Filing E-Filed PM JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendants I IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO NOTICE OF FILING DEPOSITION TRANSCRIPT EXCERPTS AND DISCOVERY RESPONSES BY JEFFREY EPSTEIN IMPLICATING THE ATTORNEY-CLIENT PRIVILEGE Counter-Plaintiff Bradley Edwards by and through undersigned counsel hereby files this Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege and as grounds therefor states as follows Summary At the November pre-trial hearing the Court requested that Counter-Plaintiff Bradley Edwards specifically identify the discovery responses provided by Jeffrey Epstein implicating the Attorney-Client privilege This Notice of Filing outlines the specific questions and answers in Epsteins March deposition testimony in which Epstein raised the privilege as well as citations to Epsteins Answers to Interrogatories dated September and Amended Answers to Interrogatories dated August which Edwards proffers for introduction at trial and relies upon to preclude Epstein from offering testimony concerning matters as to which discovery was precluded through privilege assertions FILED PALM BEACH COUNTY FL SHARON BOCK CLERK PM Case No Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege Page of I MARCH DEPOSITION a Page Line through Page Line 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 MR PIKE Form And also mischaracterizes the witness testimony THE WITNESS 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 BY MR SCAROLA Do you have any personal knowledge of anything that Mr Fisten did while Mr Fisten was in California MR PIKE To the extent that you can answer that question without disclosing my conversation or my firms conversation or any of your attorneys conversations with you you can answer the question THE WITNESS Im sorry Based on attorney/client privilege I cant answer Case No Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege Page of Page Lines Do you have any personal knowledge that Bradley Edwards was ever involved in obstructions of justice MR PIKE To the extent that you can answer that question without disclosing any attorney/client communications with any of your attorneys you can answer that question THE WITNESS Its attorney/client privilege Im afraid Page lines Do you have any personal knowledge that Bradley Edwards ever forged Federal Court Orders and/or Opinions A Its attorney/client privilege Page lines through page lines Do you have any personal knowledge that Bradley Edwards was ever involved in the marketing of non-existing Epstein settlements MR PIKE Same instruction THE WITNESS Im sorry I would like to answer that question but on attorney/client privilege I cannot today Case No Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege Page of Page lines It is alleged in your Complaint that you were subject to quote abusive investigatory tactics Other than those matters previously referred to in earlier questions is it your contention that Bradley Edwards had any personal involvement in any other quote abusive investigatory tactics MR PIKE Form THE WITNESS 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 Page lines Do you have any personal knowledge that Bradley Edwards ever filed legal papers that were unsupportable MR PIKE Im going to object to form And to the extent you can answer that question without disclosing any attorney/client communications with any of your attorneys Im going to allow you to answer that question THE WITNESS Im afraid its attorney/client privilege Case No Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege Page of Page Line through Page Line So it is your contention that Mr Edwards was part of a criminal enterprise A Yes it is Knowingly part of a criminal enterprise MR PIKE Form THE WITNESS Attorney/client privilege Page Line through Page lines through Page Line Have you ever personally witnessed Bradley Edwards engaged in money laundering MR PIKE Form THE WITNESS 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 BY MR SCAROLA 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 MR PIKE To that question to the extent you can answer it without violating attorney/client and work product you can answer the question Case No Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege Page of THE WITNESS Im afraid it will be attorney/client privilege sir Page lines 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 MR PIKE Form Page Line through Page Line 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 MR PIKE Form THE WITNESS 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 Case No Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege Page of Page Lines Is it your contention that Bradley Edwards was ever personally involved in manufacturing false and/or fraudulent Court Opinions or Orders A Attorney/client privilege Page Line through Page Line 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 MR PIKE Form Same objection THE WITNESS My best recollection is the U.S Attorney has accused the Rothstein firm of just those types of meetings where the partners got together schemed to defraud local investors of millions of dollars by fabricating cases of a sexually charged nature And whether Mr Edwards personally participated Im going to at least today sir have to assert the attorney/client privilege but look forward to one day disclosing it MR SCAROLA Move to strike all unresponsive portions of the answer Page Line through Page lines Page Line