present? 5 A. Yes. 6 Q. Who/ 1 A. I don't know. 8 O. Male or female? 9 A. I presume both. It's a park. 10 O. No, no. no. In the meeting that you had 11 with her -- my guess is there were probably a lot of 12 people in the park? 13 A. Correct. 14 Q. In the meeting that you had with W.L.N. 15 was anyone else present/ 16 A. For the conversations between myself and 17 Ms. L.M., no. IS Q. When you first met with B.M. was anyone 19 present for the conversations between that you and 20 Hs. C.W.? 21 No. 22 Q. I think you told sae at the time that the 23 complaint was filed or at the time that the Jane Doe 24 1 and 2 sued the United States Government which was 25 in early July, it was July 8th Of 'OB. you don't 1 A. Correct. 2 0. -- her originally? 3 A. Correct. O. Did you ever meet her prior to her signing 5 that fee agreement? 6 A. Yes. O. And do you COMOOLOOl where that meting took place? 9 A. Generally, yes. 10 O. Okay. Where? 11 A. A perk. 12 Q. And what town? 13 I don't know. 14 You don't know whether it was in *toward 15 County or Palm Beach County? 16 A. I do know. 11 Q. Which county? 10 A. Palm Stash County. 19 0. Was that arranged by her to meet her 20 there? 21 Yes. 22 Q. And what, for what purpose did W. L.M. 23 originally hire you? 24 MA. SCAAOLA: I em going to oblect. That 25 calls for attorney-client privilege PROSE COURT stet's/NIG SOUCY. INC. Page 100 1 recall whether you were representing Jane Doe at 2 that time? 3 I believe I was but 1 do not recall for sure. 4 At the time do you know whether, at the 5 time that you represented Jane 004 1, do you know 6 whether her name, whether she was considered a 1 victim by the United States Attorney's Office? A. Ask your question again. 9 O. All right. At the time you began 30 representing E.W. or at any time prior to the filing 31 of the lawsuit against the United States Government 12 in July of '00, did you learn whether she was listed 13 as a, or deemed to be a victim by the United States 14 Attorney's Office? 15 P . SCAROIA: If that Is information that 26 you obtained in the course of the performance 17 of your responsibilities in representation of le any client. I would instruct you not to answer. 19 If that Information was obtained 20 through some public source independent of 21 the work that you performed es counsel, 22 then you may respond. 23 THE WITNESS: I cannot respond. 24 BY MR. CRITTON: 25 Q. With regard to the question, I an not PROSE COURT IMPORTING AGENCY, INC. PROSE COVE* REPORTING AGENCY, 2NC. EFTA01100773 Page 101 1 interested in what you learned from E.N. All right. 2 Dad you learn from either any correspondence or a 3 telephone call with any third party that whether 4 again prior to [he -- let se start again. 5 Prior to the filing of the lawsuit 6 against Jane Doe 1 and Jane Doe 2 against the United States Government, did you learn fresh any source, 0 maybe a document, maybe a telephone call or a 9 conversation that you had with a third party 10 separate from your Client. that E.N. was a victim Or 11 was deemed to be a victim by the United States 12 Goverment or the United States Attorney's Off ice? 13 M. SCAROLA: Sams objection and 14 instruction. 15 BY MR. CAITTOR: 16 O. Sane question with regard CO L.M. Miller. 17 MR. SCAROLA: Sane objection and 16 instruction. 19 BY MR. CRITTON: 20 O. And sane question with regard to Jane Doe. 21 MR. SCAROLA: Same objection and 22 instruction. 23 BY MR. CRITTOM: 24 Q. Prior to your filing the lawsuit with 25 united States Government, did you ever any Picot COURT REPORTING AGING,, Inc. 2 3 4 5 6 7 0 9 10 11 12 13 14 35 16 11 10 19 20 21 22 23 24 25 Page 103 litigation which is still pending today? KR. SCARCER: And I assume that question Is qualified by inquiring as to whether such a conversation occurred with regard to any of the three individuals who he is ',Presenting claims against Mr. Epstein or the U.S. Attorney's Office. correct? MR. CRITTOM: Say that again? MR. SCAROLA: Yes, air. Are you asking whether such conversations occurred that were relevant to his prosecution of the claims on behalf of his three clients? MR. CRITTON: Sure. MR. SCAROLA: Then, then the instruction remains the sans. The Objection remains the same. BY M. SCAROLA: O. SO, even if, do you -- even if you talked about it with Mrs. Villafana, even if your client Mx. Edwards spoke with Mrs. Ifillafana about a scheduling issue. it's your position that that Is what, work-product? MR. SCAROLA: That's correct. We ere not going to discuss anything that Kr. Edwards did in the course of the prosecution of his claims Page 102 1 conversations with the United States Attorney's 2 Office -- 3 MR. SCAROLA: 1 assume -- 4 BY M. CRITTCM: 5 O. -- regarding, regarding, regarding the 6 subjeCt Of the lawsuit or Jeffrey Epstein) 1 MR. SCARPER: Same objection and 8 instruction. 9 KR. CRITTON: These are third parties: ]0 where is the work product? /1 MR. SCARPER: Work product has to do with /2 anything that was done in connection with the 13 representation of these three clients. It he 14 had such conversations Independent of his 15 representation of those clients, then he can 16 respond to the question. 17 BY MR. CRITTCM: 16 Q. Well, lot me ask you a broader question. 19 After you tiled the lawsuit against the United 20 States of America, were you aware that Marie 2] villafana or the United States Attorney's Office 22 represented the USA, Correct? 23 A. Yes. 24 All right. Did you ever speak with Katie 25 viiiatana during, during the pendency of that PROSE COURT REPORTING AGENCY, INC. Page 204 1 on behalf of his clients. 2 KR. CRITT011: So. any question that I ask 3 you with regard to conversations that 4 Kr. Edwards had with the U.S.A.O.'S office, 5 whether St was Mrs. Villafena or anyone else 6 from the time, with regard to the Jane Doe 1 7 and Jane Doe 2 versus U.S.A. case, you would 8 Instruct Hr. Edwards not to answer those 9 questions?? )0 MR. SCRRPER: that is correct. 11 MR. CRITTON: So If I -- 12 MR. SCAROLA: Obviously pending -- 13 MR. CRITTOM: lot me just finish. 