Filing E-Filed PM JEFFREY EPSTEIN Plaintiff/Counter-Defendant SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants/Counter-Plaintiff IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEINS APPENDIX IN SUPPORT OF HIS REVISED OMNIBUS MOTION IN LIMINE Plaintiff/Counter-Defendant Jeffrey Epstein Epstein files this Appendix in support of his revised Omnibus Motion in Limine Epstein will supplement this Appendix to attach the actual documents and testimony cited herein and in his revised Motion I DOCUMENTS AND INFORMATION CITED OR REFERRED TO IN EPSTEINS COMPLAINT A Cited News Coverage November On November the South Florida Sun-Sentinel printed an article entitled Scott Rothsteins investment deals seemed too good to be true Sally Kestin Jon Burstein Brittany Wallman Scott Rothstein investment deals seemed too good to be true Fla Sun-Sentinel Nov The Sun-Sentinel reported that Rothstein attracted investors by promising huge returns and selling settlements he said hed reached in sex discrimination and whistle-blower cases Available at t-plan sbnov03 FILED PALM BEACH COUNTY FL SHARON BOCK CLERK PM documents he gave prospective clients show Id The Sun-Sentinel quoted Alan Sakowitz a Miami lawyer and developer who told the Sun Sentinel he had met with Rothstein as a potential investor three times but quickly became suspicious I was convinced it was all a Ponzi scheme and I notified the FBI in detail how Scotty was hiding behind a legitimate law firm to peddle fake settlements Sakowitz said Id According to the Sun-Sentinel a spokesman for Banyan Income Fund an investment group that collected million and invested an undisclosed amount with Rothstein said it contacted federal prosecutors in recent days with concerns about suspicious activity Id The Sun-Sentinel interviewed Rosenfeldt who told the newspaper that several of his co-workers may have done work for Rothsteins investment business without realizing its scope or nature Id The Sun-Sentinel reported that it had obtained Rothsteins confidential offerings which describe extremely high-paying but largely unregulated investment opportunities one of which offered investors a percent return in three months far more than the troubled stock and bond markets Id Sakowitz told the Sun-Sentinel that Rothstein boasted of having sophisticated eavesdropping equipment and that former cops would sift through potential defendants garbage that Rothstein claimed to have a huge volume of cases an employer sleeping with the secretary or receptionist and that Rothstein claimed he offered his clients a way to avoid waiting for the settlement money by giving them a lesser amount but in a lump sum up front Id The Sun-Sentinel said that according to Rothsteins offering documents RRA sought out sexual discrimination and whistle-blower cases and used former cops to dig up incriminating evidence the firm urged the targets of the claims to pay a settlement without a public lawsuit these types of cases are highly confidential and thus quite lucrative because the defendants place a high premium on keeping the details of the case confidential and investors would receive the full settlement amount in three to months with a guaranteed minimum percent return On November the New Times Broward-Palm Beach printed an article entitled Scott Rothstein The Jeffrey Epstein and Bill Clinton Ploy Bob Norman Scott Rothstein The Jeffrey Epstein and Bill Clinton Ploy New Times Broward-Palm Beach Nov According to the New Times one way that Rothstein enticed investors was by tricking them into believing that his firm was representing numerous underaged girls who had sex with Palm Beach billionaire and convicted child sex offender Jeffrey Epstein Id The New Times reported that Rothstein claimed that he had flight logs showing that Epstein flew extremely prominent people including former President Bill Clinton on his private jet with some of the plaintiffs and that Rothstein told investors that Epstein Clinton and other celebrities involved basically had no choice but to settle these cases and that it was a veritable treasure-trove Id The New Times said that investors then ponied up millions to invest in the settlements pay out a portion of those settlements to the victims and pocket the rest but Rothstein was fabricating the story and there was no indication that the former president who was at one time a real friend of Epsteins and other celebrity names bandied about by Rothstein were involved in any way Id The New Times quoted Fort Lauderdale attorney Bill Scherer who was representing multiple Rothstein investors He used the Epstein case as a showpiece as bait said Scherer Thats the way he raised all the money He would use legitimate cases as bait for luring investors into fictional cases All the cases he allegedly structured were fictional I dont believe there was a real one in there Id The New Times mentioned one legitimate case involving Epstein and Available at and bill-clinton-ploy-64 an underaged girl involving RRA identified William Berger not Edwards as the attorney handling the matter and reported that ources said they believe Berger wasnt involved in Rothsteins scam Id A source described the Epstein fabrications as one of Rothsteins more profitable creations and told the New Times to think of the legitimate Epstein civil case as a car on the road then think of that car driving off the road onto heavy terrain and kicking into four-wheel drive Thats what happened here and Rothstein was at the wheel Id The Governments Civil Asset Forfeiture Complaint On November the United States Attorneys Office for the Southern District of Florida filed a civil forfeiture action against certain property of Rothstein The complaint said Rothstein and others had been operating a Ponzi scheme since S.D Fla Case No DE-1 The Government alleged that Rothstein had told potential investors that his firm had negotiated settlements between its clients and would-be defendants and that under the terms of these settlements the firms clients would receive substantial payments in exchange for not filing civil claims in sexual harassment and other labor-related cases Id Rothstein offered investors an opportunity to purchase these settlements at a discount Id The firms clients would receive less money but they would be paid immediately in a lump sum Id Over time the investors would receive the full value of the clients settlements Id The problem the Government alleged was that the settlements were not real Id Rothstein used new investors money to pay older investors the money they were supposed to receive from the phony settlements they thought they had purchased Id Referenced News Coverage November On November the South Florida Sun-Sentinel printed an article entitled FBI doubts Rothstein ran a Ponzi scheme alone Sally Kestin and Peter Franceschina FBI doubts Rothstein ran a Ponzi scheme alone Fla Sun-Sentinel Nov The Sun-Sentinel reported that the FBI confirmed Thursday what many have speculated since the Scott Rothstein scandal broke The flashy lawyer could not have defrauded investors of hundreds of millions without help I do not believe that this was a one-man show said John Gillies head of the FBI in South Florida Id The Investors Complaint On November William Scherer the attorney quoted in the New Times article on November sued Rothstein David Boden Debra Villegas Andrew Barnett TD Bank N.A Frank Spinosa Jennifer Kerstetter Rosanne Caretsky and Frank Preve on behalf of investors Razorback Funding LLC D3 Capital Club LLC BFMC Investment LLC Linda Von Allmen as trustee of the Von Allmen Dynasty Trust Partners LP and Dean Kretschmar 17th Jud Cir Case No DE-3 The plaintiffs alleged Rothstein had devised an elaborate plan to assign putative plaintiffs confidential settlements with structured payments to investors at a lump sum discounted rate In reality while some of the cases relied upon to induce investor funding were real all of the confidential settlements were purely fabricated Indeed returns to earlier investors were not made via structured payments but instead were made with the principal obtained from later investors-a classic Ponzi scheme Id The plaintiffs further alleged that investors were told that the Principal Conspirators had an extensive in-house private investigative team including former F.B.I and C.I.A agents whose singular task was to obtain compromising evidence against high-profile putative defendants Rothstein story was that the evidence and surveillance acquired often supporting civil causes of Available ssociates action ranging from sexual harassment to mass tort cover-ups to whistle-blower claims was