Do you have any knowledge that Bradley Edwards Case No Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege Page of fabricated a client to bring a claim against you MR PIKE Form THE WITNESS I believe Mr Scherers Complaint BY MR SCAROLA Im not asking about Mr Scherers Complaint Im asking about any evidence that you have MR PIKE The witness is basically been five words into his sentence and youre not allowing him to finish once again So if you recall the question then please respond THE WITNESS Please repeat it back please MR PIKE Madame Court Reporter if you would Pending question was read MR PIKE Form THE WITNESS 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 sir Page lines Do you have any do you have knowledge of Case No Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege Page of the existence of any evidence that Bradley Edwards knew that Rothstein was utilizing RRA as a front for a Ponzi scheme MR PIKE Form THE WITNESS Thats attorney/client privilege Page lines Do you have knowledge of any evidence that would indicate Bradley Edwards should have known that Rothstein was utilizing RRA as a front for a Ponzi scheme MR PIKE Form THE WITNESS At least today MR PIKE Wait THE WITNESS Sorry MR PIKE Form Same objections Same attorney/client work product as to the last question Same objections here attorney/client work product THE WITNESS And today Im going to have to assert the attorney/client privilege Page Line through page line As you sit here today do you have any evidence whatsoever to support an assertion that Bradley Edwards individually and personally sold allowed to Case No Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege Page of be sold and/or assisted with the sale of an interest in non-settled personal injury lawsuits MR PIKE Before you answer that question Madame Court Reporter will you please read that question back to me Pending question was read MR PIKE To the extent you can answer that question without divulging attorney/client or work product information you may answer that question MR SCAROLA Objection Coaching THE WITNESS 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 Page line through Page line Do you have knowledge of any evidence indicating that Bradley Edwards ever reached agreements to share attorneys fees with non-lawyers MR PIKE Im sorry Mr Scarola can you tell me what page of the Complaint youre referring to if you are MR SCAROLA Im not referring to any page of the Complaint although I will tell you that that precise allegation is made in the Complaint THE WITNESS 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 Case No Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege Page of specific evidence With respect to what we currently know sitting here today Im unfortunately going to have to claim my attorney I client privilege Page line through Page Line 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 MR PIKE Same instruction THE WITNESS Youll have to get I need to hear the first part of the question Do I have any evidence Do I have knowledge of evidence Im sorry What was the BY MR SCAROLA Do you have knowledge of any evidence to support that assertion MR PIKE To the extent you can answer that question without violating attorney/client work product please do so MR SCAROLA Objection Coaching THE WITNESS Im going to have to assert the attorney/client privilege Im afraid though Id like to answer that question as well sir Page Lines Do you have knowledge of any evidence that Bradley Edwards ever conducted searches wire taps or Case No Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege Page of intercepted conversations in violation of State or Federal laws and Bar rules MR PIKE Same instruction THE WITNESS 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 BY MR SCAROLA Do you have any knowledge of any evidence that Bradley Edwards was ever aware of any such activities A Im going to have to MR PIKE Same objection THE WITNESS assert the attorney/client privilege to that sir Page line through Page Line 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 MR PIKE Same objection To the extent you can answer the question without disclosing attorney/client or work product information do so THE WITNESS The pleadings of Mr Scherer with respect to the largest Ponzi scheme in South Case No Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege Page of 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 Page Line What day are you prepared to answer all these questions MR PIKE Form Attorney/client and work product THE WITNESS Thats attorney I wish I could answer that question as well but its attorney/client privilege sir Page Line through Page Line How are you going to go about finding out what the value of that loss is MR PIKE Attorney/client work product To the extent you can answer without disclosing our conversations or the conversations with your other attorneys that youve delineated you can do so BY MR SCAROLA Or you can just take the signal and say I refuse to answer because its attorney/client privilege Case No Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege Page of A I resent that MR PIKE Move to strike THE WITNESS But its okay You can continue to try to harass me sir It doesnt work The ladies and gentlemen of the jury hopefully when they see the deposition will recognize and see these pile of tricks The answer MR SCAROLA Hopefully they will THE WITNESS Yes MR PIKE Move to strike THE WITNESS I