14 MR. SCAROLA: Obviously pending, obviously 15 pending some instructions or guidance from the 16 court with regard to how the court will 17 interpret the work-product privilege in this 16 context. I might also add that It is our 19 position that any such inquiry exerts a 20 chilling effect upon the work that Mr. Edwards 21 continues to do on behalf of his three Clients. 22 It is intended as a means to obtain 23 discovery that would net otherwise be 24 available in chose pending claims. It is 25 Intended to annoy, Cs, and emba PROSE COURT REPORTING AGENCY. INC. PROSE COURT REPORTING AGENCY. 111C. EFTA01100774 Page 105 1 Mr. Epstein in a lawsuit that hat 2 absolutely no foundation whatsoever, and 3 was filed for purposes other than a 4 legitimate claim against Mr. Edwards based 5 upon any good faith belief that he engaged 6 in any form of improper or nations 7 conduct and -- e MR. CRETTON: Done? 9 MR. SCAROLA: -- those Inquires are not 10 reasonably calculated to lead to the discovery 13 of admissible and relevant evidence. So, for 22 all of those rearms, we object. 13 KR. CAPRON: Md let me just put on the 14 record very briefly so et least at this point 15 In time this is all information that clearly is 16 relevant co the complaint as it". alleged. 11 I have received a. my client and I 18 have both received a letter from you 19 asserting a motion for fees and costs and 20 certain sanctions under 57.105. by not 21 allowing us to ask what are clearly. I 22 believe, relevant material, basic 23 discoverable information are preventing 24 our ability to-get all of the facts here 25 such that We can make a reasonable PROSE COURT REPORTING Aar, INC. Page 107 1 Q. All right. Md have any, have you had any 2 discussions -- well, let me strike that. What's the 3 status of that case? 4 A. It's still pending. 5 Q. Other than still pending is a, is there. 6 aro there any outstanding motions? 7 No. 8 0. I want to ask, to get back to one question 9 with regard to both the :Ass': and with regard to the 10 Fortis System -- well, let me strike that. 11 with regard to the hard copies of the 12 files that you had that is any paper files that you 13 had associated with the Epstein files, where would 14 they have been kept at IWO 15 A. In a filing cabinet. 16 Q. And were the filing cabinets in your 11 office or were they out in the general hallways? 18 A. They were filing cabinets In my office and in 19 other locations in the office. 20 O. Okay. With regard to the Epstein related 21 matters, where did you keep those if they were -- 22 and by that that is the hard copies. did you keep 23 those solely in your office or would they have been 24 both in your office and in other places throughout 25 MA? decision as to whether or not the 51.10:494 105 2 motion and letter which you sent to me was 3 filed in good faith or has any basis in 4 it. We're unable then to, we'll be in 5 large part unable to evaluate Out 6 position. 7 MR. SCAROLA: And our position is that a those are decisions that should well have been 9 made. Could have been made, and should have 10 been made before you ever filed the claim. 11 KR. CRITTON: All right. Are we done? 12 M. SCAROLA: Yes. 13 MR. CR1TTON: All right. 14 M. SCAROLA: At least for now. 15 MR. CRITTON: I'm shocked. 16 BY MR. CRITTON: 17 0. With regard CO, with regard to the claim 16 Jane Doe 1 and Jane Doe 2 that is currently 19 pending -- or let me strike that. Jane Doe 2 -- 20 Jane DO* I and Jane Doe 2 against the O.S.A. that 21 was filed in July of '08, that case is still 22 23 pending. A. Okay. 24 O. Is that correct? 25 That was a question, yes. PROSE COORS REPORTING AGENCY. 1NC. Page 108 There were times when they were in my office 2 and there were times when they were kept in filing 3 cabinets elsewhere on one of the RAA Iloore. I believe 4 there were five or six floors of KRA 5 Q. Okay. Was there a central storage, say if 6 there were a number of files In this Instance relating to Mr. Epstein, could you send chose to basically central storage and if you wanted someone 9 could go down and pick them up and bring them up to 10 you? 11 A. I don't know. 12 Well, If you wanted to access something 13 that was in en Epstein file, and it wasn't in your 24 office, how did you access it: that is, a hard copy? 15 A. You're speaking specifically about 16 Mr. Epstein's cases or hypothetically with any eases? 17 Q. No, MS. Epstein's uses? le A. AS I sit here right now, I can't say with 19 absolute certainty that I ever had a piece of the hard 20 copy file requested for it to be brought to me. 21 O. Nell, with regard to Mr. Epstein's rtleS. 22 though, if they were in a location, would it be a 23 correct statement that those were not, wasn't a 24 locked location or a secure location within the 25 contents of within the confines of the firm? PROSE COURT REICOTING AGENCY, INC. PROSE COURT *[PORTING Marcy. INC. EFTA01100775 3 5 6 7 8 9 10 21 12 13 14 15 16 1? 18 19 20 21 22 23 24 25 Page 109 1 I don't know that that's a correct statement. 2 O. You don't know one way or the other? A. lime law firm was constantly expanding and constantly under construction. For the most part in the beginning the canoe were kept in a, in a filing cabinet in my office and later wore kept in a filing cabinet, I believe, in a locked storage location in another area of the office. Q. And did any attorney have access to that storage area or do you know? I believe any attorney could have had access. And if the attorney could have access, you wouldn't necessarily know about it, true? A. Correct. Q. In the trustee's filing that they mode in response to my motion co preserve evidence, they indicated that 13 boxes relating to Jeffrey Epstein had been removed by the FBI or the government when they came into the NIA offices. Do you remember seeing that pleading? 