presented to the putative defendant who was then offered an opportunity to avoid litigation and the negative publicity associated therewith by agreeing to resolve the matter voluntarily by and through a confidential settlement with the putative plaintiff Id The investors alleged that Rothstein would show investors the purported settlement agreement in an attempt to substantiate the deal however because the settlements were pre-suit and confidential the names of the putative plaintiffs and putative defendants were redacted Id The investors further alleged the purported settlements albeit fraudulent were based on actual cases being handled by RRA"-including one of Edwards cases against Epstein One of the settlements involved herein was based upon facts surrounding Jeffrey Epstein the infamous billionaire financier In fact RRA did have inside information due to its representation of one of Epsteins alleged victims in a civil case styled Jane Doe Jeffrey Epstein pending in the Southern District of Florida Representatives of D3 were offered the opportunity to invest in a pre-suit court settlement against Epstein arising from the same set of operative facts as the Jane Doe case but involving a different underage female plaintiff To augment his concocted story Rothstein invited D3 to his office to view the thirteen bankers boxes of actual case files in Jane Doe in order to demonstrate that the claims against Epstein were legitimate and that the evidence against Epstein was real In particular Rothstein claimed that his investigative team discovered that there were high-profile witnesses onboard Epsteins private jet where some of the alleged sexual assaults took place and showed D3 copies of a flight log purportedly containing names of celebrities dignitaries and international figures Because of these potentially explosive facts putative defendant Epstein had allegedly offered for settlement of the claims held by various young women who were his victims Adding fuel to the fire the investigative team representative privately told a D3 representative that they found three additional claimants which Rothstein did not yet know about Additionally Rothstein used RRAs representation in the Epstein case to pursue issues and evidence unrelated to the underlying litigation but potentially beneficial to lure investors into the Ponzi scheme For instance RRA relentlessly pursued flight data and passenger manifests regarding flights Epstein took with other famous individuals knowing full well that no under age women were on board and no illicit activities took place RRA also inappropriately attempted to take the depositions of these celebrities in a deliberate effort to bolster Rothsteins lies Id r,r The investors also alleged that even after Rothsteins October departure to Morocco millions of dollars continued to flow out ofRRA accounts from the Fort Lauderdale TD Bank accounts indicative of an insider maintaining operations of the Ponzi scheme Id The investors further alleged that a Ponzi scheme cannot be operated without insider help Plaintiffs believe that additional members of RRA including its non-lawyer investigators were used by Rothstein to perpetuate promote and facilitate the Ponzi scheme The details of these individuals or entities involvement,r and participation is presently unknown but further allegations and counts will be added as discovery is conducted and information concerning the complicity of these individuals or entities is confirmed Id Cited News Coverage November On November The Miami Herald printed an article entitled Feds Scott Rothstein Ponzi scheme paid salaries at law firm Jay Weaver Scott Hiaasen Feds Scott Rothstein Ponzi scheme paid salaries at law firm The Miami Herald Nov According to the article Rothsteins law firm generated revenue of million in one recent year yet his lawyer firm had a payroll of million prosecutors said Rothstein who owned half of Rothstein Rosenfeldt Adler used investors money from his Ponzi scheme to make up the shortfall they said Id The article further reported that the civil forfeiture is based on money-laundering allegations that Rothstein amassed his fortune by defrauding investors prosecutors said Investors bought shares in his fabricated confidential settlements from employment-discrimination and other civil cases during the past four years investments that promised returns ofup to percent Id Amended Complaints Filed By The Government Investors On November and November the United States Attorneys Office for the Southern District of Florida filed amended civil forfeiture complaints against Rothsteins property S.D Fla Case No The Government again alleged that Rothstein and others had been running a Ponzi scheme See id Scherer filed an amended complaint on behalf of the investor plaintiffs on November See 17th Jud Cir Case No The amended complaint quoted a November interview of Rothstein by the Sun-Sentinel Rothstein stated that karma has caught up with him but it will catch up with others too Youre in a town full of thieves and at the end of the day everyone will see Ill leave it at that Id The plaintiffs did not amend their allegations concerning the cases against Epstein See generally 17th Jud Cir Case No Rothstein Arrested Criminal Information On December the FBI arrested Rothstein and the United States Attorneys Office for the Southern District of Florida filed a criminal information against him The information identified RRA as a criminal enterprise S.D Fla Case No DE-1 The government alleged that from until November Rothstein and others had engaged in a pattern of racketeering activity that included mail fraud wire fraud money laundering and conspiracy to launder money Id r,r According to the Government Rothstein and his unidentified co-conspirators had operated a Ponzi scheme and obtained billion from investors by fraud Id The Government repeated its allegations that Rothstein had lied to investors The amended complaint misquotes the article slightly Youre hurting my daughter youre hurting my son Rothstein said Rothstein has a biological daughter who is and the son hes talking about is someone he took on as a sort of mentor he said this summer Havent I already hurt them enough he asked before delivering a final message and hanging up He called back this evening responding to a text message He said karma is going to get him but its going to get other people too Youre in a town full of thieves and at the end of the day everyone will see Ill leave it at that Brittany Wallman Scott Rothstein You re in a town full of thieves Fla Sun-Sentinel Nov Available at 11-scott_rothstein havent_i_ hurt-story.html had told them that his firm had settled certain sexual harassment and whistleblower cases on behalf of its clients and obtained sizeable payouts and had offered investors the opportunity to purchase these phony settlements at a discount Id r,r The Government alleged that Rothstein and his co-conspirators had created false and fictitious documents including confidential settlement agreements and made false statements to current investors in order to convince them to re-invest in additional purported confidential settlement agreements Id r,r II EPSTEINS DEPOSITION TESTIMONY AND AFFIDAVIT REGARDING PROBABLE CAUSE A Epsteins Deposition-March Epstein testified as follows Why are you suing L.M A L.M is part of a conspiracy with Scott Rothstein Bradley Edwards creating excuse me creating fraudulent cases of a sexually charged nature in which the U.S Attorney has already charged the firm of Rothstein a firm of which Bradley Edwards is a partner was a partner with creating fabricating malicious cases of a sexual nature including cases with respect to me specifically in order to fleece unsuspecting investors in South Florida out of millions of dollars What role do you contend L.M played in that conspiracy to create fraudulent cases A L.M testimony before she met Mr Edwards was dramatically sworn testimony to the FBI was dramatically different after she came in contact with Mr Bradley Edwards where her testimony then changed to sort of a hostile and had claims of claims never made before never made to anyone before and allegations that Ive read in her Complaint that that had been dramatically different from the ones she had spoken to the FBI about sir Tr at Your Complaint in this action alleges that L.M made claims for damages out of proportion to her alleged damages What does that mean A I believe that as part of the scheme to defraud investors in South Florida out of millions of dollars claims of outrageous sums of money were made on behalf of alleged victims across the board And