Filing E-Filed PM JEFFREY EPSTEIN Plaintiff vs IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendants I COUNTER-PLAINTIFF BRADLEY EDWARDS APPENDIX OF DOCUMENTS IN SUPPORT OF HIS 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 Appendix of Documents in Support of His Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege No Date Document March Deposition Transcript Jeffrey Epstein September Defendant Bradley Edwards Interrogatories to Plaintiff Jeffrey Epstein October Plaintiff/Counter-Defendant Jeffrey Epsteins Objections to Defendant/Counter-Plaintiff Bradley Edwards General Interrogatories dated September August Notice of Service oflnterrogatorv to Jeffrey Epstein November Plaintiff/Counter-Defendant Epsteins Amended Responses to Interrogatories FILED PALM BEACH COUNTY FL SHARON BOCK CLERK PM Case No Counter-Plaintiff Bradley Edwards Appendix of Documents in Support of His Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege Page of4 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 Tack 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 Counter-Plaintiff Bradley Edwards Appendix of Documents in Support of His Notice of Filing Deposition Transcript Excerpts and Discovery Responses by Jeffrey Epstein Implicating the Attorney-Client Privilege Page of4 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 Counter-Plaintiff Bradley Edwards Appendix of Documents in Support of His 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 Page IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendants VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN Wednesday March Banyan Boulevard Suite West Palm Beach Florida Reported By Sandra Townsend FPR Notary Public State of Florida West Palm Beach Office Job Page APPEARANCES On behalf of the Plaintiff MICHAEL PIKE ESQUIRE BURMAN CRITTON LUTTIER COLEMAN LLP Banyan Boulevard Suite West Palm Beach Florida Phone On behalf of the Defendant Bradley Edwards JACK SCAROLA ESQUIRE SEARCY DENNEY SCAROLA BARNHART SHIPLEY Palm Beach Lakes Boulevard West Palm Beach Florida Phone On behalf of the Defendant L.M BRADLEY EDWARDS ESQUIRE FARMER JAFFE WEISSING EDWARDS FISTOS LEHRMAN P.L North Andrews Avenue Suite Fort Lauderdale Florida Phone Also Present STEVEN JAFFE ESQUIRE FARMER JAFFE WEISSING EDWARDS FISTOS LEHRMAN P.L North Andrews Avenue Suite Fort Lauderdale Florida Phone EXHIBITS NUMBER DESCRIPTION Exhibit number Eyeglasses PROCEEDINGS Page PAGE Page Deposition taken before Sandra Townsend Court Reporter and Notary Public in and for the State of Florida at Large in the above cause VIDEOGRAPHER We are now on video record This is media number one in the videotaped deposition of Jeffrey Epstein in the matter of Jeffrey Epstein versus Scott Rothstein Bradley Edwards and L.M Today is Wednesday March at a.m We are at the law offices of Burman Critton Banyan of Burman Critton on Banyan Boulevard Suite West Palm Beach Florida My name is Joe Kozak Im the videographer The court reporter is Sandra Townsend from Prose Court Reporting Agency Would Counsel please introduce yourselves and then the court reporter will swear in the witness MR SCAROLA My name is Jack Scarola I am Counsel on behalf of Brad Edwards in his capacity both as Defendant and Counter-Plaintiff in this action Mr Edwards is present with me PROSE COURT REPORTING AGENCY INC Pages to Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page MR PIKE Michael Pike on behalf of the Plaintiff Jeffrey Epstein MR EDWARDS Brad Edwards on behalfofthe Defendant L.M Also present Steve Jaffe on behalf of the Defendant L.M as well THEREUPON JEFFREY EPSTEIN having been first duly sworn or affirmed was examined and testified as follows THE WITNESS Yes I do Thank you MR PIKE Before we get started Jack I just wanted to get on the record I just want to make sure that you received this letter that I sent to your office yesterday of March MR SCAROLA I did receive the letter MR PIKE Okay And were still on for Mr Edwards deposition as we sit here today MR SCAROLA Thats correct MR PIKE Okay Thank you DIRECT EXAMINATION BY MR SCAROLA Please state your full name and your current residence address A My name is Jeffrey Epstein Im currently Page residing at El Brillo in Palm Beach How long have you resided at that location Mr Epstein A Im sorry On advice of Counsel today Im going to take the Fifth Sixth and 14th Amendment with respect to that question Mr Scarola Have you maintained any other residences over the course of the last five years A Though Id like to answer each and every one of your questions here today with respect to that question Im going to have to assert my Constitutional Rights as provided by the Sixth 14th and Sixth Fifth sorry Fifth Sixth and 14th Amendment Does anyone reside with you at the El Brillo address A Again Mr Scarola though Id like to answer each and every one of your questions here today at least with respect to that question Im going to have to assert my rights as under the Sixth Fifth and 14th Amendment And Ive been advised by Counsel though Id like to answer these questions if I do so I risk losing their representation What did your lawyer tell you in that regard MR PIKE Im going to instruct you not to Page answer that question Attorney/client BY MR SCAROLA Well didnt you just tell me that your lawyer advised you that if you answered questions he wouldnt represent you anymore MR PIKE Thats exactly what he said Mr Scarola and Im instructing him not to answer the question BY MR SCAROLA Okay So I want to know then I want to know what your lawyer told you about that MR PIKE Im going to instruct you not to answer that question Attorney/client MR SCAROLA And it is our contention obviously that by making the statement that he has made Mr Epstein has waived any attorney/client privilege with regard to that matter MR PIKE Your contention definitely not mine BY MR SCAROLA Mr Epstein who else has shared that residence with you at any time over the course of the last five years A Again Mr Scarola Id like to answer that question as Id like to answer each and every one of Page your questions here today However on advice of Counsel Im going to have to assert my Fifth Sixth and 14th Amendment Right Are you a Plaintiff in a lawsuit against Scott Rothstein Bradley Edwards and an individual identified by the initials L.M A Yes sir I am Who is the individual identified as L.M A I believe from depositions that Ive read her full name is L.M When and under what circumstances did you first meet the individual referenced by the initials L.M A Mr Scarola I think you are aware these questions are simply designed to have me invoke my Fifth Amendment Sixth Amendment and 14th Amendment Right in relation to other questions and other cases filed But in response to your question Im going to have to invoke my right not to testify Do you know the individual named L.M identified by the initials L.M A Mr Scarola at least today I would like to answer that question however today on advice of Counsel Im going to have to refuse to answer that question PROSE COURT REPORTING AGENCY INC Pages to Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page Have you ever acknowledged in the presence of any other person knowing the individual identified by the initials L.M MR PIKE Form THE WITNESS Again Sorry Can you repeat the question sir BY MR SCAROLA Yes sir Have you ever acknowledged in the presence of any other person knowing the individual identified by the initials L.M MR PIKE Form Also could invade attorney/client THE WITNESS Again I would like to answer that question but today Im going to have to invoke my Fifth Amendment Sixth Amendment and 14th Amendment Right BY MR SCAROLA Have you ever acknowledged in the presence of any person other than your own lawyer having known the individual identified by the initials L.M MR PIKE Form THE WI1NESS Again Id like to answer each and every one of your questions here today Mr Scarola however on advice of Counsel at least today Im going to have to refuse to answer Page that question BY MR SCAROLA Have you ever acknowledged to A Excuse me Bradley A Sir may I suggest that ifl say I refuse to answer that it means the Fifth Sixth and 14th or would you prefer that I recite it each time I would prefer that you answer the questions thats my preference But if youre going to assert a privilege I will assume that if you simply say that you are refusing to answer your refusal to answer will be on the basis of various Constitutional privileges against self-incrimination without the necessity of specifying If your refusal to answer is on the basis of any other privilege it will be necessary for you to identify that privilege A Thank you MR PIKE And Im going to instruct you too when you do invoke invoke the Fifth Sixth and the 14th THE WITNESS Yes BY MR SCAROLA Have you ever acknowledged in the presence of Page Bradley Edwards that you knew the individual identified by the initials L.M A Im going to have to refuse to answer that question Have you ever acknowledged in the presence of Bradley Edwards that you knew L.M MR PIKE Again for purposes of the record Im instructing you to invoke the Fifth Sixth and 14th rather than just simply say THE WITNESS Okay MR PIKE I refuse to answer I want it to be clear for the Court that you have invoked your Fifth Sixth and 14th THE WITNESS Fine Then on advice of Counsel Im going to have to invoke my Fifth Sixth and 14th Amendment Right BY MR SCAROLA Have you ever acknowledged in Brad Edwards presence that you liked the individual identified by the initials L.M A Again Im going to have to invoke my Fifth Sixth and 14th Amendment Right Mr Scarola Have you ever acknowledged in Bradley Edwards presence that you liked L.M A Again Mr Scarola Im going to have to Page invoke my Fifth Sixth and 14th Amendment Right Have you ever acknowledged in the presence of Terri Becker a court reporter present at a deposition taken by Brad Edwards in a in a case in which the individual identified by the initials L.M was a Plaintiff that you knew and/or liked MR PIKE Form THE WITNESS Again BY MR SCAROLA L.M MR PIKE Same objection THE WITNESS Again Im going to have to assert my Fifth Sixth and 14th Amendment Right BY MR SCAROLA Have you ever acknowledged in the presence of Steve Jaffe that you knew and or liked L.M A Again Mr Scarola though Id like to answer each and every one of your questions today Im going to have to at the advice of Counsel invoke my Fifth Sixth and 14th Amendment Right Why are you suing L.M MR PIKE Form MR SCAROLA Let me state for the record that I dont consider a form objection to be a proper objection unless you specify the defect in the PROSE COURT REPORTING AGENCY INC Pages to Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page form and provide me with an opportunity to correct the defect MR PIKE Thats fine I believe the rules provide otherwise But nonetheless I stand on my objection to form THE WITNESS Im sorry You have to repeat the question BY MR SCAROLA Why are you suing L.M MR PIKE Form THE WITNESS 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 BY MR SCAROLA What role do you contend L.M played in that conspiracy to create fraudulent cases A L.M.s testimony before she met Mr Edwards Page 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 Is it your contention that L.M.s statement to the FBI was true MR PIKE Form THE WITNESS Mr Scarola unfortunately today with respect to that question Im going to have to assert my Fifth Sixth and 14th Amendment Right Though I know I believe you know the answer to that question I cant answer the question under advice of Counsel And hes told me ifl chose to do so I risk losing his representation BYMR SCAROLA What is the basis of your belief that I know the answer to the question MR PIKE Form THE WITNESS You I believe you have seen this because youre supposed to be a decent Page lawyer youve read the testimony I would guess youve read the difference in her testimony to the FBI versus her testimony after shes met your client and his partners who are currently in jail BY MR SCAROLA How does that respond to my question as to whether you contend that her testimony to the FBI was true or false MR PIKE Form THE WITNESS I dont believe that was your question Will you repeat BY MR SCAROLA Okay Well lets let me rephrase the question then Is it your contention that L.M.s statement to the FBI was true A Sir on advice of Counsel at least today Im going to have to assert my Fifth Sixth and 14th Amendment Right Was L.M.s statement to the FBI false in any respect A Sir at least again today on advice of Counsel Im going to have to assert my Fifth Sixth and 14th Amendment Right Was L.M.s subsequent testimony after Page according to you she met Mr Edwards and changed her testimony true A Did she change her testimony Is that yes her testimony was changed My question to you is Was her testimony which you contend was changed true testimony A Your question is not a good question Is it her testimony before or after Was the subsequent testimony given by L.M after she met Mr Edwards which you contend was different from her testimony before the FBI was the subsequent testimony true or false MR PIKE Form THE WITNESS Sir Im going at least today Im going to have to assert my Fifth Sixth and 14th Amendment Right BY MR SCAROLA Did you ever engage in any sexual conduct with L.M A I would like to answer that question but You dont need to tell me what youd like to do Mr Epstein You just need to do it please THE WITNESS Please MR PIKE Mr Scarola please let the witness finish his response Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page MR SCAROLA Thats not a response to my question MR PIKE In your mind it may not be a response In a Judges mind it may be We may have to certify it to the Court If such a procedure even exists we can take it up with