0. Okay. Are you, were there, in fact, 13 boxes of material or at least 13 banker's boxes of material that related co matters directed to. whether. whatever the content related to ear. Epstein PROSE Car REPORTING AGENCY, INC. 1 2 3 5 6 9 10 Il 12 13 14 15 16 17 le 19 20 21 22 23 24 25 Page Ill did they also have swipe cards so that they could access different areas in the firm? I believe so. With regard to when you joined PRA, did you ever have any further meetings with Hr. Rothstein: that is, from the day you started at AM. did you ever meet Mr. Rothstein again? By meet him again -- did you aver have a meeting with him again 0. regarding your position in the firm? A. No. O. Okay. Did you ever meet with him and a number of other individuals with regards to firm business? Firm uses? don't believe so. O. Was Kr. Rothstein ever present in any meeting whore any of your cases were discussed? Let me strike that. Was Hr. Rothstein ever present wherein at any meeting where any Of the Cases against Jeffrey Epstein were discussed? Don't tell me content; just was he ever present. A. Mow would I know that? I don't know. We could, he could be in a meeting right now where the case 9 10 11 12 13 14 15 16 17 10 19 20 21 22 23 24 25 1 2 3 4 5 6 7 B 10 11 12 13 14 15 16 1? 18 19 20 21 22 23 24 25 Page 110 that you were aware of; that is, hard copies? A. 1 don't know. O. Okay. Could have been more. COuld have been less: you just don't know? Cornet. If I understood your testimony. 0. Hr. Rothstein, Mr. Rownfeldt, any other attorney or investigator could have accessed those files depending or where they were within the firm, true? A. I am not sure exactly who could have accessed it. You asked me If the attorneys could and the attorneys had swipe cards for various locked areas. Each attorney I believe had access to any area whets those files were located. 1 believe so. 0. Okay. Well, during the time you were there did an Individual by the name of Ken Jenne work there? A. Yes. O. Okay. Did an individual by the name of Hike Piston work for the firm -- Yes. -- for AM? Were they employees of the Q. firm or were they independent contractors? A. I don't know. O. Okay. During the time they were there. PROSE COURT IMPORTING AGENCY, INC. 2 3 4 5 6 Page 112 could be discussed for all I know. Q. I'm sorry. Obviously. where you, where you were present. where you ever present at a meeting where Mr. Rothstein was also present where the Epstein cases were discussed? A. No. 7 O. Did he ever call you to communicate with you, call you either by phone, video conference. In any fashion to discuss any act aspect of the cases that you had against Jeffrey Epstein? MR. SCMOLA: You can answer that. THE WITNESS: Re has communicated about various, about legal issues related to the Case as well as commented about the case to me on very few occasions but I would say less than three times. BY HR. CRITTOP: O. During the time that you. from April of '09 through late October of '09. correct? In that time period, where, is that when these -- 0. Correct. A. -- things happened? O. Well, that', the time you were there: that's what I am asking. PROSE COURT REPORT= AGENCY, 1PC. PROSE COIWT REPORTING AGENCY, 1PC. EFTA01100776 Page 113 1 A. when 1 was there. 2 O. And do you. can you remember the date, any 3 specific date that you spoke with him? 4 A. No. 5 Do you remember any specific month that 6 you would have had one of the -- well, what did you say something less Than five conversations? 1 don't want to misquote you. 9 I said less then three conversations. 10 All right. So. something less then three 11 conversations you had with Mr. Rothstein regarding 12 Epstein cases, either legal issue or a comment. acme 13 comment about the ease to you, correct? 14 A. Yes. 15 Q. All right. The first time that he over 16 spoke to you, did he call you or did you call him? 1? 1, 1 never called Scott Rothstein about IS anything. Oh, take that back. About anything related 19 to Jeffrey Curtain. 20 O. The first conversation that you can recall 21 where either a legal issue or a comment was made 22 about Jeffrey Epstein by Kr. Rothstein to you, he 21 obviously initiated the call? 24 - A. It wasn't a call. 25 O. What was it? PAWL COURT REPORTING AGENCY, INC. Page 115 1 that we have had an opportunity to consult and 2 I have advised Mr. Edward, that these is no 3 privilege protection for the particular 4 communications involved. 5 BY KR. CRITTON: 6 O. What did he say? 7 A. Me commented to me, I want you t0 get that Pedophile. 9 Md your response was what? 10 1 didn't respond. 11 Q. All right. Second conversation that you 12 can remember. where were you? 13 A. I had lust CON out of the conference room on 14 the main floor after taking a deposition in another 15 case. And he walked by and said, did you get that ring 16 pedophile yet. 17 O. And your response? le A. Again. 19 O. NO response. 20 A. Didn't respond. 21 O. On the first occasion when he came over 22 and if I understand correctly, all ha said was the 23 comment that you referenced and then he left. You 24 didn't respond and then he lust made the comment and 25 then left? Page 114 1 A comment in passing. And 1 believe 1 was 2 sitting at a table in BOVA when he welted over to my 3 table and commented about Jeffrey Epstein. 4 O. Okay. Who were you there with at the time? 6 A. 1 don't remember. 7 O. Were you with sone friends? Were you with other lawyers? 9 A. All right. 1 am jagging my memory. I, 1 have 10 no ides. 11 O. What did he say? 12 101. SCAROLA: To the extent that you can 13 answer that question without disclosing any 14 mental impressions with regard to the lawsuit 15 or any attorney-client privileged 16 communiCetiOnS, you can answer. 1? To the extent that it might invade IS either the work-product or attorney-client 19 privilege, you should not respond. 20 THE WITNESS: Cen I talk to you? 21 KR. SCAROLA: Sure. 22 IA brief recess was held.) 23 KR. SCAROLA: Are we on? 24 THE VIDEOGRAPHER: Yeah. 25 KR. SCAROLA: The record should reflect PROSE COURT REPORTING AGENCY. ]NC. Page 116 1 A. Right. Ho was walking by in his normal, loud. 2 ostentatious kind of way, greeting everybody in the 3 restaurant. Came over to my table and he feels. at 4 least my impression was obliged to say something to 5 everyone. And that's the comment he said to me. 6 Md if you've ever seen him, he is 7 basically always lust skipping around end he hoped on over somewhere else. So. yell, it was in, literally in passing. 