the only way in fact Scott Rothstein sits in jail And what Ive read in the paper claims that Ive settled cases for 200-million which is totally not true She has made claims of serious sum of money which is outrageous Tr at Did Brad Edwards do anything that he shouldnt have done that forms the basis of your lawsuit against him A Yes many things List them for me please A He has he has gone to the media out of I believe in an attempt to gin up these allegations He has contacted the media He has used the media for his own purposes He has brought discovery he has engaged in discovery proceedings that bear no relationship to any case filed against me by any of his clients His firm which hes the partner of has been accused of forging a Federal Judges signature Tr at Besides having gone to the media in an attempt to quote gin up unquote these allegations and engaged in what you contend to be irrelevant discovery proceedings what else did Mr Edwards personally do that forms the basis for this lawsuit A Mr Edwards personally engaged with his partners Scott Rothstein who sits in a Federal jail cell potentially for the rest of his life he shared information what Ive been told and excuse me what Ive read in the newspapers boxes of information that had my name on it with other attorneys at his firm He counseled his clients to maintain a position alleging multi-million dollar damages in order for them to scam local investors out of millions of dollars He and his many of his other partners already under investigation by the FBI and the U.S Attorney have been accused by the U.S Attorney of running a criminal enterprise Anything else A Not that I can think of at the moment Okay What media did Mr Edwards go to A I am aware of at least the Daily News in New York City I have been told by other people that there were other media local media Ive been told that the his investigator was sent to California to harass people representing his Brad Edwards investigator representing fictitiously fraudulently that he was a FBI agent to try to gather information for Mr Edwards claims Tr at What does an investigator going to California have to do with Mr Edwards allegedly going to the media in an attempt to quote gin up unquote these allegations A Its part of Mr Edwards scheme to involve people who have nothing to do with any of his cases in order to in fact go back to the media and gin up his stories and make false allegations of people that have sexually charged nature cases in order to attempt to fleece investors local investors out of millions of dollars His firm has been accused by the U.S Attorney of manipulating the media by hiring investigators by illegal wire taps by illegal methods of eavesdropping in order to go to the media and generate cases When did Mr Edwards go to the Daily News A I dont know How did he go to the Daily News A I dont know What did he say to the Daily News A I believe Mr Edwards knows that I dont know exactly what he said What is the source of your information that he went to the Daily News at all ever A Its attorney/client You said you were told by other people that he went to other media representatives A Yes sir Who are the other people that told you that A I dont recall at the moment What did these other people who you dont remember tell you Mr Edwards did with respect to other media representatives besides the Daily News A Again the question again What did these other people tell you Mr Edwards did with respect to going to other media A Mr Edwards went to the media to gin up his cases in order that the Rothstein firm could generate profits falsely taking in investors creating false stories to the local medias and making statements to local press regarding false claims made by his clients in order that Scott Rothstein who currently sits in jail could defraud along with his other partners of his firm local Florida investors Mr Scarola out of millions of dollars When did these other people whose identity you cant remember tell you these things that Brad Edwards did A Sometime in the past year How many other people were there who told you these things about Mr Edwards A I dont recall with specificity Well do you recall in any degree how many there were A I would say probably five to ten Where were you when these conversations took place that you cant the identity of those participants you cant remember Mr Pike So were clear within the last year correct timewise Mr Scarola Well thats what your client said I dont believe a word he says but thats what he said A Again sir Yes sir Where did these conversations with these five to ten people take place whose identity you cant remember A On the telephone Who initiated the phone calls A Sir these questions I have no I dont have any recollection Did the people who were on the phone identify themselves or were these anonymous callers A Sitting here today Mr Scarola I dont recall with specificity What specifically did Mr Edwards allegedly communicate to the Daily News to quote gin up these allegations unquote A The newspapers have quoted Mr Edwards not quoted Mr newspapers have made allegations referred to as Mr Edwards statements Would you read the question back please Sandy A He alleged that third parties had already been involved in some allegations to do with sexual misconduct Which third parties A I dont recall sitting here today Involved how A If I recall with specificity if I had the articles in front of me I would be able to recall Maybe next time What does gin up these allegations mean A It means craft allegations of multi-million dollar cases in fact alleging in L.M case damages of 50-million settlements in order for Scott Rothstein and the rest of Mr Edwards partners to fleece unsuspecting investors out of millions and millions of dollars based on cases that didnt exist or alleged cases that I had settled Tr at Was your reference to quote gin up these allegations unquote a reference to allegations made against you A As part of the vast conspiracy of the Rothstein firm and Mr Edwards participation in it it has been alleged that many cases were fraudulently brought alleged that have been brought ginned up meaning crafted multi-million dollar numbers put on cases in order to fleece investors where his partner Scott Rothstein currently sits in jail for just those purposes Mr Scarola My question to you is Did the reference to quote gin up these allegations refer to allegations against you A Reported in the newspaper the answer is yes And others but specifically me yes by the newspaper reports Tr at What specific discovery proceedings did Mr Edwards engage in which you contend form the basis for your lawsuit A The discovery proceedings of bringing my attorneys to various people that had nothing to do with any of his clients or these lawsuits Which various people Who A For example he tried to depose Bill Clinton strictly as a means of getting publicity so that he and his firm could fraudulently steal craft money from unsuspecting investors in South Florida out of millions of dollars Tr at You said something about Mr Edwards sharing boxes of information with somebody A Yes as forming part of the basis for your lawsuit against Mr Edwards correct A Correct All right With whom did Mr Edwards share these boxes of information A It has been reported in the Scherer Complaint that he shared those boxes with the partners of his firm that was then formally accused by the U.S Attorney sir of being a criminal enterprise Do you remember my question A You asked me who he shared it with Yes A The partners of his firm sir Okay So part of the basis of your lawsuit is that Mr Edwards allowed members of his own law firm to see boxes of information is that correct A No thats not correct My claim is that the boxes of information that were shown to investors by Mr Edwards partners boxes that weve been told by the press contain multiple cases fraudulently and if you like the word fabricated in order to fleece investors out of money The boxes were shared with investors Mr Edwards Mr Edwards partners and some of those partners currently under indictment the others already sitting in jail Tr at Which newspaper said which case was fabricated A Bob Normans blog said most of the cases were fabricated to my best recollection The Scherer complaint alleged many fabricated cases sir Tr at Among the allegations of wrongdoing against Mr Edwards which you contend form the basis of this lawsuit is something having to do with sending an investigator to California Would you tell me please more specifically what it is that Mr Edwards did with regard to sending an investigator to California which you contend