the Court But please let the witness finish his response THE WITNESS Again please BY MR SCAROLA Did you engage ever engage in any sexual conduct with L.M A I would like to answer that question however today Im going to have to assert my rights as provided by the Fifth Sixth and 14th Amendment to that question sir Have you ever exchanged anything of value with L.M MR PIKE Form THE WITNESS At least today Im going to have to assert my Fifth Sixth and 14th Amendment Right sir BY MR SCAROLA Did you ever direct anyone to deliver anything of value to L.M Page MR PIKE Form THE WITNESS At least today Im going to have to refuse to answer that question based on the Fifth Sixth and 14th Amendment BY MR SCAROLA Do you know Carolyn Andriano A At least today sir Im going to have to refuse to testify about that question Based on advice of Counsel Im going to have to assert my Fifth Sixth and 14th Amendment Right Did Carolyn Andriano introduce you to L.M A Sir respectfully Id like to answer that question today As I said Id like to answer each and every one of your questions However on advice ofmy Counsel today Im going to have to assert my Fifth Sixth and 14th Amendment Right Did L.M suffer any damage as a consequence of any interaction between you and L.M MR PIKE Form THE WITNESS Could you repeat the question please BY MR SCAROLA Did L.M suffer any damage as a consequence of any interaction between you and L.M MR PIKE Form Page THE WITNESS Id like to answer each and every one of your questions here today Mr Scarola however on advice of Counsel today Im going to have to assert my Fifth Sixth and 14th Amendment Right BY MR SCAROLA 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 It means what it says I dont understand it Explain it to me MR PIKE To the extent you can answer that question without disclosing my conversations with you or Mr Crittons conversations with you as well as my work product you can answer the question THE WITNESS 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 Page which is outrageous BY MR SCAROLA How much have you settled claims for MR PIKE Im going to instruct you not to answer that question MR SCAROLA And the basis of that instruction is MR PIKE Confidential settlement agreements to the extent that they exist And the terms would be confidential BY MR SCAROLA Have you settled claims A Yes I have What is the nature of the claims you settled MR PIKE Im going to instruct you not to answer that question BY MR SCAROLA How many claims have you settled MR PIKE Im going to instruct you not to answer that question as well MR SCAROLA What is the basis for those instructions MR PIKE Confidential as well as there is a Victims Right Statute that may you may be tiptoeing into the identity of Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page MR SCAROLA Im not tiptoeing anywhere MR PIKE Let me finish my objection Mr Scarola You may be tiptoeing into the identity of various alleged victims underneath the Victims Right Statute as well as ongoing investigations or past investigations that have remained open with the State as well as the Federal Government So in that regard we would have to put the State Attorney as well as the Federal Government on notice that you were seeking to potentially back door certain identities at this deposition BY MR SCAROLA Other than having allegedly given different testimony before she met Mr Edwards then given after she met Mr Edwards did L.M do anything else that forms the basis for your claim against her MR PIKE Form Asked and answered THE WITNESS Id like to answer that question as well as every one of your questions with respect to L.M here today however on advice of Counsel at least today Mr Scarola Im going to have to assert my Sixth Amendment Fifth Amendment and 14th Amendment Right BY MR SCAROLA Page Did L.M fail to do anything that she had an obligation duty or responsibility to do MR PIKE Form BY MR SCAROLA that forms the basis for your claim against her MR PIKE I apologize Form THE WITNESS Again Im sorry Has she failed to do Can you repeat BY MR SCAROLA Yes sir Lawsuits are generally based civil lawsuits are generally based on a claim that someone has done something that they shouldnt have done or failed to do something that they should have done I asked you whether L.M did anything that she shouldnt have done and you asserted a Fifth Amendment privilege in refusing to answer that question Im now attempting to fmd out whether L.M failed to do something that she should have done that forms the basis of your claims against her Did L.M do anything that she should have done that forms the basis of your claims against her MR PIKE Form THE WITNESS On advice of Counsel at least today Mr Scarola Im going to have to refuse to Page answer that question based on my Fifth Amendment Sixth Amendment and 14th Amendment Right BY MR SCAROLA Did Brad Edwards do anything that he shouldnt have done that forms the basis of your lawsuit against him MR PIKE Form THE WITNESS Yes many things BY MR SCAROLA 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 I want to know what Mr Edwards MR PIKE One second THE WITNESS Excuse me Im answering BY MR SCAROLA I want to know what Mr Edwards did Im not asking you about allegations concerning his law firm Page MR PIKE Mr Scarola thats the second time that Im going to ask you not to interrupt the witness when hes giving a response He is giving a response When he finishes his response you can go on with your next question or you can you can elicit any sort of information you intend to elicit from the witness MR SCAROLA Hes being unresponsive MR PIKE No thats your contention MR SCAROLA No thats a fact MR PIKE And you can take it up with a Judge And ifwe want to continue going back and forth and bantering not allowing the witness to answer the question were here for you today for you to ask the questions and for you to get answers But if you continue to banter with the witness and interrupt the witness I will adjourn the deposition This is not proper and we certainly can take it up with the Judge So thats the second warning Mr Scarola Please MR SCAROLA How many do I get MR PIKE Im not sure yet today MR SCAROLA Okay MR PIKE Okay MR SCAROLA Good Then lets move on Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page MR PIKE But I can tell you one thing On a professional nature just because you are interrupting the witness and bantering with me I will adjourn the deposition BY MR SCAROLA 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 Page Anything else MR PIKE Form THE WITNESS Not I can think of at the moment BY MR SCAROLA 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 Does that have something to do with going to the media MR PIKE Form THE WITNESS Ive answered your question BY MR SCAROLA Does the investigator going to California to do something have something to do with the media A I believe Ive also told that you that hes gone to the Daily News sir is that correct MR PIKE Form Mischaracterizes the Page witness testimony as well BY MR SCAROLA Do you understand the question that youre supposed to be answering MR PIKE Well lets go ahead and repeat it MR SCAROLA No lets get an lets get an answer to that question BY MR SCAROLA Do you understand the question youre supposed to be answering A When MR PIKE Im confused Wait one second THE WITNESS Sorry MR PIKE Im confused as to what question is on the table MR SCAROLA And when your deposition is being taken your confusion is relevant and material MR PIKE Right And its MR SCAROLA When Mr Edwards excuse me when Mr Epsteins deposition is being taken Im concerned with whether he understands the question being asked MR PIKE Right So BY MR SCAROLA Page Do you understand the question youre supposed to be answering Mr Epstein MR PIKE And Im going to instruct you not to answer that question right now because as your Counsel I cannot let you answer that question until I understand what question is on the table Theres been a lot of bantering back and forth so Mr Scarola if you would respectfully repeat the question and then you may be able to ask him whether or not he understands the question But I cannot allow him to answer a question that I dont understand is on the table BY MR SCAROLA 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 MR PIKE Please answer the question THE WITNESS Good 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 Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page 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 BY MR SCAROLA 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 MR PIKE To the extent you can answer that question without violating any attorney/client privileges you can answer the questions THE WITNESS Its attorney/client BY MR SCAROLA 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 Page 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 MR PIKE Form THE WITNESS 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 BY MR SCAROLA 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 Page 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 whose 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 MR PIKE Form Objection Overbroad THE WITNESS Again sir BY MR SCAROLA Yes sir Where did these conversations with these five to ten people take place whose identity you cant remember MR PIKE Form THE WITNESS On the telephone BY MR SCAROLA 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 Page themselves or were these anonymous callers MR PIKE Form THE WITNESS Sitting here today Mr Scarola I dont recall with specificity BY MR SCAROLA What specifically did Mr Edwards allegedly communicate to the Daily News to quote gin up these allegations unquote A The newspapers have quoted Mr Edwards not quoted Mr newspapers have made allegations referred to as Mr Edwards statements MR SCAROLA Would you read the question back please Sandy Pending question was read MR PIKE Did he answer your question MR SCAROLA No MR PIKE Are you asking him again THE WITNESS So youre asking the question again BY MR SCAROLA Yes THE WITNESS Sorry Could you repeat the question again Pending question was read THE WITNESS He alleged that third parties Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page had already been involved in some allegations to do with sexual misconduct BY MR SCAROLA Which third parties A I dont recall sitting here today Involvedhow MR PIKE Form THE WITNESS IfI recall with specificity if I had the articles in front ofme I would be able to recall Maybe next time BY MR SCAROLA What does gin up these allegations mean MR PIKE Form THE WITNESS It means craft allegations of multi-million dollar cases in fact alleging in L.M.s 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 Can I take a break VIDEOGRAPHER Going off video record Briefrecess VIDEOGRAPHER Were now on video record at Page a.m BY MR SCAROLA Was your reference to quote gin up these allegations unquote a reference to allegations made against you MR PIKE Form THE WITNESS 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 BY 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 Specifically what are the allegations against you which you contend Mr Edwards ginned up A I would like to answer that question A many Page of the files and documents that weve requested from Mr Edwards and the Rothstein firm are still unavailable With respect to anything that I can point to today Im unfortunately going to have to take the Fifth Amendment on that Sixth and 14th You seemed to be defining ginned up as crafted is that correct A Thats correct Does ginned up or crafted mean fabricated MR PIKE Form THE WITNESS Im sorry Mr Scarola I understand that you are trying to back door your way into a waiver of my Fifth Amendment But respect to that question Im going to have assert my Fifth Amendment Sixth Amendment and 14th Amendment Right BY MR SCAROLA So you are asserting your Fifth Amendment Sixth Amendment and 14th Amendment Right to remain silent about what you mean when you use the words gin up and crafted is that correct A I dont believe that was your question Yes sir thats exactly my question A Would you repeat the question for me Page I want to know whether when you use the phrase gin up and the word crafted which you have told us is synonymous with gin up A Yes you mean fabricated A Im sorry On advice of Counsel sir and Ive answered that question before but if you didnt hear me the first time I must assert my Fifth Sixth and 14th Amendment Right 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 MR PIKE Form THE WITNESS 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 BY MR SCAROLA Who else besides Bill Clinton is included in Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page your reference to various people A There are people in California There are people in New York Would you name them for us please A Im sorry Sitting here today Mr Scarola Im going to have to assert my Fifth Amendment Sixth Amendment and 14th Amendment Right Lets then talk about Bill Clinton by whom I assume you mean former President Clinton is that correct A Thats correct All right Do you know former President Clinton personally A Im sorry As I sit here today though Id like to answer that question on advice of my Counsel at least today Im going to have to take the Fifth Sixth and 14th Amendment 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 Page 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 MR PIKE And just for purposes BY MR SCAROLA 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 inditement the others already sitting in jail I had asked you earlier whether ginned up and crafted meant fabricated and you asserted your Fifth Amendment privilege Page Are you now telling us that there were claims against you that were fabricated by Mr Edwards A Im going to again assert my Fifth Sixth and 14th