10 O. Okay. How, how, how did he even know you 11 had cases involving Mr. Epstein? 12 A. 1 don't know. 13 O. Because 1 think you testified earlier chat 14 you had never discussed an Epstein case with 15 Mr. Rothstein one-on-one, correct? 16 Absolutely, true. 1? You never discussed an Epstein Case or IS either of your three clients with Mr. Rothstein even 19 with a group of people around, Correct? 20 A. Correct. 21 O. All right. Do you remember a third 22 occasion that he spoke to you regarding Epstein 23 related occasion, cases? 24 A. Anything else that he ever spoke with me about 25 related to Epstein related issues is attorney-client and PROSE COURT REPORTING AGENCY. INC. PROSE COURT REPORTING AGENCY INC EFTA01100777 Page 111 1 work-product privileged information that L am not going 2 to divulge. 3 O. Okay. I am not -- I need to still ask the 4 last question though. 1 thought You said earlier is that you never had any substantive conversations, 6 maybe I misunderstood, with Mr. Rothstein about the 1 Epstein cases. Did 1 misunderstand you? A. I don't believe that that was -- I had 9 conversations at a point about legal issues related to ID Jeffrey Epstein and that's. that's it. 11 O. Was that a one conversation? Was that a 12 number of conversations that you had where legal 13 issues were discussed as to, separate and apart from 14 the two consents he made about the case to you which 15 you were, you waived any privilege, work-product or 16 attorney-client Privilege? 17 A. 1. I can't tell you. If you and I this morning had a conversation and then we took a bathroom 19 break, and we had the same continuing conversation. I 20 don't know if that's one conversation or two. But I can 21 tell you the, the only time 1 remember Scott Rothstein 22 participating in any way, shape, or form in any 23 conversation related to anything substantive dealing 24 with, and not dealing with any specific client but a 25 legal issue, was on a particular one-day event, one-day PROSE CCUAT REPORTING AGENcV, INC. Page 119 A. Scott Rothstein's office. 2 Q. Had you been called up to meet with 3 Mr. Rothstein? 4 A. Yes. 5 0. Okay. And who contacted you and tole you 6 that Mr. Rothstein wanted to see you? 7 A. Nis, his secretary or paralegal or something. O. And did you get a cell. saying Mr. 9 Rothstein would like to see you right now, or was it 10 something that was scheduled? 11 A. It was not scheduled. 12 0. SO, you got a call and somebody told you. 13 Cane up. Scott. Scott wants to sea you. 14 A. I don't remember exactly what was used, but it 13 was I believe, Russell is discussing a legal issue with 16 Scott Rothstein: cane to his office. 17 O. Okay. Was the legal issue, did it involve IR one of the Epstein cases or the Epstein cases? 19 A. It, it was a legal issue related to -- yet. 20 Q. Okay. Now long, how much time did you 21 spend -- well, let me strike that. So, when you 22 went up to ler. Rothstein's office. it's -- I 23 understand you had to go through some security to 21 get in? 25 A. You've seen the video? Page lie conversation, if you want to cell It. 2 Q. And that'', at what time? At that time 3 legal issues were discussed? 4 KR. SCAROLA: Legal Issue was the testimony. a particular legal issue. 6 KR. CRITTON: Correct. A legal issue. BY MR. CRITTON: 0. When did that occur: that is. this one-day 9 discussion or a day discussion occur regarding a 10 specific legal issue? 11 I don't know. /2 Was he present, he Mr. Rothstein and you 13 present at the same time? 14 Yes. 15 Okay. Was anyone else there with you? 16 Yes. 17 Who else was present? 16 Russ Adler, someone was on the telephone. I'm 19 not remembering who that was. I can't remember. 1 will 20 tell you if 1 do remember. 21 Wail Bill Berger there? 22 23 And, you don't. So, there was you. Well, 24 let me strike that. Where did the conversation take 25 place? . PAWL COURT REPORTING AGENCY. INC. Page 120 1 0. 1 actually haven't. 2 A. Oh, really. Okay. Yeah, it'll -- 3 Q. In order to get into Mr. Rothsteln's 4 A. It's like a compound. 5 Q. Kind of concern you that this guy running 6 the firm had a compound? A. I -- at the time, no. In retrospect, okay, now that we all know how this whole thing unfolded, but 9 at the time, no. 10 Q. Had you over worked in en office? And you 11 had worked at some big offices. You worked at the 12 State Attorney's office in Brower.) County? 13 True. 14 You worked (Or, I think for Kubicki 15 Draper? 16 A. Correct. 17 Did Mr. Kubicki, Gene Kubiak! ever have e 10 compound around his office that you had to go 19 through any type of security either people and/or 20 locked doors or secured doors in order to access 21 him? 22 A. No. 23 Had you ever worked other than the Broward 24 County Sheriff's, at the Broward County State 25 Attorney's Office with, and with Kubicki Draper. had PROSE COURT REPORTING AGENCY. INC. PROSE coon azeoarim AGENCY. INC. EFTA01100778 Page 121 1 YOu ever woried fOr a large firm? 2 A. Ho. You just named all the places I have 3 worked. 4 Q. All right. Is this the first time then 5 that you had been to Hr. Rothstein's office that he 6 called yOu up there? 7 NO. You had been in his office before? 9 one time. 10 O. And what was that occasion? 11 A. I use having back surgery, and 1 went there CO 12 tell him I am having back surgery. As you know I had 13 back surgery, and I was telling him 1 don't know how 14 long I'm going to be off because, you know, the recovery 15 time is different for everybody. 16 O. Is that the only thing you talked about. 17 the back Ourgeff2 18 That's the only thing we talked about. 19 Old the meeting you had with Scott. when 20 you went up, when you were called up to his office 21 that day, did that occur before your back surgery 22 episode or meeting or after? 23 A. 24 Q. So, you would, you had back surgery. I 25 think you were out two or three weeks and then you PROSE Cain PEPORT/NG AGENCY. /PC. Page 123 1 0. How many security, different security 2 levels did you have to go through in order to get, 3 to go have your meeting with Hr. Rothstein and 4 Hr. Adler? 