justifies a legal claim against Mr Edwards A Reported widely in the newspapers is the use of illegal activities wire taps and methods by the Rothstein firm while Mr Edwards had basically been bringing these cases The investigator Mr Fisten whos mentioned in the Complaint represented himself as an FBI agent falsely represented himself as an FBI agent Do you have any personal knowledge of anything that Mr Fisten did while Mr Fisten was in California A Im sorry Based on attorney/client privilege I cant answer Tr Is it your contention that Mr Edwards was involved in an illegal wire tap A It was widely reported in the newspaper Im not asking if it was reported A Excuse me in the newspaper A Excuse me I want to know whether your contention is that Mr Edwards was involved in an illegal wire tap A Its been widely reported in the newspaper that his firm and his partners were involved in illegal wire taps eavesdropping hired former FBI and law enforcement officials in order to fabricate cases of a sexually charged nature against me and others Do you have any personal knowledge of Mr Edwards ever having engaged in any illegal wire tap A I have no personal knowledge however what I read in the newspapers and is widely reported is that his firm and I believe Mr Sakowitz went to the FBI after he was told that the firm was engaged in illegal wire taps and his partners were engaged in illegal wire taps The FBI the U.S Attorney has accused his firm of RICO being the largest criminal fraud enterprise in South Floridas history and engaged in illegal wire taps But the answer specifically to your question about personal knowledge sir no Do you have any personal knowledge of Mr Edwards ever having been involved in any illegal or improper eavesdropping A Its been widely reported in the newspapers in South Florida that Mr Edwards firm his partners were involved in illegal wire taps illegal fact gathering using what the newspapers quoted as sophisticated methods Mr Sakowitz who was approached as an investor and Mr Scherer whos filed a Complaint alleges similar activities But personal knowledge myself sir no Do you have any personal knowledge that Bradley Edwards was ever involved obstructions of justice A Its attorney/client privilege Im afraid Do you have any personal knowledge that Bradley Edwards was ever involved in any actionable frauds A Outside of the newspapers which have accused his firm of a monstrous fraud purported to be the largest fraud in South Floridas history accused by the U.S Attorney where his partner sits in jail excuse me reported in the newspapers of boxes of material on Jeffrey Epstein separate and apart from the allegations of fraud by his partners I cannot answer that question because of attorney/client privilege Do you have any personal knowledge that Bradley Edwards ever forged Federal Court Orders and/or Opinions A Its attorney/client privilege Do you have any personal knowledge that Bradley Edwards was ever involved in the marketing of non-existent Epstein settlements A Im sorry I would like to answer that question but on attorney/client privilege I cannot today It is alleged in your Complaint that you were subject to quote abusive investigatory tactics Other than those matters previously referred to in earlier questions is it your contention that Bradley Edwards had any personal involvement in any other quote abusive investigatory tactics A Its been widely reported in the newspapers that Mr Edwards firm was engaged in widely wildly abusive practices throughout the State of Florida in order to fleece unsuspecting investors out of millions of dollars The U.S Attorneys Complaint alleges his firm engaged in a corrupt criminal enterprise Mr Scherers Complaint alleges monstrous amounts of fraud and discovery abuse I have no personal knowledge separate from the attorney/client privileged information regarding Mr Edwards Do you have any personal knowledge that Bradley Edwards ever filed legal papers that were unsupportable A Im afraid its attorney/client privilege Do you have any personal knowledge that Mr Edwards was ever involved in any conduct that quote compromised the core values of both State and Federal justice systems in South Florida A Can you just ask can you define for me what you mean by personal knowledge sir Yes Did you ever see hear smell taste or touch anything that communicated to you directly and not through the report of some third person or newspaper that Bradley Edwards was personally involved in compromising the core values of both State and Federal justice systems in South Florida Mr Pike Form Same instruction with regard to attorney/client A Yes Are you suggesting that anyone who told me specifically or things that I might have read that specifically relate to him is not what youve been asking me for Yes sir thats exactly right A You told me if I hear something thats not personal knowledge Not if you hear it from somebody else A Who else would I hear it from besides somebody else sir Well if you heard it directly yourself A From who Maybe Mr Edwards A Uh-huh Is that the only person sir Thats the only person thats correct A Well if its the only person separate from attorney/client privilege I cannot answer that Tr at Your Complaint makes reference to a purpose in filing this lawsuit A Yes to vindicate the hardworking and honest lawyers and their clients who were adversely affected by the misconduct that is the subject of this Complaint A Yes sir Who are those hardworking and honest lawyers on whose behalf you are bringing this Complaint A Yes The U.S Attorney sir has accused the Rothstein firm of misusing the entire legal system a level of abuse never seen before in the United States history of forging documents an affront to any decent lawyer signing Judges Orders sending false statements to other lawyers The people who have been excuse me the Complaint by the U.S Attorney in fact describes the behavior of the law firm as well as Mr my Complaint says Mr Edwards being a part of that Tr at I want to know who the quote hardworking and honest lawyers are that are referred to in that section of your Complaint A My attorneys at least are honest Which ones A All of them And you say that you want to vindicate the hardworking and honest lawyers and their clients A Thats correct Which clients A Me some of the other clients in fact abused by the Rothstein firm I dont know the full extent Hopefully when we get to trial were going to find out the extent of the people the lawyers the clients that were abused by Mr Edwards and the Rothstein firm We have asked for Scott Rothsteins deposition We hopefully will get it Maybe he will give us some insight on how other lawyers have in fact been handled and the abuses theyve undergone including forging a Federal Judges signature sir Tr at And did you mean to say what this sentence says the Rothstein racketeering enterprise endeavored to vindicate the hardworking and honest lawyers and their clients who were adversely affected by the misconduct that is the subject of this Complaint Mr Pike Okay Im going to move to strike Mischaracterizes the language of the document The document reads as follows for purposes of the record The Rothstein racketeering enterprise endeavored to compromise the core values of both State and Federal justice systems in South Florida and to vindicate the hardworking and honest lawyers and their clients who were adversely affected by the misconduct that is the subject of this Complaint Is that what you meant to say A What I meant to say it is seems to me somewhat unclear is that the Rothstein firm along with Mr Edwards is part of a criminal enterprise the largest excuse me the largest criminal enterprise in South Floridas history forging Judges signatures engaging in illegal wire taps illegal behaviors And part of this lawsuit should vindicate which means I believe should set right And if its not clear the Rothstein firm compromised the core values of our legal justice system It abused every many of the precepts the most basic values of the American justice system And in fact I believe this lawsuit part of the reason for filing this lawsuit it will disclose the various techniques of attorney/client privilege abuse of technique abuse of discovery illegal wire taps forging signatures engaged in by both Mr Edwards and his firm So it is your contention that Mr Edwards was part of a criminal enterprise A Yes it is Knowingly part of a criminal enterprise A Attorney/client privilege Tr at What knowledge do you have of Brad Edwards ever having personally engaged in mail fraud A Its been widely reported in the press Im going to withdraw my