Amendment Right sir I would respond that the newspapers are very clear that the cases were fabricated 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 Well which of Mr Edwards cases do you contend were fabricated A Again weve requested most of the information from the bankruptcy trustee Weve been unable Mr Edwards has not given us the total file but respect to any individual I would have at the moment I would have to assert my Fifth Sixth and 14th Amendment claim sir So you will not answer questions about whether the claim on behalf of L.M was fabricated is that correct A I believe Ive already answered that but if again Ill have to assert my Fifth Sixth and 14th Page Amendment Right sir Your Complaint also makes reference to a claim on behalf of Jane Doe referred to as Jane Doe versus Epstein case number a case pending in the United States District Court for the Southern District of Florida Is it your contention that the claim on behalf of Jane Doe is a fabricated claim A Sir though Id like to answer that question as well as every one of your other questions here today today Im going to have to assert my rights as under the Constitution of the Fifth Sixth and 14th Amendment Do you know the real name of the person referred to as Jane Doe in that case A I dont know which Im sorry sir I do not sitting here today Did you ever have personal contact with the person referred to by the name Jane Doe in that lawsuit A Im sorry sir Sitting here today Im going to have to assert my Fifth Sixth and 14th Amendment Right When did you first meet the person referred to as Jane Doe A Sir though Id like to answer each and every one of your questions here today at least with respect Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page to that question Im going to have to assert my rights under the Sixth Amendment 14th Amendment and Fifth Amendment Where did you first meet the person referred to as Jane Doe A Sir though Id like to answer that question here today at least today on advice of Counsel Im going to have to assert my Fifth Amendment Sixth Amendment and 14th Amendment Right How many times have you been in the physical presence of the person referred to as Jane Doe A The person referred to as Jane Doe Yeah How many times have you been in her physical presence MR PIKE Form THE WITNESS At least at least sitting here today Mr Scarola Im going to have to assert my Fifth Amendment Sixth Amendment and 14th Amendment Right BY MR SCAROLA Did you ever have any physical contact with Jane Doe MR PIKE Form THE WITNESS Now for this purposes youre assuming this Jane Doe is somebody I know I dont Page think so since this question makes no sense to me BY MR SCAROLA You have alleged in your Complaint that there is a claim on behalf of Jane Doe versus Epstein pending in the Federal District Court of the Southern District ofFlorida I would like to know whether you ever had any physical contact with the person referred to as Jane Doe in that Complaint A Ah that Jane Doe Im sorry But sitting here today Mr Scarola Im going to have to refuse to answer that question based on the Fifth Amendment Sixth Amendment and 14th Amendment Did you ever exchange any money or gifts with Jane Doe A Again Mr Scarola sitting here today Im going to have to on advice of Counsel assert my Sixth Amendment Fifth Amendment and 14th Amendment Right Your Complaint makes reference to a case styled E.W versus Epstein case number a case pending in the Circuit Court of Palm Beach County Florida Do you know who E.W is A Sitting here today Mr Scarola Im going to have to assert my rights as under the Fifth Sixth and Page 14th Amendment Have you ever learned the real name of E.W A Yes sir Did that person whose real name you learned ever spend any time in your physical presence A Sir at least sitting here today I would like to answer each and every one of your questions regarding your E.W and are we not allowed to use the names of these people sir MR PIKE In the past in the past cases the names of these individuals have been utilized for deposition purposes Brad Edwards sitting here today knows that we have used however any documents that are filed with the Court will redact those names So the answer to the question is yes for purposes of this deposition to the extent you know the names of individuals you can utilize them with agreement of Mr Edwards MR EDWARDS I have no problem with that THE WITNESS I think to avoid confusion so theres not I know who youre talking about Thats all BY MR SCAROLA What is the real name of the person referred to as E.W A I believe it is E.W How long have you known E.W A Well with respect to that question Page Mr Scarola Im going to have to assert my Fifth Sixth and 14th Amendment Rights though Id like to answer every single question you have about E.W How many times have you been in the physical presence of E.W A Id like to answer every question about E.W that you have today Mr Scarola however on advice of Counsel Im going to have to assert my Fifth Sixth and 14th Amendment Right How old is E.W A I dont know How old was she when you met her A Mr Scarola Im going to have to assert my rights under the Fifth Sixth and 14th Amendment on advice of Counsel though I would like to answer every one of these questions Did you ever have any physical contact with E.W A Mr Scarola once again I would like to answer each one of your questions here today but on advice of Counsel Im going to have to assert my Fifth Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page Sixth and 14th Amendment Right Did you ever exchange any money or gifts with E.W A Sir Id like to answer every question you have about E.W however today on advice of Counsel Im going to have to assert my Fifth sixth and 14th Amendment Right Did you ever cause any money or gifts to be delivered to E.W A Mr Scarola as Ive answered most of your questions here today regarding E.W I would like to answer every question regarding E.W however today on advice of Counsel Im going to have to assert my Fifth Sixth and 14th Amendment Right because though I would choose to do so Ive been told that ifl do so I risk losing my Counsels representation What is the actual value that you contend the claim of E.W against you has MR PIKE Form Relevance THE WITNESS Sir though Id like to answer every question about E.W and her claims and the claims of your other people on advice of Counsel here today I cannot do so I must assert my rights under the Sixth Fifth and 14th Amendment BY MR SCAROLA Page Would your answer be the same with regard to L.M and to Jane Doe MR PIKE Im going to instruct you if your answer is the same to invoke in full THE WITNESS With respect to I believe Jane Doe and who is the other person Im sorry BY MR SCAROLA L.M A L.M Though Id like to answer your claims with respect to all three of Mr Edwards clients on advice of Counsel at least today Im going to have to invoke my Fifth Sixth and 14th Amendment Rights Though Id prefer to answer the question Ive been told that ifl choose to do so I risk losing their representation Among those items listed by you as wrongdoing on the part of Mr Edwards forming the basis for this lawsuit is that he quote counseled his clients to make multi-million dollar claims against you is that correct MR PIKE Form Document speaks for itself THE WITNESS Document speaks for itself BY MR SCAROLA Im not asking about a document Im asking you about the list of wrongdoing that you gave us during Page the course of this deposition which you allege form the basis for your claim against Mr Edwards Is it your contention that among those things Mr Edwards did that form the basis for your lawsuit is to have counseled his clients to make multi-million dollar claims against you MR PIKE Form THE WITNESS What the newspapers have said is that the claims purported to have been made by the Rothstein firm and its partners allege multi-million dollar claims where no claims exist However respect specifically to my claim today Im going to have assert my Fifth Sixth and 14th Amendment Right MR PIKE Also the question mischaracterizes the witness testimony BY MR SCAROLA By whom was Bradley Edwards employed when he initiated litigation against you A I would like to know the answer to that question So the answer to that question is I dont know A I would like Correct Page A No I answered that question which is Id like to know Yes But that isnt an answer to my question My question is By whom was Mr Edwards employed at the time that he initiated litigation against you Do you know the answer to that question A Id have no way of knowing the answer to that question sir 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 Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page 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 BY MR SCAROLA 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 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 MR PIKE Try once again to answer that question THE WITNESS Its been widely reported in the newspaper that his firm and his partners were Page 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 BY MR SCAROLA 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 Page 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 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 BY MR SCAROLA Do you have any personal knowledge that Bradley Edwards was ever involved in any actionable frauds MR PIKE Same same instruction with any of your lawyers THE WITNESS Yes 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 ofboxes of material on Page Jeffrey Epstein separate and apart from the allegations of fraud by his partners I cannot answer that question because of attorney/client privilege BY MR SCAROLA Do you have any personal knowledge that Bradley Edwards was involved in any egregious civil litigation abuses MR PIKE Form Confusing THE WITNESS Its widely reported in the newspaper that Mr Edwards firm engaged in wild discovery processes illegal activities illegal eavesdropping in order to fleece unsuspecting investors in South Florida out of millions in dollars by crafting fabricating malicious cases of a sexually charged nature in order to perpetrate a fraud BY MR SCAROLA 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-existing Epstein settlements Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page MR PIKE Same instruction THE WITNESS Im sorry I would like to answer that question but on attorney/client privilege I cannot today BY MR SCAROLA 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 BY MR SCAROLA Page 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 BY MR SCAROLA 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 MR PIKE Form THE WITNESS Can you just ask can you define for me what you mean by personal knowledge sir BY MR SCAROLA 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 Page justice systems in South Florida MR PIKE Form Same instruction with regard to attorney/client THE WITNESS 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 BY MR SCAROLA Yes sir thats exactly right A You told me ifl 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 Your Complaint makes reference to a purpose in filing this lawsuit to quote vindicate the hardworking and honest lawyers and their clients who Page were adversely affected by the misconduct that is the subject of this Complaint unquote Who are those hardworking and honest lawyers that you are seeking to vindicate MR PIKE Form Give me a minute What page of the Complaint are you referring to MR SCAROLA Page MR PIKE Give me one second THE WITNESS Can we go off the record just for a second MR PIKE If its okay with Mr THE WITNESS Its a bathroom break MR PIKE Theres a question pending and usually THE WITNESS Sorry MR PIKE Just give me a second Okay THE WITNESS Where is it MR PIKE Its page of the Complaint which has my notes on it down here the last sentence And to the extent that you have knowledge and can answer that question you can do so THE WITNESS Could you repeat the question for me sir Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page BY MR SCAROLA Yes sir 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 MR PIKE Okay Form Mischaracterizes the Complaint itself To the extent you understand that question you can attempt to answer if you recall THE WITNESS 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 Page BY MR SCAROLA Now before you answered that question you reviewed a document right A The Complaint sir Id like to see it please MR PIKE Definitely not Mr Scarola My notes are on that and thats attorney/client I allowed the witness to take a look at the document and he did not write anything on the document He looked at the document Thats my client And you will certainly not be looking at my notes which are all over this document MR SCAROLA He didnt look at everything He looked at one page I would like that one page please MR PIKE Absolutely not Mr Scarola MR SCAROLA I would like that page marked as an Exhibit to this deposition MR PIKE Absolutely not Mr Scarola MR SCAROLA I would state for the record that it is my intention since that page with handwritten notations on it was reviewed by the witness during the course of this deposition while a question was pending I want that page preserved Page so that the Court can make a determination as to whether I am entitled to see it MR PIKE I would object based upon attorney/client and work product in that regard THE WITNESS Now can we take a bathroom break MR SCAROLA No sir because you still havent answered my question THE WITNESS Okay BY MR SCAROLA 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 Page 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 Now was it your intention in this sentence to say that you were trying to vindicate the hardworking and honest lawyers and their clients A Its attorney/client