5 6 O. And so your recollection you don't 7 remember !VOL seeing a security person? 0 Right. 9 O. Okay. Who was in the office? 10 A. Well -- 11 O. I'm sorry. 12 A. I do not remember seeing a security person 13 manning the door or granting access to his office. 1 14 saw security people every day in the office of IPA 15 O. All right. And when you got into the 16 office. Mr. Rothstein was there? 17 A. Yes. 18 Q. Mr. Adler? 19 A. Yee. 20 O. There was someone on the telephone who you 21 don't recall? 22 A. Yes. 23 O. Okay. Wee there anyone 01Se present? 24 A. Not that I remember. 25 O. Okay. Was, wore there any investigators. Page 122 1 returned to the office, and then that meeting would 2 have occurred? 3 Yeah, that's correct. 4 When you. in order to get into the office 5 just as you have described it as a bunker, how many, 6 did you have to go through any security people to 7 get into -- e KR. SCAROLA: No, I think the description 9 was a compound. 10 MR. CRITTON: I will use compound. Ate 11 you more comfortable with compound or a bunker? 12 I have seen it described both ways. I haven't 23 seen the video, but I have seen it described 24 both ways. 15 THE WITNESS: I will describe it for you. 16 Well, first I will answer your question. 21 Security people, I don't know if there was ever 18 a time where one would have to go through 19 security people to get to him office. Sut on 20 the day or two days that I have been in his 21 office. I did not encounter any security 22 personnel. 23 BY MR. CRITTON: 24 Q. Did you have to be buzzed into the office? 25 A. It was more complicated than that.. PROSE COURT REPORTING AGENCY, INC. Page 124 was Mr. Jenne or Mr. Fasten present? 2 3 So, it was, you. Rothstein. Adler. and 4 someone on the ohmic; that's it? 5 From what I remember. 6 How long did the meeting last? 7 I don't know how long the meeting lasted. rive minutes or was it a substantially 9 long meeting? 10 A. DO you went how long I was in the meeting, 1 11 can give you an answer. How long the meeting lasted, I 12 have no idea. 13 O. How long did the meeting last while you 14 were present? 15 A. Less than five minutes. 16 O. Was the value of any of the three Meg 17 discussed at all? 18 A. No. 19 Q. Did Mr. Rothstein, did Mr. Rothstein 20 appear to be knowledgeable about your cases? 21 A. Ho. 22 Q. Mr. Adler. was Hr. Adler someone that you 23 had diaeueSed the cases with on a somewhat regular 24 basis -- 25 MR. SCAAOLA: Objection, compound. non COURT inokntio ROOKY. INC. PROSE cogerr Warm AGENCY, INC. EFTA01100779 Pepe 125 Page 126 1 BY MR. CRITTON: 2 0. -- not content. Was Mr. Adler someone 3 that you had discussed these Epstein cases with 4 prior to that meeting? 5 A. Yes. 6 O. Was he familiar with the cases, generally? A. Ne attended Jeffrey Cpstein's deposition. so 0 he heard the questions asked and heard the Filth 9 Amendment invocation and so the adverse inferences and ID was therefore informed -- 11 M. CRITTON: Move to strike as 12 nonresponsive. 13 BY NP. CR1TTON: 14 O. My question is was he familiar generally 15 with the subject matter of the litigation against 16 Mr. Epstein? 17 A. In that he reed the newspaper articles about 10 molesting a bunch of children, yes. he was familiar with 19 the subject matter. 20 O. And he read -- did you provide him with 21 copies of the pleadings in these cases when they 22 cam to ARA? 23 A. No. 24 0. What was the topic? Mat was the legal 25 Issue that you discussed -- well, let me strike PROSE casts REPORTING AGENCY. INC. Page 127 1 issue. 2 If it was not an issue that was 3 identified in the course of the 4 proceedings to opposing counsel. I am 5 going to object and instruct you not to 6 answer on the beets of the work-product 7 privilege. THE WITNESS: Work-product privilege. 9 BY MR. CRITTCN: 10 Q. Do you know an individual by the name of 11 Tandry. P-a-n-d-r-y7 12 A. That nave doesn't ring a bell right now. 13 0. Do you know him to be -- does that name 14 man anything with regard to, as an investigator, 15 Fandry? 16 A. That's a male? 17 Q. Pardon? IS That's a first name or a last name? 19 O. Last name, Richard fandry. 20 A. I know en investigator named Rick that did 21 work, was contracted out by MA to do investigative 22 work. I don't know his last name but -- 23 Q. D1d. did Rick ever do any work on any of 24 the Epstein cases to your knowledge? 25 A. I believe so. 1 that. Who raised the legal Issue, did 2 Kr. Adler raise it or did Mr. Rothstein? 3 A. I don't know. 4 Q. Okay. Well. how did the, who stetted the. S if you were there I think you said five minutes, who 6 did the talking? 7 A. When I came in the, in the office, it was in S the middle of a discussion. 9 O. Was a question posed to you? 10 A. The question was on the table at least from my 11 perspective coming into the room and was then directed 12 at M. what's the answer to this particular legal Issue. 13 O. And what was the legal Issue? 14 104. SCAROLA: Let's talk for just a 15 second. 16 THE VIDCOGRAPAER: Are we going off the 17 record? 10 MR. SCAROLA: Actually, we don't even have 19 to go off the record. Stay right here. 20 If this was an issue that was 21 identified during the course of the legal 22 proceedings to opposing Counsel, then I am 23 going to allow you to you Identify the 24 issue without getting into any of the 25 substance of the discussion regarding that PROSE COURT REPORTING AGENCY, INC. Page 120 1 O. Do you know what the name of his business 2 was? No. 4 O. Is Rick still being employed at the 5 current time by your firm to do investigation? 6 A. No. 7 Is Mr. -- I asked you earlier if you knew 0 Ken Jenne and Michael Piston and you said yes and 9 you knew that they had an association with ARA: is 10 that correct? 11 A. Yeah, that's correct. 12 O. And do you know whether they were 13 employees or whether they were independent I4 contractors? 