question What person knowledge do you have of Bradley Edwards ever having been engaged in any mail fraud A Will you describe what you mean by personal knowledge sir I mean direct observation through your senses on your part A So are you asking me whether or not Ive witnessed him sending something directly putting physically in the mail sir Im asking whether you have ever personally witnessed Bradley Edwards ever having engaged in mail fraud A Im not sure how thats possible for anybody to witness a mail fraud so would you inform me how its done So the answer to my question is you dont know is that correct A My answer to your question is Ive asked for a clarification Have you ever personally witnessed Bradley Edwards engaging in mail fraud A No sir Have you ever personally witnessed Bradley Edward Edwards engaged in wire fraud A How would one Im not sure how anyone would personal have personal knowledge witness someone engaging in wire fraud unless they were simply sitting over their computer looking at their bank accounts So unfortunately I would have to say no sir Have you ever personally witnessed Bradley Edwards engaged in money laundering A Again sir the U.S Attorneys Complaint of the Rothstein firm alleges money laundering wire fraud mail fraud RICO claims of Mr Edwards partners and his firm calling the firm the largest criminal enterprise in South Floridas history accused of fabricating malicious cases sir of a sexually charged nature in order to fleece unsuspecting South Floridians out of millions of dollars And Im trying to find out Mr Epstein whether you have any evidence whatsoever that Mr Edwards ever personally participated in any of that wrongdoing A Im afraid it will be attorney/client privilege sir Do you have any evidence knowledge of any evidence whatsoever that Mr Edwards ever participated in any effort to market any kind of investment in anything A I would have to claim attorney/client privilege on that sir Do you have knowledge of any evidence whatsoever that Mr Edwards was ever a participant in devising a plan through which were sold purported confidential assignments of a structured payout settlement A The newspapers and biogs have widely reported that Mr Edwards firm crafted would you repeat the question for me again sir Im sorry Yes sir I want to know whether you have any knowledge of evidence that Bradley Edwards personally ever participated in devising a plan through which were sold purported confidential assignments of a structured payout settlement A Id like to answer that question by saying that the newspapers have reported that his firm was engaged in fraudulent structured settlements in order to fleece unsuspecting Florida investors With respect to my personal knowledge Im unfortunately going to today but I look forward to at some point being able to disclose it today Im going to have to assert the attorney/client privilege Your Complaint alleges that Rothstein and others in RRA were using RRA to market investments Who are the others referred to in the Complaint A From my understanding of the U.S Attorneys Complaint from Mr Scherers Complaint it is the partners and people who held themselves out to be partners of the Roth Scott Rothstein including Mr Berger Mr Adler Mr Edwards and other people associated with the firm like Mr Fisten Diane Villegas if thats how you pronounce her name Russell Adler and many of the other partners of his firm currently under investigation by either the Florida Bar or the U.S Attorney or FBI or all of the above sir Which which source of information referenced in that answer specifically made reference to Mr Edwards A I dont recall sir But you do have a recollection that one or more of them did is that correct A I dont recall sir Tr at Did anyone ever sift through your garbage looking for damaging evidence A Its been widely reported in the newspapers sir that the Rothstein firm engaged in sifting through many peoples garbage in order in an attempt to blackmail them Tr at Yes Id like to know what the answer to that question is Did anyone ever sift through your garbage looking for damaging evidence A I dont know Tr at Do you have any information indicating that Bradley Edwards ever had any knowledge of anyone associated with the Rothstein firm holding meetings during which quote false statements were made about the number of cases/clients that existed or RRA had against Epstein and the value thereof unquote A My best recollection is the U.S Attorney has accused the Rothstein firm of just those types of meetings where the partners got together schemed to defraud local investors of millions of dollars by fabricating cases of a sexually charged nature And whether Mr Edwards personally participated Im going to at least today sir have to assert the attorney/client privilege but look forward to one day disclosing it Tr at Paragraph of your Complaint says that RRA Rothstein and Edwards claiming the need for anonymity with regard to existing or fabricated clients they were able to effectively use initials et cetera Do you have any knowledge that Bradley Edwards fabricated a client to bring a claim against you A I believe Mr Scherers Complaint Im not asking about Mr Scherers Complaint Im not asking about any evidence that you have A The pleadings of Mr Scherer and his claim against the Rothstein firm for a massive fraud as well as Mr Sakowitzs claims to at least in the described in the public press because he went to the FBI for fabricating cases that included initials With respect to anything specific with Mr Edwards Im going to have to claim the attorney/client privilege today Slf Do you have any do you have knowledge of the existence of any evidence that Bradley Edwards knew that Rothstein was utilizing RRA as a front for a Ponzi scheme A Thats attorney/client privilege Do you have any knowledge of any evidence that would indicate Bradley Edwards should have known that Rothstein was utilizing RRA as a front for a Ponzi scheme A And today Im going to have to assert the attorney/client privilege Separate from the communication Ive had with my attorneys I cant answer that question Tr at Do you have any evidence that Brad Edwards sold allowed to be sold and/or assisted with the sale of an interest in non-settled personal injury lawsuits A The newspapers have widely reported that the Rothstein firm engaged in illegal structured settlements of cases of a sexual nature including specifically me We have subpoenaed the documents from Mr Edwards and his firm and we have not been able to get them as of yet I am confident that once we do I will be able to answer your questions with more specificity As you sit here today do you have any evidence whatsoever to support an assertion that Bradley Edwards individually and personally sold allowed to be sold and/or assisted with the sale of an interest in non-settled personal injury lawsuits A You said allowed to be sold Im going to assert attorney/client privilege to the answer Im afraid but Id like to answer that question Do you have knowledge of any evidence indicating that Bradley Edwards ever reached agreements to share attorneys fees with non-lawyers A In fact Mr Scarola we have subpoenaed Mr Edwards documents and documents from his firm that I believe will in fact give me more specificity with the answers to that question Im looking forward to getting the that specific evidence With respect to what we currently know sitting here today Im unfortunately going to have to claim my attorney client privilege Do you today have any evidence to support an assertion that Bradley Edwards ever used investor money to pay L.M E.W and/or Jane Doe up-front money such that they would refuse to settle civil actions A Im going to have to assert the attorney/client privilege Im afraid though Id like to answer that question as well sir Do you have any evidence to support the assertion that Bradley Edwards conducted searches wire taps or intercepted conversations in violation of State or Federal laws and Bar rules A Your question once again asked did Mr was Mr Edwards personally involved in the eavesdropping Did he walk to someones house and sort of put a bug in their house Did he personally stand outside The question is did Mr Edwards firm engage in this behavior in an attempt to defraud local investors out of millions of dollars The U.S attorney has filed a Complaint saying that they did The Complaints filed by Scherer saying that his firm did The Scherer Complaint says my name and the boxes of files that weve subpoenaed used my name sir We have requested information but up until today have not received any To give you a more specific answer Im