Im sorry Your intention is attorney/client privileged MR PIKE Form Im not quite BY MR SCAROLA Is that what youre telling us MR PIKE Wait a second Im not quite sure I understand the question THE WITNESS Whats the question BY MR SCAROLA Were you attempting to communicate in this Complaint a desire on your part to vindicate hardworking and honest lawyers and their clients MR PIKE Form THE WITNESS In this Complaint I intend to get to the truth of Mr Edwards behavior and the Rothstein firm sir BY MR SCAROLA Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page Well what this sentence says is quote A Yes the Rothstein racketeering enterprise endeavored to compromise the core values of both State and Federal 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 communicate A It says what it says sir Well I know it says what it says Im trying to find out if thats what you meant to say that is that 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 Form Mischaracterizes the language of the document THE WITNESS Yeah I think youve misread that again You want to I certainly didnt ask for the Rothstein firm to vindicate the lawyers is what youve just BY MR SCAROLA Well thats what Im trying to find out whether you meant to say what you said in this Page Complaint Did you read the Complaint before it was filed MR PIKE Form Move to strike THE WITNESS Thank you sir BY MR SCAROLA Did you read the Complaint before it was filed A It was a while ago yes sir And did you approve the Complaint prior to its filing A Yes sir 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 Page the misconduct that is the subject of this Complaint BY MR SCAROLA 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 Page Knowingly part of a criminal enterprise MR PIKE Form THE WITNESS Attorney/client privilege MR SCAROLA You wanted to take a break and before I move on to another subject well do that But I want I want to observe for the record that the last break was less than an hour ago While I want to try to make reasonable accommodations to witnesses so as not to impose unnecessarily upon their physical comfort I will object to breaks occurring at less than one-hour intervals during the course of this deposition VIDEOGRAPHER Were now off video record It is a.m Briefrecess VIDEOGRAPHER We are now back on video record It is a.m and we are on media number two BY MR SCAROLA 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 personal knowledge do you have of Bradley Edwards ever having been engaged in any mail fraud Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page 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 MR PIKE Form Mischaracterizes the witness testimony THE WITNESS Ive asked for a clarification BY MR SCAROLA Have you ever personally witnessed Bradley Edwards engaging in mail fraud MR PIKE Form THE WITNESS No sir BY MR SCAROLA Page 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 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 Page can answer it without violating attorney/client and work product you can answer the question THE WITNESS Im afraid it will be attorney/client privilege sir BY MR SCAROLA 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 BY MR SCAROLA 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 blogs 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 Page 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 BY MR SCAROLA 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 ofhis firm Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page 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 So you want to withdraw the earlier response that you made and your real answer is I dont know is that correct MR PIKE Mischaracterizes the witness testimony Move to strike BY MR SCAROLA Your response sir A My answer stays the same sir Is it your contention that one or more lawsuits was fabricated against you A Its been widely reported in the newspapers Thats not my question A Excuse me I was answering MR PIKE Please let the witness answer the question Mr Scarola BY MR SCAROLA Page No youre not answering my question MR PIKE Hes only said three words so you dont know whether hes answering your question or not MR SCAROLA I didnt ask him anything about newspapers I asked him about his contention I dont know hes not answering my question BY MR SCAROLA But you can go ahead Mr Epstein and you can make your silly speech one more time MR PIKE Im going to move to strike THE WITNESS You want to repeat the question BY MR SCAROLA Yes sir I would like to know whether it is your contention that one or more lawsuits have been fabricated against you A My contention sir is that the firm of Edwards partners Scott Rothstein fabricated many cases reported by the press and the U.S Attorney amongst people like me and others of a sexually charged nature in order to fleece investors of South Florida out of millions of dollars Do I have a with respect to my individual cases that Mr Edwards has filed in these three cases Im unfortunately today and only today at least on Page advice of Counsel Im going to have to assert my Fifth Sixth and 14th Amendment sir Okay Well Im not limiting my question to the three cases referenced in your Complaint I want to know whether you contend that any claim against you has been fabricated MR PIKE Form Overbroad and confusing and its compound THE WITNESS The question makes no sense to me Im sure you could do better BY MR SCAROLA Is there any pending claim against you which you contend is fabricated A At least today sir Im going to have to respond by asserting my Fifth Sixth and 14th Amendment Right MR PIKE Form also BY MR SCAROLA 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 Your Complaint makes reference to someone sifting through a potential defendants garbage looking for damaging evidence to use with investors to show how Page potential defendants could be in essence blackmailed MR PIKE Would you identify for me Mr Scarola what page MR SCAROLA Page paragraph BY MR SCAROLA Did anyone ever sift through your garbage looking for damaging evidence MR PIKE One second In light of clarity Mr Scarola would you please read the entire paragraph so Mr Epstein understands the tenor of the paragraph MR SCAROLA No I want to know whether anyone ever sifted through Mr Edwards garbage through Mr Epsteins garbage Thats the pending question MR PIKE To the extent you understand the question you can answer THE WITNESS I think the question is poorly phrased Did anyone ever sift through my garbage What does that mean BY MR SCAROLA You dont know what sifting through garbage means A Does that mean the garbage man Does that include the garbage man Im sure he sifted through my Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page garbage Which garbage man sifted through your garbage A Im sure people who go through garbage sift through the garbage I have no idea 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 Yes But I didnt ask you what some newspaper is alleged to have reported What I did ask you is whether anyone ever sifted through your garbage looking for damaging evidence And the answer to that question I think can be either yes no or I dont know MR PIKE Move to strike BY MR SCAROLA Or you could refuse to answer it on the grounds that it may tend to incriminate you A I think you might MR PIKE Move to strike THE WITNESS I would like to answer my own questions If youd like to answer all my Page questions Mr Scarola Im more than happy to sit here and answer them Would you like to continue BY MR SCAROLA Yes Id like to know what the answer to that question is Did anyone ever sift through your garbage looking for damaging evidence MR PIKE Form THE WITNESS I dont know BY MR SCAROLA Did you ever have damaging evidence in your garbage A Whats damaging evidence sir Evidence tending to implicate you in criminal conduct MR PIKE Form THE WITNESS At least today Mr Scarola with these with your questions and your claims and your defense of Mr Edwards and his firm the Rothstein firm while his partner sits in jail today Im going to have to assert my Fifth Sixth and 14th Amendment Right sir BY MR SCAROLA Did you ever have any evidence in your garbage that would subject you to blackmail MR PIKE Form Same same objection Page THE WITNESS Again Ill respectfully answer the question by asserting my Fifth Sixth and 14th Amendment Right BY MR SCAROLA Your Complaint in paragraph page says that Upon information and belief Rothstein David Boden Debbie Villegas Andrew Barnett Michael Fisten and Kenneth Jenne all employees ofRRA through brokers or middle men would stage regular meetings during which false statements were made about the number of cases/clients that existed or RRA had against Epstein and the value thereof Do you have any knowledge that Mr Edwards ever knew about such meetings being conducted MR PIKE Form To the extent you understand the question and it will not violate any attorney/client or work product privilege information you can answer that question MR SCAROLA Mr Pike it has become evident that that speaking instruction to your witness is an instruction for him to assert an attorney/client privilege regardless of whether it is or is not valid and I object to it MR PIKE Let me make the record clear Page Youve been interchanging knowledge with personal knowledge And many of the objections to which I am asserting an attorney/client and work product privilege are based upon your malphrased question and use of personal knowledge and knowledge interchangeably with those questions So if you want to rephrase your question to attempt to elicit a response let me finish then I have no objection to that However Im not going to sit here and allow my client to waive attorney/client and work product Now to the extent youre saying Im coaching the witness I object to that because I am certainly not The witness is here to answer your questions and I believe has been answering your questions today to the best of his ability MR SCAROLA I am saying youre coaching the witness BY MR SCAROLA Could you answer the question MR PIKE Same objection THE WITNESS Youll have to repeat it BY MR SCAROLA Do you have any information indicating that Bradley Edwards ever had any knowledge of anyone Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page 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 BY MR SCAROLA 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 MR PIKE Form Page 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 BY MR SCAROLA Page 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 MR PIKE Form THE WITNESS Thats attorney/client privilege BY MR SCAROLA 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 MR PIKE To the extent you can answer that question THE WITNESS I understand Page MR PIKE then please THE WITNESS Yes MR PIKE answer Mr Scarolas question THE WITNESS Separate from MR SCAROLA Objection Coaching the witness THE WITNESS Separate from the communication Ive had with my attorneys I cant answer that question MR PIKE Mr Scarola Im confused I started objecting to form in the beginning of this deposition You then instructed me which is against the rules Mr Pike I dont know whats wrong with the form I object to you objecting to form Then I assert the attorney/client work product and now youre telling me Im coaching the witness So tell me Mr Scarola what is the what is the way that you would like me to object in this deposition and maybe I can conform that way for you which may or may not be consistent with the Florida Rules of Civil Procedure MR SCAROLA Mr Pike MR PIKE Yes sir Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page MR SCAROLA if you dont know the difference between a form objection and a privilege objection MR PIKE Right MR SCAROLA then this deposition is not the proper context in which for you to learn the difference between a form objection and a privilege action MR PIKE Im pretty clear on what a form objection is and what a privilege objection is and Im pretty knowledgeable on that The problem MR SCAROLA Then we dont need to engage in any further discussion MR PIKE I want to try to make the record clear because initially you didnt want me to object to form You wanted me to speak So Im thinking youre conceding to that point What my question is is Whats wrong with my objecting to attorney/client work product So I guess Im asking you what you were asking me earlier on Whats wrong with the form We can just move forward BY MR SCAROLA In your Complaint you identify the RRA law firm Rothstein and Edwards as the quote litigation Page team unquote You then go on to say in paragraph of your Complaint at page that Rothstein and the litigation team MR PIKE Wait a minute Put that down for a second Hold on THE WITNESS You can read it BY MR SCAROLA Individually and in a concerted effort may have unethically and illegally engaged in certain specified conduct May we correctly conclude from that statement that you dont have any knowledge as to whether the quote litigation team including Mr Edwards engaged in any unethical and illegal conduct MR PIKE For now while Im reviewing the document itself Im just going to just tell you to hold off THE WITNESS Sure MR PIKE on answering that question You may want to go off the record so we dont have a lag in MR SCAROLA No Id like it on the record Thank you MR PIKE Mr Scarola did you bring an extra Page copy of the Complaint that youre questioning Mr Epstein on for Mr Epstein to look at MR SCAROLA No MR PIKE Okay Im going to have to go get him a copy so he can the paragraphs of this Complaint are very long and the Complaint itself is in excess of it was approximately pages so MR SCAROLA Ill withdraw the question BY MR SCAROLA Do you have any evidence that Brad Edwards sold allowed to be sold and/or assisted with the sale of an interest in non-settled