15 A. You asked me that and I still have no Idea. 16 O. Did they have offices within RM, 17 Mr. Jenne and Mr. Elston? IA A. They, Mr. Jenne definitely had an office 19 within RM Mr. Piston was normally in the field end I 20 seams/ he had a place to go In SIM I don't know if you 21 call it an office. 22 O. Did you ever go -- 23 A. That'll it. 24 O. Did you aver go met with him within ARA? 25 A. Yes. PROSE COURT REPORTING AGENCY. INC. PROSE COURT REPORTING AGENCY. INC. EFTA01100780 Page 129 Page 13D O. Where did you go did you go to an 2 office to meet him? 3 A. Well, I went to a particular area, a locked 4 areal that I could get in with my swipe card and there 5 was a, a room like this. Is this an office? 6 O. Sure. 7 A. Okay. Then yea. Q. If you wanted to contact Hr. Fisten, did 9 you, did you have a number: that is, an inside 10 number? 11 I don't know. 12 O. Did Mr. Platen do work on the EliSteln 13 related cases? 14 A. Yes. 15 Okay. What kind of work did he do? 16 A. Investigator. 17 0. Meaning what? 18 Meaning investigative work. 19 Okay. Has Hr. listen continued to do -- 20 let me strike that. When NIA Imploded in early or 21 in late '09. In October of '09, did Mr. Fisten case 22 to work for your firm? 23 A. Yea. 24 O. Farmer. Jaffe. Is he an employee of your - 25 firm? PR= COURT REPORTING AGENCY. INC. Page 131 1 A. Yes. 2 Q. Did he ever do any work, or did you ever 3 direct him to do any work with regard to the Epstein 4 cases? 5 A. No. 6 O. Did he know about the Epstein cases? 2 A. Yes. 8 O. Okay. Md how did he know? How did you 9 know he knew? Well, let me strike that. I think 10 you said you never directed him to do any work? 11 A. Right. 12 O. Okay. Md how do you know he was 13 knowledgeable about the Epstein cases? 14 A. I talked to him about it before. 15 O. Did you discuss the fact, and 16 circumstances of the cases with him? 17 A. Of L.M., E.M., and Jane Doe's specific IS clecummtanCes, no. In fact, I would say, I would 19 highly, It's highly unlikely that he would even know 20 their names. 21 O. Rut you have discussed the Epstein cases 22 with him generically? 23 A. Right. 24 O. Md did he approach you about discussing 25 the Epstein cases or did you approach him? 1 A. Correct. 2 O. 110. about Mr. Jenne. Is he currently 3 employed by your firm? 4 A. No. 5 Q. Do Mr. Jenne and Hr. Piston. to your 6 knowledge, have any association at the current tine? No. 8 Have, has Mr. Fasten Continued to do work 9 on behalf of your firm: that is. investigative work 10 relating to Mr. Epstein? 13 What do you mean has he continued to? 12 Q. Ras he continued, has Mr. Fisten done. 13 continued to do investigative work since he had been 14 with Farmer Jaffe relating to the Epstein cases? 15 On, on many uses and Jeffrey Epstein's calf 16 being one of them, yes, he's done some work. 17 O. Has he, has he es well -- well, let me 18 strike that. Has Ken Jenne done any work for any 19 outside agency, investigative egenCy or entity, done 20 investigation work relating to Jeffrey Epstein here 21 In the State of Florida? 22 1 don't, I don't know. I don't talk to him. 23 0. Have you had any contact -- well, let me 24 strike that. Did you ever have any contact with 25 Hr. Jenne during the time you were at PRA? PROSE COURT RtrorriNG AGENCY, INC. Page 132 1 He would have approached me. I didn't know 2 him. 3 Do you recall why -- let me strike that. 4 Do you recall how long you were at the firm, RSA 5 before he approached you to talk about the Epstein 6 7 A. My recollection Is snore) months. 8 O. Okay. On how many occasions did he 9 approach you to talk about the Epstein cases? 10 1 don't know. 11 Q. More than once? /2 A. Yes. 13 Q. Ware than twice? 14 Yea. 15 More then five times? 16 A. Yes. 17 Q. More than ten times? ID A. Possibly. 19 O. Okay. Md with regard to Mr. Jenne did 20 you ever give him, was he ever en invite person on 21 your Otask? 22 A. I dO not believe so. 23 O. Did, did you ever ask Mr. Jenne why he was 24 Interested in your Epstein cases? 25 A. Mo. PROSE COMP REPORTING AIWJACV, IMO. PROSE COURT REPORTING AGENCY, INC. EFTA01100781 Page 133 1 O. Okay. And on each occasion he approached 2 you about talking about the Epstein cases? 3 A. On the first I occasion, definitely. 1 can't 4 say on every occasion that we had a conversation. S O. And If I understood you correctly. you 6 never assigned Mr. Jenne any tasks, any task: is 7 that correct? B That's Correct. 9 0. Did you find it odder strange that he 10 would want to talk to you about your Epstein cases? 11 12 O. Did you, did you -- Mr. Jenne reported to 13 whom as you understood? 11 1 didn't understand anything. 15 Do you know what his position with the 16 firm was? 11 A. No idea. 16 Q. Did he ever offer to help you with the 19 Epstein cane? 20 A. In some respect, I guess so. Generally, you 21 know. I, I can help. This Is basically a criminal 22 matter: I can help. You know, that kind of thing. I am 23 not saying those are his exact words but paraphrasing 24 the gist of It, that's what 1 remember. 25 O. Okay. Mt. Edwards. did you ever contact PROSE COURT REPO/RIM AGUICr, INC. Page 135 1 A. No. 2 O. When Mr. Push contacted you, do you know 3 why he contacted your that is, what -- well, let me 4 strike that. When ha contacted Mai. did you take 5 his Call right sway or was his a call that you had 6 to return? A. I don't remember. 8 Q. Do you remember speaking with a person 9 named John Canally? 10 Yes. 11 Okay. What was Mr. Canally's association? 12 I don't know. 13 O. Do you know who he was with at the time? 14 A. No. 15 What did your discussion with Mr. Canally: 16 that is. what was Mr. Canally interested in and what 11 did you tell him? 15 M. SCAROLA: Objection. compound. 19 TIE WITNESS: /, I listened to him more 20 than told him anything. 21 BY MR. CRITTON, 22 Q. Did you provide him any information? 23 A. In the back and forth of the conversation. I. 24 you know, maybe general information that one could read 25 from the newspapers 1 talked to him about. Page 134 the media or the press when, that's 10Cated in New 2 York. City, the State Of New York, about any of the 3 Epstein cases? 