afraid I cannot Do you have knowledge of any evidence that Bradley Edwards ever conducted searches wire taps or intercepted conversations in violation of State or Federal laws and Bar rules A The newspapers and the U.S Attorneys Complaint widely reported that Mr Edwards firm and people hired by his firm investigators hired by his firm fraudulently representing themselves as FBI agents engaged in just those activities sir Do you have any knowledge of any evidence that Bradley Edwards was ever aware of any such activities A Im going to have to assert the attorney/client privilege to that sir Do you have any knowledge that Bradley Edwards ever participated in or was aware of actions that utilized the judicial process including but not limited to unreasonable and unnecessary discovery for the sole purpose of furthering a Ponzi scheme A The pleadings of Mr Scherer with respect to the largest Ponzi scheme in South Floridas history engaged in by Mr Edwards firm and Scott Rothstein who currently sits in jail probably for the rest of his life for engaging in not only illegal wire taps and eavesdropping but an abuse of the entire legal system I believe speaks for itself Unfortunately with respect to Mr Edwards today Im going to have to assert the attorney/client work privilege sir Is it your contention that Mr Scherers Complaint even contains the name Bradley Edwards A I dont recall sir Tr at What are the damages that you claim to have suffered as a consequence of any wrongdoing on the part of Bradley Edwards A The cost of ridiculous litigation of having my attorneys prepare responses to wildly irrelevant discovery in various locations at a minimum sir Which lawyers A Burman Critton Jack Goldberger and a bunch of the others sir Which ones Name them for me please A Specifically I have so many lawyers defending me here against Mr Edwards I cant sit here at the moment I cant recall it with specificity You dont remember any of your lawyers names A Uh I do Besides Mr besides the Burman Critton firm and Mr Goldberger A Are you asking me for the firm sir or are you asking me for the names I want as much information as you can give me about this element of damage which you claim and that is the cost of legal services that you claim to be damages in this case A Okay Mr Roy Black Okay Who else A Mr Marty Weinberger Mr Alan Dershowitz Mr Jay Lefkowitz The firm of Burman Critton Luttier Thats it for the moment How much have you paid the law firm of Burman Critton and Luttier which you claim is damages A Hundreds of thousands of dollars sir How much A I dont have that figure offhand Can you give us any better figure than hundreds of thousands of dollars A No not sitting here today Are you paying them on an hourly basis A Yes sir What is the hourly rate at which you are compensating members of the law firm A Theyre ordinary rates What are they A I dont know How much have you paid Mr Goldberger A Im not aware total amount sir What is the hourly rate at which youre paying Mr Goldberger A His normal hourly rate How much is that A I dont know How much have you paid Mr Black which you claim as damages in this case A Hundreds of thousands of dollars Are you paying him on an hourly basis A I believe so What is the hourly rate A Im not I do not know sir How much have you paid Marty Weinberger A I dont know the exact amount sir Whats your best estimate A More than a hundred thousand dollars Are you paying him on an hourly basis A I believe so Whats the hourly rate A I dont know sir How much have you paid Alan Dershowitz A Hundreds of thousands of dollars Are you paying him on an hourly basis A I believe so At what hourly rate A I dont know sir How much are you paying Jay how much have you paid Jay Lefkowitz A Im not sure sir Do you have any idea at all A More than a hundred thousand dollars Are you paying him on an hourly basis A Yes sir Whats the hourly rate A I dont know What is the form of payment to your lawyers How do you transfer money to them A I dont know sir Pardon me A I dont know Does someone do that on your behalf A I would guess so Who A I dont know Are there any other elements of damage apart from the money paid to lawyers A Yes sir What A The stress and emotional damage of imperiling my friendships and business relationships with no relevance whatsoever to these cases brought by a firm that whose partner sits in a Federal prison who engaged in discovery to harass my friends and social contacts with no consideration or relevance to this case whatsoever in an attempt to simply fleece partly fleece investors in South Florida out of millions of dollars sir What is the value of those losses A Im not sure yet sir Do you have any idea at all A Not sitting here today More or less than A I would guess its more than sir More or less than a hundred A I would guess its quite an amount of money Is it more or less than a hundred A Yes sir More or less than a thousand A I would say its more than More or less than a million A I dont know sir So somewhere between and a million A No sir Its not No sir Thats not what I said I said I did not know Maybe more than a million A Maybe More or less than a billion A I dont know Maybe more than a billion A Maybe more How are you going to go about finding out what the value of that loss is A I will respectfully decline to answer that On what basis A Attorney/client privilege Mr Pike And work product Any other elements of damage A Not there might be but sitting here today I cant think of them Do you have written contracts with any of your lawyers A I dont know Who does A I dont know Tr at Epsteins Deposition-January Epstein testified as follows Yes sir Is it your contention that Bradley Edwards abusively prosecuted the federal court action on behalf of LM A Yes sir How A Bradley Edwards filed a 234-count federal complaint in conjunction with his partner Scott Rothstein to enable his partners at RRA to defraud south Florida investors of millions of dollars His partner Scott Rothstein and his partner Mr Adler have excuse me Mr Rothstein has now in deposition admitted that they needed to file a complaint to show investors that there was real action in Mr Rothsteins words going on in federal court The investors had not been able to find a filed complaint and had complained to Mr Rothstein that there was no filed complaints two days excuse me before Mr Edwards filed the federal complaint for Were you ever served with that complaint A Not to the best of my recollection So one contention is that Mr Edwards abusively prosecuted a federal court action on behalf of LM with which you were never served correct A I had I was notified that the case was in fact filed But you were never served with the case correct A I was notified that the case was filed But you were never served with the case correct A Not to the best of my recollection Okay What damage did you incur as a consequence of the filing of a complaint with which you were never served A I incurred many legal much legal fees many legal fees in fact to try to figure out why what was going on and in fact getting prepared to defend the case though I had not yet been served Were the allegations in the federal complaint on behalf of LM any different than the allegations in the state court case on behalf of LM A I dont recall Tr at Epsteins Affidavit-June Epstein set forth the following good faith basis for commencing his action against Rothstein and Edwards I filed the Action against Rothstein and Edwards because based on the facts described below and in the Summary Judgment Motion I believed at the time of filing my original Complaint that these two individuals and other unknown partners of theirs at Rothstein Rosenfeldt Adler RRA engaged in serious misconduct involving a widely publicized illegal Ponzi scheme operated through their law firm the Ponzi Scheme that featured the very civil cases litigated against me by Edwards which were being used to defraud potential investors in the Ponzi Scheme In early November stories in the press on the news and on the internet were legion about the implosion of RRA the Ponzi Scheme perpetrated at that firm and the misuse in the Ponzi Scheme of certain civil cases then being litigated against me by RRA partner Edwards The cases Edwards was litigating against me which are described in the Summary Judgment Motion the Epstein Cases were being used to defraud investors out of millions of dollars and to fund the RRA Ponzi Scheme In November I also became aware of news stories that as a result of the Ponzi scheme at RRA the Florida Bar had commenced investigations into over one-half of the attorneys employed by RRA At or about the