personal injury lawsuits MR PIKE Form THE WITNESS The newspapers have widely reported that the Rothstein firm engaged in illegal 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 BY MR SCAROLA As you sit here today do you have any evidence whatsoever to support an assertion that Bradley Page Edwards individually and personally sold allowed to 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 BY MR SCAROLA 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 Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page 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 specific evidence With respect to what we currently know sitting here today Im unfortunately going to have to claim my attorney/client privilege BY MR SCAROLA 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 Page 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 BY MR SCAROLA 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 Page 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 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 BY MR SCAROLA 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 Page 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 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 BY MR SCAROLA Is it your contention that Mr Scherers Complaint even contains the name Bradley Edwards A I dont recall sir Did sexual assaults ever take place on a private airplane on which you were a passenger MR PIKE Form Relevance THE WITNESS At least I would like to answer each and every one of your questions here today Mr Scarola But at least today Im going do have to assert my Fifth Sixth and 14th Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page Amendment Rights as provided by the U.S Constitution BY MR SCAROLA Does a flight log kept for a private jet used by you contain the names of celebrities dignitaries or International figures A At least today sir Im going to have to respectfully decline to answer based on my Fifth Sixth and 14th Amendment Right though Id like to answer that question Have you ever had a personal relationship with Donald Trump A What do you mean by personal relationship sir Have you socialized with him A Yes sir Yes A Yes sir Have you ever socialized with Donald Trump in the presence offemales under the age of A Though Id like to answer that question at least today Im going to have to assert my Fifth Sixth and 14th Amendment Right sir Have you socialized with Alan Dershowitz A Yes sir Hes my attorney as well as a Page friend Have you ever socialized with Alan Dershowitz in the presence offemales under the age of MR PIKE Form THE WITNESS Sir at least here today Im going to have to assert my Fifth Amendment Sixth Amendment and 14th Amendment Rights BY MR SCAROLA Have you ever socialized with Tommy Mottola A This is the type of questions where people who have nothing to do with this case whatsoever have been brought into the case by Mr Edwards in an attempt to simply imperil my relationships with social friends and serves as an example of why this case has been brought against Mr Edwards and his firm sir MR PIKE Form as well BY MR SCAROLA Well do you know who brought those persons names into this lawsuit MR PIKE Form And just to be clear what Mr Scarola I believe talking about this lawsuit Epstein versus RRA BY MR SCAROLA Yes sir thats the lawsuit Im talking Page about The one in which your deposition is being taken today Do you know who brought those persons names into this lawsuit A As a reaction and only as a reaction to total misbehavior on Mr Edwards part and the Complaint was obviously written by my attorneys sir So you know that those names are in your Complaint right A Yes sir Okay So because those names are in your Complaint Im asking you about the people you named Have you had a social relationship with Tommy Mottola A The names in my Complaint are strictly as a reaction to the abusive discovery process by Mr Edwards his partners Scott Rothstein who sits in jail in an attempt to imperil my friendships But yes I have socialized with Mr Mottola Have you ever socialized with Mr Mottola in the presence of females under the age of MR PIKE Form THE WITNESS At least today the typical to the Edwards contention of bringing cases of a malicious nature where his partner sits in jail for Page this just this type of behavior the answer is today at least I must assert my Fifth Sixth and 14th Amendment Right though Id like to answer each and every one of your questions Mr Scarola BY MR SCAROLA Have you had a social relationship with David Copperfield A As a reaction to once again the abusive discovery process of bringing in names of people that have absolutely nothing to do with any of Mr Edwards Mr Rothsteins or their clients claims by bringing in the names of friends of mine strictly in an attempt to stress my relationships imperil my business relationships Im going to say yes I do know Mr Copperfield Have you ever socialized with David Copperfield A Again as MR PIKE Form THE WITNESS Sorry Its a typical Edwards/Rothstein strategy of trying to involve well-known people in maliciously fabricated cases in order to fleece investors out of millions of dollars They brought up names in attempts at abuse of discovery process to try and Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page take discovery of people who have nothing to do with this case Did I socialize with David Copperfield The answer is yes BY MR SCAROLA Did you ever socialize with David Copperfield in the presence of females under the age of A Im sure again this question is a typical question of Mr Edwards/Rothstein scheme to defraud investors asking questions knowing it serves no purpose or relationship relevance to their case whatsoever At least today though Id like to answer that question on advice of my Counsel and only on advice of my Counsel Im going to have to assert my Fifth Sixth and 14th Amendment Right MR PIKE Form as well BY MR SCAROLA Have you ever had a social relationship with Bill Richardson Governor ofNew Mexico and formerly U.S Representative and Ambassador to the United Nations MR PIKE Form THE WITNESS As is typical of the Edwards scheme along with his partner Scott Rothstein who sits in jail what they attempted to do was Page bring in any celebrity I might have known well-known people in an attempt to strictly imperil my relationships with these people where these people have no bearing whatsoever on any of their claims or cases Yes I do have a social relationship BY MR SCAROLA Have you ever socialized with Mr Richardson in the presence offemales under the age of MR PIKE Form THE WITNESS Again typical of the Edwards/Rothstein scheme ofbringing in well-known people asking them ridiculous questions ridiculous questions in an attempt strictly to imperil my relationships with these people where they have absolutely nothing to do with anything to do with Edwards Rothstein or any of their alleged victims the answer to your question is yes I have socialized BY MR SCAROLA Yes but that wasnt my question My question was Have you ever socialized with Mr Richards in the presence offemales under the age of MR PIKE Form Page THE WITNESS In response to your question again my full answer was typical of the Edwards/Rothstein scheme to ask questions of a sexual charged nature crafted cases the U.S Attorney has called his firm the largest fraud in U.S history fleecing investors out of millions of dollars by engaging in just these types of questions Though I would like to answer each and every question about every one of these people on advice ofmy Counsel today I must take assert my Fifth Amendment Sixth Amendment and 14th Amendment Right Though Id prefer to answer the question I was told that ifl choose to do so I risk losing their representation sir BY MR SCAROLA Have you ever sexually abused children MR PIKE Form THE WITNESS On advice of Counsel and only upon advice of Counsel though Id like to answer that question as well as every other one of your claims brought by Mr Edwards and his partner who currently sits in jail sir I would like to answer those questions But today at least I have to assert my Sixth Amendment 14th Amendment and Fifth Amendment Right Though Id prefer to answer the Page question Im told by my Counsel that if I choose to do so which is my preference I risk losing their representation BY MR SCAROLA How many children have you sexually abused MR PIKE Form And I just want to be clear on the record These types of questions are argumentative and harassing And moreover its my contention that these types of questions are not related to this lawsuit by any stretch of the imagination In this deposition while Ive been liberal in allowing these questions are being utilized in an attempt to provoke a waiver of the Fifth Amendment Right There has been an Order entered by I believe Judge Hafele regarding these types of questions So with that caution Mr Scarola I would ask you that you refrain from asking abusive and harassing questions that are not relevant to this case MR SCAROLA Well its very interesting that you claim theyre not relevant when they are directly taken from the allegations in your Complaint And I agree with you that they are not Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page relevant because there is no basis whatsoever for this claim against Mr Edwards But since youve made these baseless allegations I am obliged to pursue the allegations by asking these questions So well move on from there And whenever you think its appropriate to terminate this deposition because you believe that Ive acted inappropriately be my guest MR PIKE I appreciate your invitation Mr Scarola Im going to move to strike The fact is Mr Scarola is that these types of questions have already been ruled upon as being argumentative and harassing If you want to direct some questions relevant to your lawsuit I invite you to do so But attempting to use this deposition process as a mechanism to provoke a waiver of the Fifth Amendment and to obtain information that is more or potentially more relevant to Mr Edwards cases in which he is lead Counsel on I think is improper BY MR SCAROLA Did you have staff members that assisted you in scheduling appointments with underage females that is females under the age of Page A So along with many of the other claims that the Rothstein firm crafted with malicious claims against people like me and others of a sexually charged nature in order to simply fleece investors out of millions of dollars in South Florida these types of questions though Id like to answer today at least this specific question Im going to have to assert unfortunately my Fifth Sixth and 14th Amendment Right though Id prefer to answer the question BY MR SCAROLA Who are the others referred to in that response A Again sir You said you and others Who are the others that you were referring to A Youll have to read my answer back MR PIKE Im sorry Madame Court Reporter would you please read the witness answer back THE WITNESS Youll have to I have to take a bathroom break MR PIKE Actually I dont one second For the record were going on now Is there do you have a time frame as to when you MR SCAROLA About a half hour MR PIKE You have a half hour left Page MR SCAROLA Uh-huh MR PIKE Okay Do you have an objection to us taking a quick bathroom break and THE WITNESS Ill just walk out and back in MR SCAROLA IfMr Epstein needs to go to the bathroom Mr Epstein needs to go to the bathroom THE WITNESS Thank you sir MR PIKE Then were off the record VIDEOGRAPHER Were off the record Briefrecess VIDEOGRAPHER We are back on video record at p.m BY MR SCAROLA I think when we went off the record you had requested that the last answer that you gave and the question asked of you based on that answer be read back so well start there MR PIKE Madame Court Reporter Previous question and answer were read THE WITNESS Sounds like a complete answer to me BY MR SCAROLA No sir My question to you following that answer was Who are the others to whom you made Page reference in that response You said me and others Who are the others A Can you repeat where it says me and others Im sorry MR SCAROLA Read it back again please Sandy Answer was read THE WITNESS The others are people reported in the press to be many people in South Florida who were the victims of the Rothstein scam Im glad Im happy to answer the others Id like to know the others In fact weve subpoenaed documents from the bankruptcy trustee of Brad Edwards firm in an attempt to find out more details of the others that youve just asked about People I believe the Attorney Scherer has filed a Complaint for some of the others who have been defrauded as well as some of the investors who were told about many others sir BY MR SCAROLA So you dont know any names is that correct MR PIKE Form Move to strike Mischaracterizes the witness testimony THE WITNESS Im sure thats an its an easy way of saying that as a response to the Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page questions and subpoenas weve asked Mr Edwards to produce so we can find out the specific names of the others who have been the U.S Attorney has claimed have been blackmailed and victims of the Rothstein firm Id be happy and hopefully at the end of this trial everyone will know some of the names of the others sir BY MR SCAROLA Do you know the names of any of the others A No sir I do not However the U.S Attorney we believe is going to file more charges against Mr Roth Mr Edwards partners And Mr Scherer and us have subpoenaed the bankruptcy trustee for the names of the others So sitting here today I do not Hopefully sometime before trial we will have names of the others sir Have you ever pled guilty to any criminal wrongdoing A Yes sir What criminal wrongdoing did you plead guilty to A A solicitation of prostitution and procuring a