4 A. I may have returned telephone calls that were 5 initiated by press to me. 6 O. My. my question to you was, did you 7 initiate any telephone calls; that is, without B returning a call to the, to any member of the media 9 or press in New York regarding the Epstein cases? 10 A. Meaning the first conversation -- 11 Q. Right. 12 -- between -- yeah. No, I did not. 13 Who contacted you from New York with 14 regard to any Epstein related matter? 15 The press. 16 O. Who? 1? A. 1 don't remember anybody's name. 16 0. Give me anybody's name that you can 19 recall. 20 George Rush. 21 What media, what did you understand his 22 association? 23 A. I believe New York Daily Hews. 24 O. Do you remember when Mr. Rush contacted 25 you? PR E COURT REPORTING AGENCY. INC. Page 136 1 O. 01d you speak with, other than -- on how 2 many occasions did you speak with Mr. Canally? 3 I don't know. 4 O. On how many occasion's have spoken with 5 Mr. Rush/ 6 A. I don't know. 7 NOre than onCe with Mr. Rush? I would say so, yea. 9 O. More than five times with Mr. Rush? 10 A. That's approximate, that's approximately 11 correct. 12 O. Okay. Mr. Canally, did you speak with him 13 on more than one occasion? 14 A. Yes. 15 O. On how many occasion's have you spoken 16 with film? 11 A. I don't know. 18 O. Flue, two, three. Your best estimate? 19 More than five. 20 O. When was the last time you spoke with 21 Mr. Canally7 22 A. 2009. 23 O. Nave you had any contacts with the media 24 or the press during the year 2010, January. 25 February, March, and we're almost, well. we're PROSE cow? REPORTING AGENCY. INC. PROSE COURT REPORTING AGENCY, INC. EFTA01100782 Page 13? Page 13$ 1 almost at the end of March. In the last three 2 months, starting in January 1st of 2010. have you 3 had any contact with the pleas? 4 A. Not that I recall. 5 9. Nes the press contacted you, but you have 6 not returned their Calls? A. On hundreds and hundreds of ocCellOrill. Q. Well, my question is since the beginning 9 Of. Since January let of 2010 has the press 10 attempted to contact you? Yes. 12 0. And if I understand your testimony. you 13 have not returned any of those calls? 14 A. To the best of my recollection 1, 1 do not 15 remember speaking with anybody from the press during 16 this year, 2010. 17 O. In 2010. do you have a recollection of IS having spoken with people but saying you can't quote 19 me. 1.e., I have no comment or I will tell you off 20 the record? 21 A. 1 don't even remember having those 22 conversations with anybody In 2010. If you know of 23 mem:meshing and can refresh my recollection. I. you may be 24 - to remind me. but I don't think in 2010 I have had 25 -sny'of those conversations. PROSE COURT REPORTING AGENCY, INC. Page 139 I -Z-billeve. November. 2 r Q. And the first time that Mt. Rush called 3 you, what was the subject? 4 A. Jeffrey Epstein. 5 Q. Okay. 1 assume you never talked with 6 Mr. Push about any topic other than pr. Epstein, 7 correct? 0 A. That's a safe assumption. 9 Q. When he first COntaCted you, can you 10 differentiate what he said on the first occasion 11 versus a later occasion? 12 A. 1, I, no, in chronological order 1 can't right 13 now. 1 haven't gone back and thought about this like 14 this before. 15 0. Did you ever correspond with Mr. Rush or 16 Mr. Canally by -mall? 17 A. Mr. Rush. I believe that answer is no. With IS Mr. Canally, yes. 19 Q. And so 00 you have copies of the e-mails 20 that you and Mr. Canally exchanged? 21 A. No. 22 O. Okay. Would they have been while you were 23 at ARA. ARA7 24 A. Correct. 25 O. Wich regard to Mr. Rush, If you did 1 Q. The conversations you had with George 2 Rush, when you returned his call, whet did Mr. Rush 3 ask you? What was he inquiring about? 4 My response to Jeffrey EpsteLn's consents. 5 Q. Which comments? 6 A telephone conversation initiated by Jeffrey 7 Epstein to George Rush related to the various cases and claims against Mr. Epstein. 9 0. Did Mr. Rush call you -- I'm sorry, 1 will 10 improve it. If I understand correctly when Mr. Rush 1/ called you, that's the first time you knew who he 12 13 A. I didn't know who he was before he called me, 14 15 What did Mr. Rush tell you what Jeffrey 16 Epstein had said to him? 17 A. And I'm not sure that that was the first 10 Conversation I had with, with George Rush. Like I said 19 I think I've talked to him three or four, five times. 20 Q. Okay. Well, let se see if 1 can place, 21 can you give me a point in time when you first spoke 22 to Mr. Push and when you last spoke with him the 23 approximately five-tines that you related? 24 A. Each oS those times were in 2009 between, • 25 earliest possible, June. I think, yeah, latest possible, PROSE COURT REPORTING AGENCY, INC. Page 140 1 communicate with his by e-mail, would it be during 2 the time you were with AM? 3 A. That's correCt. 4 Did you communicate with any other member 5 Of the press during the time, we'll cone back to 6 Mr. Epstein. During the time when you were at AAA, • did you communiCaut with anybody else by. by either, • first of all, by e-mail? 9 A. Whet is your question again? I'm sorry. 10 Q. Okay. Did you -- other than Mr. Rush who 11 you're not sure you communicated by e-mail, 12 Mr. Canally who you are sure you ccerrounicated by 13 e-mail during the time you were at AAA. WS there 14 any master of the press. TV, written news media. 15 television that you communicated with -- 16 A. I'm sure. 11 Q. -- by e-mail? 10 1 em sure there is. 19 Okay. Do you remember any of their names 20 other than Hr. Rush and Mr. Canally es you sit here 21 today? 22 A. Hot as I sit here today. I do not. 23 Q. Did you ever communicate with Jose 24 Lambiet7 25 A. I don't know who that Is. PROSE COURT REPORTING AGCNCY. INC. PROSE COURT REPORTING AGENCY. INC. EFTA01100783 Page 141 Q. No does a Page 2 or accething with the. 2 Page 1, Page 2 of the Pals Beach Post? 3 A. No. I'm not, no. 4 Q. Okay. Nave you ever spoken with Jane 5 Muskrat 1phonetic1? 6 A. Again. I don't know who that is. 1 O. Nave you ever -- did you ever give or 0 allow one of your clients CO give en Interview to 9 one of the local TV stations? 10 HR. SCAROLA: Clajection, compound. 