same time in November I also became aware that the law firm of Conrad Scherer filed a Complaint against Scott Rothstein and others Razorback Funding LLC et al Scott Rothstein et al Case No hereinafter referenced as the Razorback Complaint on behalf of some of the Ponzi Scheme investors Upon reviewing the Razorback Complaint I learned that the Razorback Complaint detailed the use of the Epstein Cases i.e the cases being litigated against me by Edwards to defraud investors in the Ponzi Scheme including but not limited to improper discovery practices and other methods to bolster the cases Prior to my filing the initial Complaint in the Action I also became aware that the Federal government filed an Information against Scott Rothstein which included allegations of RRA as an Enterprise in which Rothstein and his yet unidentified co-conspirators engaged in a racketeering conspiracy money laundering conspiracy mail and wire fraud conspiracy and wire fraud and specifically alleged that a potential investors were defrauded by Rothstein and other co-conspirators who falsely advised that confidential settlement agreements were available for purchase when the settlement agreements offered were fabricated the fabricated settlements agreements were allegedly available in amounts ranging from hundreds of thousands of dollars to millions of dollars and could be purchased at a discount and repaid to the investors at face value over time Rothstein and other co-conspirators utilized the offices of RRA and the offices of other co conspirators to convince potential investors of the legitimacy of the and success of the law firm which enhanced the credibility of the purported investment opportunity in these fictitious settlements Rothstein and other co-conspirators utilized funds obtained through the Ponzi Scheme to supplement and support the operation and activities of RRA to expand RRA by the hiring of additional attorneys and support staff to fund salaries and bonuses and to acquire larger and more elaborate office space and equipment in order to enrich the personal wealth of persons employed by and associated with the RRA Enterprise Prior to filing the initial Complaint in the Action consistent with the allegations made by the press in the Razorback Complaint and in the Rothstein Information it was clear that the activity in the Epstein Cases being litigated by Edwards intensified substantially during the short six months during which Edwards was a partner at RRA from April through the end of October Furthermore during that six month period questionable discovery like that detailed in the Razorback Complaint had taken place in the Epstein Cases being litigated against me by Edwards including Edwards noticing the depositions of famous dignitaries and celebrities such as Bill Clinton and David Copperfield However the plaintiffs in the Epstein Cases had made no allegations of improper conduct against them implicating any celebrities or dignitaries Equally consistent with the allegations in the press and in the Razorback Complaint that the Epstein Cases were being deliberately misused for purposes unrelated to the litigation in order to lure investors into the Ponzi Scheme is the fact that on July Edwards filed a two hundred thirty-four page one fifty-six count federal complaint against me on behalf of a plaintiff LM for whom Edwards was already prosecuting a case against me in state court involving the same matters alleged in the federal complaint The complaint was filed in federal court but was never served on me or prosecuted leading me to conclude that the only reason it was filed was to enhance the case files shown at the offices of RRA to potential investors in the Ponzi Scheme Also while a partner at RRA Edwards filed a motion in Federal court in which he requested that the court order me to post a fifteen million dollar bond in the Jane Doe case This case according to the Razorback Complaint was being touted at that same time to investors in the Ponzi Scheme In connection with that motion Edwards filed papers discussing my net worth and filed supplemental papers purporting to list in great detail my vehicles planes and other items of substantial value all at a time when according to the accounts in the press the Information and the Razorback Complaint the Ponzi Scheme was unraveling and the need for new investors in the Ponzi Scheme was becoming urgent The court rejected the Motion calling it devoid of evidence 15th Jud Cir Case No r,r I EDWARDS DEPOSITION TESTIMONY A Edwards Deposition-March Edwards testified as follows Did he ever call you to communicate with you call you either by phone video conference in any fashion to discuss any aspect of the cases that you had against Jeffrey Epstein A He 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 Tr at All right Do you remember a third occasion that he spoke to you regarding Epstein related occasion cases A Anything else that he ever spoke with me about related to Epstein related issues is attorney client and work-product privileged information that I am not going to divulge Tr at All right And when you got into the office Mr Rothstein was there A Yes Mr Adler A Yes There was someone on the telephone who you dont recall A Yes Okay Was there anyone else present A Not that I remember Okay Was were there any investigators was Mr Jenne or Mr Fisten present A No So it was you Rothstein Adler and someone on the phone thats it A From what I remember How long did the meeting last A I dont know how long the meeting lasted Five minutes or was it a substantially long meeting A Do you want how long I was in the meeting I can give you an answer How long the meeting lasted I have no idea How long did the meeting last while you were present A Less than five minutes Was the value of any of the three cases discussed at all A No Did Mr Rothstein did Mr Rothstein appear to be knowledgeable about your cases A No Mr Adler was Mr Adler someone that you had discussed the cases with on a somewhat regular basis not content Was Mr Adler someone that you had discussed these Epstein cases with prior to that meeting A Yes Edwards March Tr at What lawyers other than yourself were involved in the Epstein cases during the time you were associated with RRA A What do you mean by were involved I guess all What what lawyers actually worked on the file I know Mr Berger worked on the Epstein cases correct A In some limited capacity correct Okay Mr Adler I know attended Mr Epsteins deposition correct A Correct Edwards March Tr at Edwards Deposition-October Edwards testified as follows Okay At the meetings that you at the meetings that occurred with these various lawyers Berger Adler Stone Rob Busche were present and Epstein was discussed was the discovery that discovery and/or investigation regarding Mr Epstein ever discussed A I I would assume so Well I A In meetings that we were talking about was Epstein discussed Yeah I I I assume based upon the what we saw in the e-mails today that is exactly the purpose of the meeting correct A Exactly that was the purpose of the meeting Edwards Oct Tr at Edwards Deposition-November Edwards testified as follows So there is some truth that Rothstein is weaving in based on documents the flight log that was obtained by you as the lead trial lawyer in the pending lawsuits A There is some truth in the pending lawsuits No Im saying that what Rothstein was doing we all A He used actual evidence to support a fabricated story And the actual evidence that was referred to here are these flight logs that you as the lead lawyer obtained and brought back to the Rothstein firm right A I maintain the evidence for all of my cases at the Rothstein firm where I worked yes Thats all I was confirming A Does it appear that Rothstein gained access to it and used it to support his fairytale It does Edwards Nov Tr at Were you reporting to Mr Adler in how to represent the three Rothstein clients the three ladies on how to prosecute the Epstein matters A Well this email is dated April 8th so I had just started at the firm I had just got there Russ Adler was one of the only lawyers that I had known for years before I got to the firm And Russ Adler handled sexual abuse cases So especially in the beginning I talked to Russ about how to kind of navigate through the complications with Jeffrey Epstein and with the type of defense that was going on So this just appears that Wayne Black and Russ Adler Wayne was the investigator that they were talking also about how to what we needed to do in the investigation Yeah Russ was definitely involved then He didnt do much in the day-to-day so I dont want to