minor for prostitution sir Page On how many occasions did you solicit prostitution A Under excuse me Again On how many occasions did you solicit prostitution A At least sitting here today Im going to have to on advice of Counsel assert my Fifth Amendment 16th Amendment sic and Fourth sic Amendment Right On how many occasions did you plead guilty to soliciting prostitution A Once sir How many acts of solicitation of prostitution did you plead guilty to A Three What are the names of the individuals who you pled guilty to soliciting as prostitutes A I do not know When did those acts occur A I do not know How many prostitutes have you solicited MR PIKE Form THE WITNESS On advice of Counsel at least sitting here today sir Id like to answer each one of those questions However today Im going to have to assert my Fifth Sixth and 14th Page Amendment Right BY MR SCAROLA Who are the minors who you solicited for prostitution MR PIKE Form THE WITNESS Who are the I pled guilty to soliciting prostitution There was no soliciting minors charge sir MR SCAROLA Could you read back the response to the question about what Mr Epstein pled guilty to please MR PIKE About four questions back Previous question and answer were read MR PIKE And his answer MR SCAROLA That was his answer BY MR SCAROLA Who are the minors who you procured for prostitution MR PIKE Form THE WITNESS I believe if you my answer was procuring a minor sir not minors BY MR SCAROLA Who is the minor that you procured for prostitution A I do not know Page MR PIKE Form And relevance BY MR SCAROLA How many minors have you procured for prostitution MR PIKE Form THE WITNESS On advice of Counsel sir Im going to have to assert my Fifth Sixth and 14th Amendment Right though I pled guilty to procuring a single minor BY MR SCAROLA Yes but my question wasnt about what you pled guilty to I just want to know how many minors you have procured for prostitution MR PIKE Asked and answered THE WITNESS Again at least with respect to what Ive pled guilty to I pled guilty to procuring a single minor With respect to the rest of your question Im going to have to assert my Fifth Sixth and 14th Amendment Rights as provided by my Counsel BY MR SCAROLA When did you procure the minor for prostitution as to which procurement you pled guilty MR PIKE Form THE WITNESS I dont know Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page BY MR SCAROLA Was there a time before you entered your guilty plea when you knew the identity of the prostitutes that you solicited MR PIKE Form THE WITNESS Again BY MR SCAROLA Was there a time before the entry of your guilty plea when you knew the identity of the prostitutes you solicited MR PIKE Form THE WITNESS I dont recall BY MR SCAROLA Was there a time before the entry of your guilty plea when you knew the identity of the minor that you pled guilty to procuring for prostitution MR PIKE Form THE WITNESS I dont know BY MR SCAROLA Did you plead guilty because you were in fact guilty MR PIKE Form Thats attorney/client work product Attorney/client MR SCAROLA I havent asked anything about Page any communication MR PIKE It definitely could get into a communication with Mr Epsteins lawyers at the time of the criminal proceeding MR SCAROLA No sir it cant BY MR SCAROLA I want to know whether you pled guilty because you were in fact guilty A Im going to have to assert my Fifth Sixth and 14th Amendment sir Do you understand the term John to be a slang reference to the customer of a prostitute MR PIKE Form THE WITNESS Yes sir BY MR SCAROLA How many times were you one ofL.M.s customers MR PIKE Form THE WITNESS L.M.s customers Youll have to rephrase the question sir BY MR SCAROLA Your Complaint says MR PIKE What page were you reading from MR SCAROLA Page MR PIKE Thank you Page BY MR SCAROLA Paragraph a last sentence Under the circumstances her claim for damages against Epstein one ofL.M.s many Johns during that same period et cetera You have identified yourself in this Complaint as one ofL.M.s many Johns which you acknowledge to be a reference to a customer of a prostitute How many times were you one ofL.M.s customers for purposes of prostitution A Well now that youve now put on the record that L.M I believe in her deposition is an admitted prostitute I would like to answer that question but on advice of Counsel sir Im going to have to respectfully decline But I am happy to hear you finally admit it in your own questions that your L.M is an admitted prostitute MR SCAROLA Move to strike Unresponsive BY MR SCAROLA Have you ever coerced induced or enticed any minor to engage in any sexual act with you MR PIKE Form THE WITNESS A typical question from Mr Scarola representing Mr Edwards and the firm of Rothstein who Scott Rothstein sits in jail for Page crafting cases of a sexual nature against people in South Florida me and others the others yet to be determined However today though Id like to answer every one of his questions on advice of Counsel at least today Im going to have to assert my Fifth Sixth and 14th Amendment Right BY MR SCAROLA How many times have you engaged in fondling underage females MR PIKE Form THE WITNESS This is relevance here at some point MR PIKE To the extent you can answer the question THE WITNESS Again as another one of the irrelevant questions asked of this lawsuit with respect as a client how I was abused by the Rothstein firm for his the practices the abuse of the legal system the hopefully the ladies and gentlemen of the jury will be able to see through some of these ridiculous questions with respect to questions that today at least I must take the Fifth Sixth and 14th Amendment but I believe are obvious to the ladies and gentlemen of the jury what youre trying to do here Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page Mr Scarola MR SCAROLA Move to strike Unresponsive MR PIKE No Thats fine BY MR SCAROLA How many times have you engaged in illegal sexual touching of minors MR PIKE Form Relevance THE WITNESS Again an irrelevant question to this lawsuit strictly as a continued attempt to bring in irrelevant facts to the fact of what the Rothstein firm has done to both me and others in South Florida defrauding investors of millions of dollars knowing that at least today Im going to have to with respect to that particular question assert my Fourth excuse me Fifth Sixth and 14th Amendment Rights MR SCAROLA Move to strike as unresponsive MR PIKE Mr Scarola hes answering your question Youre asking abusive and harassing questions that are unrelated to this lawsuit If you can direct me to anywhere in the Complaint that even remotely addresses your two questions that youve just posed to Mr Epstein Id be happy to look at the section in the Complaint But moving to strike the witness Page answer when hes answering your abusive and harassing questions is improper BY MR SCAROLA How many times have you engaged in oral sex with females under the age of MR PIKE Objection Relevance Abusive and harassing Not reasonably calculated to lead to discovery of admissible evidence in this case THE WITNESS A typical question posed by Mr Scarola in an attempt to divert the attention away from the wrongdoing of Bradley Edwards his partner Scott Rothstein who sits in jail for defrauding investors of South Florida of millions of dollars by crafting malicious cases of a sexual nature just in order to fleece investors called by the U.S Attorney one of the largest frauds in South Floridas history Mr Scarola as I would like to respond to the questions regarding of your underage girls the fondling or the other questions youve asked me here today unfortunately I cannot on advice of Counsel answer those questions so I must assert my Fifth Sixth and 14th Amendment Rights though these questions are totally irrelevant to this lawsuit Page MR SCAROLA Move to strike as unresponsive BY MR SCAROLA Do you have a personal sexual preference for children MR PIKE Form Relevance Abusive Harassing Not reasonably calculated to lead to the discovery of admissible evidence in this case THE WITNESS Another totally irrelevant question to this lawsuit Mr Edwards behavior in an attempt to strictly divert attention from the wrongdoing of the Rothstein firm in this matter by asking sexually charged questions in a case where the Rothstein firm has been charged by the U.S Attorney of fabricating claims of a malicious nature hiding behind attorney/client privilege forging documents excuse me but as with respect to these questions designed for nothing more than to harass me Mr Scarola Im going to have to unfortunately take the Fifth Sixth and 14th Amendment MR SCAROLA Move to strike as unresponsive BY MR SCAROLA Have you ever acted on a sexual preference for children MR PIKE Form Irrelevant Abusive Page Harassing And not reasonably calculated to lead to admissible evidence in this case THE WITNESS One more of Mr Scarolas irrelevant questions designed nothing more to try to harass me to divert attention from the fact that Mr Edwards and his firm perpetrated one of the largest frauds in South Floridas history by using people like me and others in an attempt to fleece South Florida investors out of millions of dollars where the U.S Attorney has accused his firm of being the largest criminal enterprise in South Floridas history where Mr Edwards partner sits in prison potentially for the rest of his life Id like to answer all of your questions here today Mr Scarola even though theyre irrelevant however on advice of Counsel at least today Im going to have to assert my Fifth Sixth and 14th Amendment Right MR SCAROLA Move to strike as unresponsive BY MR SCAROLA Your Complaint at page paragraph says that RRA and the litigation team took an emotionally driven set of facts involving alleged innocent unsuspecting underage females and a Palm Beach Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page billionaire and sought to tum it into a gold mine end of quote Who is the Palm Beach billionaire referred to in that sentence A On advice of Counsel today Mr Scarola though I would like to answer each one of your questions Im going to have to assert my Fifth Sixth and 14th Amendment Right What is the emotionally driven set of facts to which you make reference in that sentence A Its the same set of facts that were used by the Rothstein firm to fleece unsuspecting investors out of millions of dollars crafting fabricating malicious cases of a sexually charged nature with no fundamental basis whatsoever reported wildly by the press The U.S Attorney has accused Mr Edwards partner of not excuse me Mr Edwards partner sits currently in jail pled guilty to some of these charges There are other members of his firm under investigation for just these types of questions and fabrications But however today though Id like to answer every one of your questions with specificity on advice of Counsel Im not going to be able to Mr Scarola and respectfully decline based on my Fifth Sixth and 14th Amendment Right Page 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 BY MR SCAROLA Your Complaint says that Rather than evaluating and resolving the cases based on the merits open parens i.e facts close parens which included knowledgeable voluntary and consensual actions by each of the claimants et cetera Who are the claimants that are referenced there A Its Im sorry You have to repeat the question Yes sir Your Complaint says MR PIKE Page rather than evaluating MR PIKE Can you give me a page sir MR SCAROLA Page paragraph second sentence BY MR SCAROLA Quote rather than evaluating and resolving Page the cases based on the merits that is facts which included knowledgeable voluntary and consensual actions by each of the claimants A Yes Who are the claimants that youre referencing there A Theyre the prostitutes you referred to in the past sir What are their names A I think the prostitutes names were the prostitute that you described before was L.M With respect to the others Im going to have to claim the Fifth Sixth and 14th Amendment sir So one of the individuals that youre referencing there is L.M is that correct A Its the individual Ive referenced is a person who filed a claim against me Is it L.M A It is L.M as far as I know from the claim sir Okay So one of the people that youre referring to is L.M who youve identified as L.M is that correct A With respect to that question sir on advice of Counsel Im going to have to assert my Fifth Sixth Page and 14th Amendment What are the voluntary and consensual actions by L.M that you are referencing there A Sir though Id like to answer each one of your questions here today Im going to have to respectfully decline based on advice ofmy Counsel and have to assert my Fifth Sixth and 14th Amendment Right What are the damages that you claim to have suffered as a consequence of any wrongdoing on the part of Bradley Edwards MR PIKE Form THE WITNESS The cost of ridiculous litigation of having my attorneys prepare responses to wildly irrelevant discovery in various locations at a minimum sir BY MR SCAROLA 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 Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page Page A Oh I do Are you paying him on an hourly basis Besides Mr besides the Burman Critton firm A I believe so and Mr Goldberger Whats the hourly rate A Are you asking me for the firm sir or are A I dont know sir you asking me for the names How much have you paid Alan Dershowitz I want as much information as you can give me A Hundreds of thousands of dollars about this element of damage which you claim and that Are you paying him on an hourly basis is the cost oflegal services that you claim to be A I believe so damages in this case At what hourly rate A Okay A I dont know sir MR PIKE Form And move to strike How much are you paying Jay how much have THE WITNESS Mr Roy Black you paid Jay LeJkowitz BY