11 TNC WITNESS: One of my clients gave an 12 interview to One of the local television 13 stations. 14 BY NA. CRITTON: 15 O. Which of your clients gave the interview? 16 A. Jane Doe. 1? O. Md did you organize that? 18 A. 1 assisted. 19 Which, which TV station was it? 20 A. I don't remember. 21 0. Do you remember who the person was from 22 the TV station that contacted you? Let me strike 23 that. Now did it came about that Jane Doe gave an 24 interview to the TV station? 25 A. Various television stations have been PROSE coupe REPORTING AGENCY, INC. Page 143 1 SY Ni. CRITTON: 2 Q. Jane Doe. though, did give an interview, 3 correct -- 4 A. That is correct. 5 O. -- en TV and they blocked out her fate? 6 A. That is cOrreCt. 7 O. Were you there, were you present when she gave the interview? 9 A. Yes. 10 O. Okay. Did you see the interview on TV? 11 No. 12 Did they give you a Gan of the tape of 13 the interview? 14 I believe a copy of the tape was sent to me. 15 O. Okay. Do you still have that in your 16 possession? 17 10 O. Who has it? 19 A. I believe it was destroyed. 20 O. Who destroyed it? 22 A. Nobody destroyed it. 22 O. Okay. You said, I think you said you 23 believe it's destroyed. Now did it come to be 24 destroyed? 25 A. It was sent to me and it was kept in my house Page 1 interested over the course these cases in havingT 112 h4, 2 clients talk. I was adamant that that was not going to 3 happen and Jane Doe wanted that to happen. 4 O• Now did Jane Doe even know that that 5 opportunity existed? If you didn't want It to 6 happen when the news, when the news people, when the 7 TV stations called you why didn't you just say my 3 clients sic not available for Interview? 9 A. What's your question? 10 O. The question is. is. with regard to the 11 T.V. station, you said multiple TV stations wanted 12 to do interviews with your clients. Did 13 understand you correctly? le You did. 15 Md you said you didn't want any of your 16 clients to do interviews. correct? 17 A. Right. 18 Okay. So. why didn't you just say, no, I 19 an not making any of my clients available? 20 MA. SCAROLA: 1 as going to object to the 21 extent that that calls for either mental 22 impressions or attorney-client privileged 23 communications and instruct you not to answer. 24 THE WITNESS: I'm not going t0 answer 25 based on the privilege. PROSE CONY? REPORTING AGENCY, INC. Page 144 1 as I didn't believe it was any portion of the file and 2 ny house flooded and the tape was destroyed. 3 Md did you try to play the tape? 4 1 have never watched the tape. 5 You still hive it. You just think It's 6 destroyed? A. No. I don't even have it. 8 O. You threw it away? 9 It wasn't a natter of throwing anything away. 10 Ny entire house was full with water, every square inch 11 for 12 inches up the wall, end everything was just in 12 mud end got thrown in these huge bins and trashed so -- 13 O. All right. Have you ever spoken with 14 Michelle Daryan? 15 A. Yes. 16 O. On how many Occasions have you spoken with 1? her? Several. 19 O. Nave you e-meiled, exchanged e-malls with 20 her? 21 A. Yes. 22 O. During the tine you, only during the time 23 you were with RNA] 24 A. I believe ao. Theta, there could have been, 25 there could have been en e-mail. oh I only think at AM PROSE COURT REPORTING AGENCY. INC. PROSE GENET REPORTING AGENCY, INC. EFTA01100784 Pape 145 Page 146 1 1 believe that's right. 2 O. As a result of Jane Doe speaking with the 3 press. did she receive any compensation? 4 5 O. NM any in eeee been given separate 6 and apart from the TV interview that Jane Doe gave? 7 Did any of the other, did either of your other two 8 Clients. L.M. or L.14. , ever give an interview to. 9 written to. to the written media, not TV? 10 A. No. 11 With regard to, back to George Rush. you 12 said that Mr. Rush. Mr. Rush contacted you. You 13 reContacted him, correct? 14 A. That's Correct. 15 O. Okay. Md what was the subject matter? 16 What was Hr. Rush interested in talking with you 17 about? 18 A. Jeffrey Epstein. 19 O. Okay. Md what, what specifically about 20 Hr. Epstein? Mow did he even know you existed, did 21 he say? 22 A. I don't know. Or, or If I knew, I don't 23 remember how he knew that. 24 Q. Okay. Did you, did you talk to him? 25 'c Yes, I did talk to him. PROSE COURT REPORTING AGENCY. INC. Page 141 1 was something he was conveying to me. 2 Q. Okay. Did he tell you that he had any 3 information that Nr. Epstein had been involved with • any other individuals in any other states, females? 5 A. I don't remember. 6 Q. Did you tell him or did you disclose to him that you were aware of Hr. Epstein having been. having assaulted underage females in other states? 9 I don't remesber. 10 IF. [BITTEN: Heed to take -- why don't 11 we. why don't you change the tape now? 12 THE VICEOGRAPMER: We're now off the video 13 record. It's 1:02 p.m. 14 IA luncheon recess was held.' 15 16 17 18 19 20 21 22 23 24 25 O. Approximately. how many. how long have 3 your conversations been? 3 A. Short. 4 O. And with regard to George Rush. what, you 5 said he was interested In talking about Jeffrey 6 Epstein. What was he interested in? 7 A. I don't remember specifically the issue, but 0 it seemed to me that he can* to me with an issue each 9 time. something related to the case. 10 O. Okay. The case being Hr. Epstein's case 11 or your three cases? 12 A. 1 think that It was typically in general 13 related to the various criminal acts committed by 14 Jeffrey Epstein against the large number of girls in 15 each of the states that Jeffrey Epstein has lived in. I 16 think that was like the gist of his coamun1catiml to me. 17 Well, did he? 18 Or why he was interested. 19 Old he indicate to you that someone had 20 told him that, that certain acts had 0«urred in 21 Other States or locations other than the State of 22 Florida? 23 A. 1 can't say with any degree of specificity 24 what was said, but that. certainly is the impression that 25 I have right now thinking back. Go, 1 believe that that PROSE COURT REPORTING AGENCY. INC. PROSE COURT REPORTING AGENCY. INC. EFTA01100785