will respectfully decline to answer that BY MR SCAROLA On what basis A Attorney/client privilege MR PIKE And work product Page Lines through THE WITNESS As proportionate to the amount of damages I think Mr Edwards played a vital role I believe his partners potentially played a role Ive only had any contact with Mr Edwards Slf BY MR SCAROLA Which partners A Beg your pardon Case No Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege Page of Which partners besides Mr Edwards and Mr Rothstein do you claim engaged in conduct that renders them liable to you A I believe its in the Complaint sir And I believe its Mr Adler Mr Berger Theres Mr Jenne Mr Fisten but those are not partners So Mr Berger Mr Adler and I forgot the names of the others at the moment sir but its in the Complaint Why didnt you sue them MR PIKE Form THE WITNESS Attorney/client privilege sir MR PIKE Work product II EPSTEINS OBJECTIONS TO EDWARDS GENERAL INTERROGATORIES DATED SEPTEMBER Describe in detail all information written or oral which William Scherer or any attorney or agent of the law firm of Conrad Scherer has provided to you or your attorneys which relates to any allegation which has been asserted in this case against Bradley Edwards ANSWER With regard to Interrogatory number the Plaintiff/Counter-Defendant objects on the grounds that the information is protected by work product and attorney-client privilege at this time Case No Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege Page of I EPSTEINS AMENDED RESPONSES TO INTERROGATORIES DATED AUGUST A With regard to all communications that occurred at any time prior to the filing of your civil lawsuit against Bradley Edwards in which communication you expressed the position that Bradley Edwards was a knowing participant in the efforts of Scott Rothstein to defraud investors the Scott Rothstein Ponzi scheme or that Bradley Edwards engaged in any misconduct relating to the Scott Rothstein Ponzi scheme state the following a detailed description of the contents of the communication all participants in and parties to the communication the date time place and circumstances of the communication including how the communication was made whether when how and why the contents of the communication were ever subsequently related to any other person whether and how the contents of the communication were ever memorialized in any manner and if so the identity of everyone having custody of such memorialization ANSWER No such non-privileged communication occurred In other worst I never had a conversation as delineated above with anyone other than my counsel which would require the disclosures of information that is protected by the attorney/client privilege United Services Auto Assn Roth So 2d Fla th DCA Nevin Palm Beach County School Bd So 2d Fla st DCA Accordingly I assert the attorney/client privilege as provided for in of the Florida Statutes With regard to any request direction or authorization to sue Bradley Edwards communicated by you at any time prior to the filing of your civil lawsuit against Bradley Edwards state the following a detailed description of the contents of the communication all participants in and parties to the communication the date time place and circumstances of the communication including how the communication was made whether when how and why the contents of the communication were ever subsequently related to any other person whether and how the contents of the communication were ever memorialized in any manner and if so the identity of everyone having custody of such memorialization Case No Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege Page of ANSWER No such non-privileged communication occurred In other worst I never had a conversation as delineated above with anyone other than my counsel which would require the disclosures of information that is protected by the attorney/client privilege United Services Auto Assn Roth So 2d Fla th DCA Nevin Palm Beach County School Bd So 2d Fla st DCA Accordingly I assert the attorney/client privilege as provided for in of the Florida Statutes I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list this 4th day of December Isl Tock Scarola JACK SCAROLA Florida Bar No DAVID VITALE JR Florida Bar No Attorney E-Mails jsx searcylaw.com and mmccann searcylaw.com Primary E-Mail ScarolaTeam searcylaw.com Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorney for Bradley Edwards Case No Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege Page of Bradley Edwards Esquire staff.efile pathtojustice.com Andrews Avenue Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein COUNSEL LIST Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian Avenue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Nichole Segal Esquire njs FLAppellateLaw.com kbt FLAppellateLaw.com Burlington Rockenbach P.A Railroad Avenue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Scott Link Esquire Eservice linkrocklaw.com Scott linkrocklaw.com Kara linkrocklaw.com Angela linkrocklaw.com Tanya linkrocklaw.com tina linkrocklaw.com Link Rockenbach P.A Palm Beach Lakes Boulevard Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com Case No Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege Page of One Broward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein 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 10Cy n??m?n k?o?h I A I w?!ac qr MCX 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