MR SCAROLA A Im not sure sir Okay Who else Do you have any idea at all A Mr Marty Weinberger Mr Alan Dershowitz A More than a hundred thousand dollars Mr Jay LeJkowitz The firm of Burman Critton Luttier Are you paying him on an hourly basis Thats it for the moment A Yes sir How much have you paid the law firm of Burman Whats the hourly rate Critton and Luttier which you claim is damages A I dont know A Hundreds of thousands of dollars sir What is the form of payment to your lawyers Howmuch How do you transfer money to them A I dont have that figure oflhand A I dont know sir Can you give us any better figure than MR PIKE Form hundreds of thousands of dollars BY MR SCAROLA A No not sitting here today Pardon me Page Page Are you paying them on an hourly basis A I dont know A Yes sir Does someone do that on your behalf What is the hourly rate at which you are A I would guess so compensating members of the law firm Who A Theyre ordinary rates A I dont know What are they MR PIKE Form A I dont know BY MR SCAROLA How much have you paid Mr Goldberger Who are the people who are authorized to make A Im not aware total amount sir payment on your behalf What is the hourly rate at which youre paying A With respect to that question Im going to Mr Goldberger have to assert the Fifth Sixth and 14th Amendment sir A His normal hourly rate Are there any other elements of damage apart How much is that from the money paid to lawyers A I dont know A Yes sir How much have you paid Mr Black which you What claim as damages in this case A The stress and emotional damage of imperiling A Hundreds of thousands of dollars my friendships and business relationships with no Are you paying him on an hourly basis relevance whatsoever to these cases brought by a firm A I believe so that whose partner sits in a Federal prison who engaged What is the hourly rate in discovery to harass my friends and social contacts A Im not I do not know sir with no consideration or relevance to this case How much have you paid Marty Weinberger whatsoever in an attempt to simply fleece partly A I dont know the exact amount sir fleece investors in South Florida out of millions of Whats your best estimate dollars sir A More than a hundred thousand dollars What is the value of those losses Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page MR PIKE Form THE WITNESS Im not sure yet sir BY MR SCAROLA Do you have any idea at all A Not sitting here today More or less than MR PIKE Form THE WITNESS I would guess its more than sir BY MR SCAROLA 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 MR PIKE Form Mischaracterizes the witness testimony THE WITNESS No sir Thats not what I said I said I did not know BY MR SCAROLA Page Maybe more than a million A Maybe More or less than a billion MR PIKE Form THE WITNESS I dont know BY MR SCAROLA Maybe more than a billion A Maybe more 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 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 Page 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 BY MR SCAROLA 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 MR SCAROLA Lets take a short break We may be finished VIDEOGRAPHER We are now off the record at p.m Briefrecess VIDEOGRAPHER We are back on video record at p.m Page BY MR SCAROLA Do you attribute all of the damages that you have described to Mr Edwards conduct MR PIKE Form THE WITNESS As a participant I dont know how to proportion the conduct as opposed to Mr Edwards and his partner who sits in jail I guess the U.S Attorney will also make a decision to how much the conduct and proportion is relevant to both damages and anything else hes done in this case sir BY MR SCAROLA But Im not asking you about what the U.S Attorneys opinion is I want to know whether you hold Mr Edwards responsible for all of those elements of damage that you have described to us A Its a difficult question to answer Mr Scarola No its easy Yes no or I dont know MR PIKE Mr Scarola you know as well as I do the witness is attempting to answer your question MR SCAROLA I dont think so I think hes attempting to evade all of my questions Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page MR PIKE And I understand your contention However if you would allow Mr Epstein to finish his response THE WITNESS Could you repeat your question BY MR SCAROLA Do you hold Mr Edwards responsible for all of the damages that you have described MR PIKE Form THE WITNESS Its difficult for me to proportion the damages that I have described between Mr Edwards his partner who is currently in jail his the other people named in the Complaint Hopefully a jury will do that BY MR SCAROLA Do you hold L.M responsible for all of the damages you have described MR PIKE Form THE WITNESS Again these questions these ambiguous questions as opposed to who participated I would let Mr Edwards and his clients and his partners decide whose proportionate responsibility it is sir BY MR SCAROLA So you defer to them MR PIKE Form Page 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 sir BY MR SCAROLA Which partners A Beg your pardon 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 MR SCAROLA I have no further questions MR EDWARDS I have three or four questions Thats it MR PIKE Okay I just want to be clear for Page the record Mr Scarola represents Mr Edwards in this case is that correct Mr Scarola MR EDWARDS Thats correct MR SCAROLA Yes MR PIKE And in this particular case Epstein versus Rothstein et al Mr Edwards who do you specifically represent MR EDWARDS L.M MR PIKE Okay I believe that if you follow through with questioning you have an irreconcilable conflict with regard to the other case in which you represent L.M and L.M I cannot stop you from asking any questions however if you do move forward with asking questions I will take the appropriate action MR SCAROLA And on behalf on behalf of my client MR PIKE Yes sir MR SCAROLA we do not accept your assessment of Mr Edwards ethical responsibilities MR PIKE That is absolutely fine for you to do that I just wanted to put it on the record that I am by no means going to prevent you from questioning today However I wanted to put my Page contention on the record Okay CROSS EXAMINATION BY MR EDWARDS Mr Epstein is your sole basis for your claim against L.M that she changed her testimony from the time she testified to the FBI in MR PIKE Form To the extent you can answer that question without invading attorney/client work product you can do so THE WITNESS Unfortunately Id like to answer that question but I cant do so without invading attorney/client privilege BY MR EDWARDS Is there anything in L.M.s Complaint that was filed against you in September which you contend to be false MR PIKE Asked and answered THE WITNESS I recognize Mr Edwards again the concept of attempting me to get to waive my Fifth Amendment privilege however in this lawsuit Ive answered questions with respect to your lawsuit And with regard to the question you just asked Im going to have to unfortunately assert my Fifth Amendment Sixth Amendment and 14th Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page Amendment Right But Im willing to listen to any other questions you may have MR EDWARDS Finished MR PIKE I have a couple questions CROSS EXAMINATION BYMR.PIKE Mr Epstein earlier in the deposition Mr Scarola was reading from page of the Complaint filed in the Epstein versus Rothstein Rosenfeldt and Adler et al Do you recall that A Yes sir And then I showed you page of a Complaint that I had my notes on correct A Yes Did you read the black type or did you read the handwritten notes in the comers of the Complaint that particular page that I showed you A Unfortunately my eyesight is not good enough to read the notes I only read the black letter And it was that one sentence correct A It was two sentences I believe but yes MR PIKE Thank you Well read REDIRECT EXAMINATION BY MR SCAROLA What is your eyesight A Sorry What is your eyesight A My eyesight Page Yes sir You said that your eyesight was not good enough to be able to read the handwritten notations What is your eyesight A Are we on the record or off Were on the record MR PIKE Were on the record THE WITNESS I need glasses BY MR SCAROLA And you had those on when you were reading the Complaint didnt you A But these arent my sir What are they A I dont know Lets hand them over if you would Lets take a look at them A Sure Do you see anything No Is it your contention that those glasses were inadequate to enable you to read the handwritten Page notations on the Complaint MR PIKE Form Mischaracterizes testimony THE WITNESS My testimony was I only read the black letter and partially because I cannot see thoroughly through these glasses sir BY MR SCAROLA Is it your contention that those glasses did not sufficiently correct your vision to be able to read the handwritten notations on the papers that were handed to you MR PIKE Form THE WITNESS Again we can play this game back and forth What I just said and I think I was very clear that I did not read the notes I said BY MR SCAROLA What you said was you couldnt read the notes MR PIKE Allow the witness to finish THE WITNESS Let me finish And what I said was with these glasses it would be almost impossible for me to read the notes on the page BY MR SCAROLA Yes sir So your contention is that those glasses do not adequately correct your vision to be able Page to read the handwritten notations is that correct MR PIKE Form THE WITNESS In this particular instance sir these glasses did not Im not saying they cannot but did not allow me to read the notes thats correct MR SCAROLA I would like those glasses marked as an Exhibit to this deposition MR PIKE I dont think so MR SC ARO LA Youre refusing to allow that to happen MR PIKE I dont see how you can mark a set of glasses as an Exhibit to a deposition The witness has already said that he did not read the handwritten notes in the comer or the comers of page of the Complaint MR SCAROLA The witness is a liar The witness testimony is totally incredible The witness made up a response and I want to be able to demonstrate to the Court and jury that the witness lied when he said that those glasses did not correct his vision sufficiently to be able to read the handwritten notes I want the glasses marked as an Exhibit If you refuse to mark them I am placing you Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend Page Page on notice that they are relevant and material to CERTIFICATE issues involved in this lawsuit and need to be STATE OF FLORIDA COUNTY OF PALM BEACH preserved I Sandra Townsend Court Reporter and MR PIKE All right Well mark the glasses Notary Public in and for the State of Florida at Large Well mark the glasses as an Exhibit Okay And I do hereby certify that the aforementioned witness was by me first duly sworn to testify the whole truth that I will keep them here in my office was authorized to and did report said deposition in MR SCAROLA Thank you stenotype and that the foregoing pages numbered to inclusive are a true and correct transcription of MR PIKE Thats fine my shorthand notes of said deposition VIDEOGRAPHER This concludes todays I further certify that said deposition was videotaped deposition of Jeffrey Epstein The time taken at the time and place hereinabove set forth and is that the taking of said deposition was commenced and completed as hereinabove set out Exhibit number was marked for I further certify that I am not attorney or counsel of any of the parties nor am I a relative or identification purposes and retained by Counsel for employee of any attorney or counsel of party connected Plaintiff with the action nor am I fmancially interested in the action Witness excused The foregoing certification of this transcript Deposition was concluded does not apply to any reproduction of the same by any means unless under the direct control and/or direction of the certifying reporter Dated this 26th day of March A Sandra Townsend Court Reporter Job Page Page CERTIFICATE OF OATH DATE March STATE OF FLORIDA TO JEFFREY EPSTEIN Job c/o Michael Pike Esquire COUNTY OF PALM BEACH Banyan Boulevard Suite West Palm Beach Florida I INRE Epstein vs Edwards et al I the undersigned authority certify that JEFFREY EPSTEIN personally appeared before me and was CASE NO duly sworn on the 17th day of March Please take notice that on Wednesday the 17th of March you gave your deposition in the Dated this 26th day of March above-referred matter At that time you did not waive signature It is now necessary that you sign your deposition Please call our office at the below-listed number to schedule an appointment between the hours of a.m and p.m Monday through Friday at the Esquire office located nearest you If you do not read and sign the deposition within a reasonable time the original which has already been forwarded to the ordering attorney may be filed with the Clerk of the Court If you wish to waive Sandra Townsend Court Reporter your signature sign your name in the blank at the Notary Public State of Florida bottom of this letter and return it to us My Commission Expires Very truly yours My Commission No DD Job Sandra Townsend FPR PROSE COURT REPORTING AGENCY Australian Avenue Suite West Palm Beach Florida Phone I do hereby waive my signature JEFFREY EPSTEIN I do hereby waive my signature cc Via transcript All Counsel of Record file copy Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Sandra Townsend Electronically signed by Sandra Townsend CERTIFICATE THE STATE OF FLORIDA COUNTY OF PALM BEACH I hereby certify that I have read the Page foregoing deposition by me given and that the statements contained herein are true and correct to the best of my knowledge and belief with the exception of any corrections or notations made on the errata sheet if one was executed Dated this __ day of JEFFREY