say anything to that I understand But Im talking about on April 8th it looks to me like hes giving you instructions on what to do Do you agree A Not giving me instructions on what to do I mean hes telling me bring Marc Nurik the non-prosecution agreement is the instruction Edwards Nov Tr at Did you become aware of the fact that your Epstein-related files at some point in time had been requested by Scott Rothstein A Yes How did you become aware of that A I think Mike told me Fisten Was there any explanation offered as to why Scott Rothstein wanted to see the Epstein related files A That if these cases went to trial he wanted to try the cases with me He who A He Scott Rothstein wanted to try the case with me Thats the explanation that I was given Edwards Nov Tr at You were an employee in your mind and he was the lawyer ultimately at the firm responsible for the three clients true A Theres seventy lawyers at the firm They all work for him Hundreds of files Hes still the equity partner of the firm so they are the firms files They are not I understand You told me earlier And I didnt realize that that the interest that Bradley Edwards PA had in three files you gave up to Mr Rothstein and became a salary employee essentially A Gave up to RRA Mr Rothsteins firm correct A Right Weve established this And so that Mr Rothstein was the lawyer at that firm as the one of two equity shareholders who was ultimately responsible for the three Epstein matters A For every case in the entire firm including those Including the three Epstein matters A Every case yeah Edwards Nov Tr at IV ROTHSTEINS DEPOSITION TESTIMONY Rothstein testified as follows in this case You never spoke to Brad about this case A I didnt say that but I had a lot more interaction If you talk to the people in the firm if they are honest with you theyll tell you my interaction was far more significant with Russ Adler probably more so because he was a co-conspirator of mine My interaction with Russ was far greater by many many percents over my interaction with Brad and then you go down the line I had more interaction with Mr Farmer than I did with Mr Fistos more interaction with Jaffe than I did with Mr Edwards and so on Rothsteins June Tr at Right How did you know at the time when you said these investors wanted to investigate and you said you were going to create a fake settlement how did you know that this case was the case that you could use A From talking to all the people that I just said Adler Fistos Jaffe Farmer Mr Edwards to the extent that I spoke to him about it Did you speak with Mr Edwards about the case A I dont have a specific recollection one way or the other I remember speaking to him at least briefly the day or the day of or the day before the actual investors due diligence was going on as to what was going on And I may have spoke to him I know I spoke to Russ but I may have spoke to him as well within a couple of days just prior to this due diligence because I was trying to at least get some information in my head that I could use when I was creating this story for the investors Rothsteins June Tr at Well then explain to me You testified earlier that what was important to the investors to see is that there was a real case correct A Yes What did you look at or show them what did you look at first of all to see if it was in fact a real case A I knew it was a real case How did you know A Because my lawyers told me it was a real case I believed them What lawyers told you that A I already told you it was a mixture of Russ and Jaffe and Fistos and Farmer and Mr Edwards I mean I knew it was a real case We had all these boxes we had people really working on the file How do you know A or they were pulling a hell of a scam on me Not that I didnt deserve it but How did you know you just said you knew people were working really hard on this case Who do you know was working on the case A The only people that I knew for certain were working on the case was Brad Edwards and Russ Adler was doing his supervisory schtick whatever that was But other than that I dont know which other lawyers were assisting Mr Edwards I didnt get involved at that level Rothsteins June Tr at Rothstein testified as follows in Razorback Funding LLC Rothstein 17th Jud Cir Case No You pulled out some kind of a flight manifest do you recall that A Yeah At some point in time I believe it was either Brad Edwards or Russ Adler pointed out to me that one of the pieces of evidence they were using in the actual case was the flight manifest And I actually used that to make a fairly big show I found that those most of the time in these cases the more significant our underlying investigation was and the more tantalizing it was the more interested the investors got We had that real piece of evidence and we used it to our advantage to attempt to secure the investor Rothsteins Dec Tr at Didnt you add some sensational names to the manifest that werent there to start with A I did I did Tell us about that A There were I said that there were additional manifests if I remember correctly I said there were additional manifests that we had discovered containing Bill Clintons name Prince Andrew all being shown flying with young girls on the plane And do you know whether let me back up The original manifests that were in evidence in the real case didnt have those names on it A No but its interesting you bring that up because the way I came up with Bill Clinton and Prince Andrew was Mr Adler and Mr Edwards both told me on different occasions that the reason the case when we were discussing the actual real case the reason it was becoming so quote unquote tasty because they had information that he had been flying Bill Clinton around and Prince Andrews around the piece that was missing from the real case was the connection to the young girls The young girls connection to the young girls was fiction it was a lie A Not as far as Mr Epstein is concerned but as far as the other people are concerned yes Rothsteins Dec Tr at When you were asked this morning about Brad Edwards you really hesitated I dont know if you know you did that You were answering yes no maybe so On him you really paused A On the question as whether or not he would have turned us in you mean Whether he was a player or whether he was involved and you didnt quite answer A Just because of the way I knew Brad and socialized with him I did not know that he was at that level There are certain people Barry Stone second he found out about it would have absolutely done what was appropriately supposed to do from an ethical standpoint And then there were people who I say would never do that And then there are people in the middle I believe Brad Edwards is probably in the middle Rothsteins Dec Tr at Im trying to understand Im not going to have you go through all boxes but Im trying to get a frame of reference Youre talking about a flight manifest or flight manifests for private jets right A Yes This is a very small document It may have been one or two pages And I had it specifically set aside Id either ask Mr Adler or Mr Edwards to isolate the flight manifest Rothsteins Dec Tr at CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on November through the Courts e-filing portal pursuant to Florida Rule of Judicial Administration Jack Scarola LINK ROCKENBACH PA Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Angela Many FBN Primary Scott linkrocklaw.com Primary Kara linkrocklaw.com Primary Angela linkrocklaw.com Secondary Tina linkrocklaw.com Secondary Troy linkrocklaw.com Secondary Tanya linkrocklaw.com Secondary Eservice linkrocklaw.com Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Nichole Segal Searcy Denny Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard Burlington Rockenbach P.A Courthouse Commons Suite West Railroad A venue West Palm Beach FL mep searcylaw.com jsx searcylaw.com scarolateam searcylaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards West Palm Beach FL njs FLAppellateLaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Marc Nurik Edwards Pottinger LLC Law Offices of Marc Nurik Andrews Avenue Suite One Broward Boulevard Suite Fort Lauderdale FL Ft Lauderdale FL brad epllc.com marc nuriklaw.com staff.efile pathtojustice.com Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Jack A Goldberger Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL goldberger agwpa.com smahoney agwpa.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein A A 4A E0 A4 DE a qr?q rq qrCX HhL Kg lg d?a d6U a M3 flW y??S m/y t0 I F/Z V/j 1a qC KS u?v vZ O5 a qr rCX qC 0V I I dc rM?M rM 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