EPSTEIN Job Page ERRATA 4/mep JEFFREY EPSTEIN Plaintiff vs IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendant I DEFENDANT BRADLEY EDWARDS INTERROGATORIES TO PLAINTIFF JEFFREY EPSTEIN Defendant/Counterplaintiff Bradley Edwards hereby gives notice that pursuant to Rule Florida Rules of Civil Procedure that General Interrogatories numbered through have been directed to Plaintiff/Counterdefendant Jeffrey Epstein this LP ay of September Fax and U.S Mail to all Counsel copy of the foregoing has been furnished by z::-fr September ack ola Flo 1d ar No a Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard est Palm Beach Florida Phone Fax Attorney for Bradley Edwards Case No Bradley Edwards Interrogatories to Jeffrey Epstein COUNSEL LIST Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Gary Farmer Esq Farmer Jaffe Weissing Edwards Fistos Lehrman PL Andrews Avenue Suite Fort Lauderdale FL Phone Fax Christopher Knight Esq Joseph Ackerman Esq Fowler White Burnett P.A Flagler Drive Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esq Law Offices ofMarc.S Nurik One Broward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein Case No Bradley Edwards Interrogatories to Jeffrey Epstein DEFENDANT/COUNTERPLAINTIFF BRADLEY EDWARDS INTERROGATORIES TO PLAINTIFF/COUNTERDEFENDANT JEFFREY EPSTEIN If answering for another person or entity answer with respect to that person or entity unless otherwise stated I What is the full name and Florida address of the person answering these interrogatories and if applicable the persons official position or relationship with the party to whom the interrogatories are directed What is your best estimate of the number of minor females with whom you have had physical contact in the last years when at the time of the physical contact a your genitals were exposed the genitals or breasts of the minor female were exposed the minor female was clothed only in underwear minor females is defined as females who were known by you at the time or who are now known to you to have been under years of age at the time of your interaction with them and females who you now have reason to believe may have been under years of age at the time of your interaction with them Case No Bradley Edwards Interrogatories to Jeffrey Epstein What is your best estimate of the number of times in the last years when you have had physical contact with minor females when at the time of the physical contact a your genitals were exposed the genitals or breasts of the minor female were exposed the minor female was clothed only in underwear What is your best estimate of the number of times you have witnessed Ghislaine Maxwell engage in sexual activity with minor females What is the total obligation that has been incurred to date for both fees and costs both paid and currently owing in connection with your representation in this lawsuit sexual activity for purposes of these interrogatories means any physical contact with the genitals or exposed breasts of another person Case No Bradley Edwards Interrogatories to Jeffrey Epstein With regard to the last time you engaged in sexual activity with a minor state the following a the identity of the minor name and last lmown address the date the location a description of the sexual activity 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 Describe in your own words all interaction you have had with the individual identified in this action as L.M including but not limited to the dates places participants in witnesses to and a description of all sexual activity involving L.M Case No Bradley Edwards Interrogatories to Jeffrey Epstein What is the name and last known address of eery healthcare provider with whom you have treated or been evaluated for any sexual disorder List all former names and when you were known by those names State all addresses where you have lived for the past years the dates you lived at each address your Social Security number and your date of birth Have you ever been convicted of a crime other than any juvenile adjudication which under the law under which you were convicted was punishable by death or imprisonment in excess of I year or that involved dishonesty or a false statement regardless of the punishment If so state as to each conviction a The specific crime The date and place of conviction Case No Bradley Edwards Interrogatories to Jeffrey Epstein List the names and addresses of all persons who are believed or known by you your agents or attorneys to have any knowledge concerning any of the issues in this lawsuit and specify the subject matter about which the witness has knowledge Have you heard or do you know about any statement or remark made by or on behalf of any party to this lawsuit other than yourself concerning any issue in this lawsuit Ifso a State the name and address of each person who made the statement or statements State the name and address of each person who heard it State the date time place and substance of each statement Case No Bradley Edwards Interrogatories to Jeffrey Epstein State the name and address of every person known to you your agents or attorneys who has lmowledge about or possession custody or control of any physical evidence model plat map drawing motion picture video tape or photograph pertaining to any fact or issue involved in this controversy and describe as to each what such person has the name and address of the person who took or prepared it and the date it was taken or prepared Have you made an agreement with anyone that would limit that partys liability to anyone for any of the damages sued upon in this case If so state the terms of the agreement and the parties to it Case No Bradley Edwards Interrogatories to Jeffrey Epstein Please state if you have ever been a party either plaintiff or defendant in a lawsuit other than the present matter and if so state whether you were plaintiff or defendant the nature of the action the date and court in which such suit was filed the nature of the disposition of each matter and if the matter has been settled describe all terms and conditions of the settlement including the nature and amount of all consideration paid by you or on your behalf in connection with each settlement STATE OF COUNTY OF __ The foregoing instrument was acknowledged before me this day of by who is personally known to me or who has produced as identification and who did did not take an oath SEAL Notary signature Notary name print NOTARY PUBLIC State of Florida Serial number if any JEFFREY EPSTEIN Plaintiff/Counter-Defendant SCOTT ROTHSTEIN Individually BRADLEY EDWARDS Individually and L.M Individually Defendants/Counter-Plaintiffs __ IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Complex Litigation Fla.R.Civ.Pro Case No PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEINS OBJECTIONS TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS GENERAL INTERROGATORIES DATED SEPTEMBER Plaintiff/Counter-Defendant Jeffrey Epstein by and through his undersigned counsel and pursuant to Florida Rules of Civil Procedure files his objections to the General Interrogatories of Defendant/Counter-Plaintiff Bradley Edwards and would state as follows With regard to Interrogatories and the Plaintiff/Counter Defendant objects because the interrogatories seek irrelevant information are burdensome are propounded for the purpose of harassment and ask for information which is protected by the Fifth Amendment of the United States Constitution With regard to Interrogatories and the interrogatories seek information that is irrelevant burdensome to produce and unlikely to lead to discoverable information Epstein Rothstein et al Case No CA Epsteins Ans to Edwards General Interrogatories With regard to Interrogatory No the Plaintiff/Counter-Defendant objects on the grounds that the information is protected by work product and attorney-client privilege at this time CERTIFICATE OF SERVICE I HEREBY CERTIFY that a tru and correct copy of the foregoing has been duly furnished via Facsimile U.S Mail Hand Federal Express this day of October to Jack Scarola Esq Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Blvd West Palm Beach FL Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian A venue South Suite West Palm Beach FL Marc Nurik Esq Law Offices of Marc Nurik One Broward Blvd Suite Ft Lauderdale FL Yj/_ eph Ac erman Jr a Bar No FOWLER WHITE JEFFREY EPSTEIN Plaintiff vs IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendant I NOTICE OF SERVICE OF INTERROGATORY TO JEFFREY EPSTEIN Bradley Edwards hereby gives notice pursuant to Rule Florida Rules of Civil Procedure that an Interrogatory has been directed to Jeffrey Epstein this to1v--ray of August It is requested that the aforesaid answers be served within thirty days at the offices of Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida 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 245.ugust l_;c-iL Floiid ar Prim mail jsx searcylaw.com Sec E-mail mep searcylaw.com Se cy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorneys for Bradley Edwards Edwards adv Epstein Notice of Service oflnterrogatory to Jeffrey Epstein Case No COUNSEL LIST Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian A venue South Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Bradley Edwards Esquire staff.efile pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehrman FL North Andrews A venue Suite Fort Lauderdale FL Phone Fax Fred Haddad Esquire Dee FredHaddadLaw.com haddadfm aol.com Fred Haddad P.A One Financial Plaza Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com Law Offices of Marc Nurik One Broward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein Tonja Haddad Coleman Esquire tonja tonjahaddad.com Debbie Tonjahaddad.com Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Edwards adv Epstein Notice of Service of Interrogatory to Jeffrey Epstein Case No INTERROGATORY TO JEFFREY EPSTEIN If answering for another person or entity answer with respect to that person or entity unless otherwise stated 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 267contents of the communication were ever memorialized in any manner and if so the identity of everyone having custody of such memorialization 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 I a detailed description of the contents of the communication all participants in and parties to the communication Edwards adv Epstein Notice of Service oflnterrogatory to Jeffrey Epstein Case No 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 In the event that you claim that any responsive information sought by these interrogatories is privileged identify every privilege pursuant to which you claim protection STATE OF COUNTY OF Tue foregoing instrument was acknowledged before me this day of by who is personally known to me or who has produced as identification and who did/did not talce an oath SEAL Notary signature Notary name print NOTARY PUBLIC State of Florida Serial number if any IN COUNTY JEFFREY EPSTEIN Plaintiff/Counter-Defendant vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually Defendant/Counter-Plaintiff IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT AND FOR PALM BEACH FLORIDA Case No CA PLAINTIFF/COUNTER-DEFENDANT EPSTEINS AMENDED RESPONSES TO INTERROGATORIES Plaintiff/Counter-Defendant Jeffrey Epstein Epstein by and through his undersigned counsel and pursuant to this Courts order and Rule of the Florida Rules of Civil Procedure hereby files his amended responses to Defendant/Counter PlaintiffBradley Edwards Interrogatories to Jeffrey Epstein as follows 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 As per the trial courts order and pending hearing Epstein is not responding as to any communication that may have occurred with counsel 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 words I never had any conversation regarding the propriety of filing suit against Rothstein and Edwards with anyone other than my counsel which would require the disclosure of information that is protected by the attorney/client privilege United Services Auto Ass Roth So 2d Fla 4th DCA Nevin Palm Beach County School Bd So 2d Fla 1st 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 ANSWER No such non-privileged communication occurred In other words I never had a conversation as delineated above with anyone other than my counsel which would require the disclosure of information that is protected by the attorney/client privilege United Services Auto Ass Roth So 2d Fla 4th DCA Nevin Palm Beach County School Bd So 2d Fla 1st DCA Accordingly I assert the attorney/client privilege as provided for in oftheFlorida Statutes WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below via Electronic Service this November Isl Tonja Haddad Coleman Tonja Haddad Coleman Esq Fla Bar No LAW OFFICES OF TONJA HADDAD PA SE th Street Suite Fort Lauderdale Florida facsimile Tonja tonjahaddad.com STATE OF NEW YORK COUNTY OF NEW YORK Before me the undersfgoed authority this day personally appeared Jeffrey Epstein who being ptxSOnally known to me and who first bemg duly sworn says that he has read the foregoing Amended Rcsponset To lntcm,gatories and that all of the ms.ucrs therein are true and correct this November NOTARY PUBLIC STATE OF NEW YORK SERVICE LIST CASE NO Jack Scarola Esq jsx searcylaw.com mep searcylaw.com Searcy Denney Scarola et al Palm Beach Lakes Blvd West Palm Beach FL Jack Goldberger Esq jgoldberger agwpa.com smahoney agwpa.com Atterbwy Goldberger Weiss PA Australian Ave South Suite West Palm Beach FL Marc Nurik Esq East Broward Blvd Suite Fort Lauderdale FL Bradley Edwards Esq brad pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehrman Andrews Avenue Suite Fort Lauderdale Florida Fred Haddad Esq Dee FredHaddadLaw.com 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