October and November While in his original Counterclaim filed December Edwards alleged that Epsteins Complaint was nothing more than a press release D.E in his October Amended Counterclaim and November Second Amended Counterclaim he characterized it as a highly defamatory press release D.E D.E January In Answers to Interrogatories Edwards stated that Bradley Edwards has described the special damages he has sustained and will continue to sustain in the future in his currently pending counterclaim He has been falsely accused of immoral unethical and illegal conduct impugning his professional integrity his professional competence and his fitness to practice law Such accusations are defamatory per se and Florida law conclusively presumes the damages that inevitably arises from such defamation The false accusations have been disseminated repeatedly throughout not only the South Florida legal community but nationally and internationally Ex A No e.s In addition in response to the interrogatory asking Edwards to explain the basis of his claim that his reputation had been injured he simply responded Defamation per se Ex A No e.s To another request Edwards responded Epsteins malicious unsupported unsupportable false accusations of Bradley Edwards knowing involvement and active participation in a massive Ponzi scheme singled Mr Edwards out from among all other innocent RRA employees Those accusations were the only source falsely linking Bradley Edwards to Rothsteins criminal enterprise and absent those allegations there is no basis to believe that Bradley Edwards impeccable professional reputation would have been tarnished by his brief employment with Rothstein Rosenfeldt Adler Ex A No May and January In his Third and Fourth Amended Counterclaims Edwards continued to characterize Epsteins Complaint as a highly defamatory press release D.E e.s D.E e.s September In recent Answers to Interrogatories Edwards continued to base his claims on alleged defamatory statements The allegations of Epsteins maliciously filed Complaint are defamatory per se Ex No e.s October In opposition to Epsteins Motion to Stay Edwards referenced Epsteins alleged malicious lies the poisonous effects of Epsteins malicious lies about Edwards remain judicially unremedied Edwards is entitled to his day in Court to publicly prove that the scurrilous claims made by Epstein were nothing but a baseless attempt at extortion D.E e.s November Edwards testified at his deposition that there still looms this false allegation over my head Ex e.s Edwards claimed that his reputation suffered damage that unless and until a jury returns a verdict in my favor cant be undone Ex WEAK An Opinion or a Verifiable Statement Fact In the recent hearings before this Court Edwards has focused in large part on Epsteins allegation in the original Complaint that Edwards clients cases were weak D.E I42h Tr But the fact of the matter is that Bradley Edwards was sued for ginning up fabricating constructing those three cases and others as a knowing participant in Floridas largest Ponzi scheme Tr This Court commented during dialogue with counsel that the allegations in the original Complaint said weak The allegation in subparagraph Rothstein and the litigation team knew or should have known that their three filed cases were weak and had minimal value Tr Epsteins allegation however is nothing more than the authors subjective belief of the economic value of the three civil cases The view that something is weak falls within the classic definition of an opinion is not a statement of fact and thus is not actionable even if this was a defamation case Zorc Jordan So 2d Fla 4th DCA A false statement of fact is absolutely necessary ifthere is to be recovery in a defamation action Fid Warranty Services Inc Firstate Ins Holdings Inc So 3d Fla 4th DCA A party cannot recover for defamation based on statements which are pure opinion Consistent with Edwards testimony pleadings argument and now damages expert there can be no question Edwards is attempting to clear his name by proving that individual allegations pied by Epstein in the original civil proceeding against Edwards were false The cherry-picking of individual statements in one entire original civil proceeding to determine the truth or falsity of any statement is appropriate for a defamation action not a malicious prosecution action governed by the existence of probable cause to initiate an original civil Excerpts of the November hearing transcript are attached as Exhibit proceeding Of course defamation for the complaints allegations is barred by the absolute litigation privilege Therefore Edwards continually attempts to morph an element from the tort of defamation whether any given statement pied by Epstein was true/false and made with good/bad motives and superimpose the defamation element onto his onerous burden of proving the lack of probable cause If allowed this would be reversible error Edwards Expert has no Opinion on Damages The error is compounded by the fact that Dr Jansens testimony is focused on simply identifying internet sources that published articles that mentioned Edwards and Rothstein without regard to the actual damages proximately caused by the malicious prosecution if any Edwards in this one count malicious prosecution action can only recover actual damages Edwards may take the position that if he has no actual damages then he is entitled to nominal damages i.e Dr Jansens testimony is not helpful to the trier of fact as required by section Florida Statutes for either category of damages No Testimony Related to Actual Damages Dr Jansen did not testify about any actual proximately caused damages Edwards expert could not and did not opine that Edwards reputation was harmed that Edwards has made less money or even that he has suffered attorneys fees damages as a result of the original civil proceeding Dr Jansen candidly admitted he had performed zero research on the impact the defamatory statements had on any of the readership or what opinions were formed Simply Dr Jansen offers nothing to assist the trier of fact or even support Edwards claim of damages Florida Standard Jury Instruction Civil Issues on Plaintiffs Claim Defamation allowable under Florida Standard Jury Instructions for malicious prosecution and Florida law reasonable expenses including lawyers fees injury to reputation mental anguish Perhaps even more compelling Dr Jansens research revealed only the number of hits a particular publication or news media outlet on the internet received by a reader over an average period of days covering when a Rothstein article was published Jansens Tr Ex Critically his research did not reveal what the viewer read on a particular website i.e whether it was an article involving Rothstein stock prices or pictures from the most recent Palm Beach gala Jansens Tr Ex Rather Dr Jansen testified that his calculation of the number of hits based on a day an article was published reflected the daily traffic that that particular site received Id When questioned further it turned out that the hits were not for an actual day but were an average over a week or month or something like that because you cant look at a particular date Id Dr Jansen candidly admitted that the trafficking services he used provide an average readership over a period of time and the exact readership numbers are not typically available for the individual articles Id at Clearly this guesswork testimony does not relate to actual damages when there is no concrete nexus between the internet hit and someone reading or even glancing at the actual article referencing Rothstein and Edwards How could it when it is an average over time for a particular media outlet website This testimony fails to meet a basic section relevance test Edwards also alleges special damages of fear of physical injury to himself and members of his family the loss of the value of his time required to be diverted from his professional responsibilities in his Fourth Amended Counterclaim but these are unsupported by Florida law D.E at See Ware United States Supp M.D Fla and Burchell Bechert So 2d Fla th DCA Expert Testimony Unnecessary for Nominal Damages and Sub;ect to Balancing Recognizing the missing link of actual damages in Dr Jansens testimony Edwards fallback damages position is that even without actual damages he is entitled to seek the recovery of nominal damages i.e If the recovery of nominal damages is even allowed by this Court Dr Jansens testimony is prejudicial and certainly not helpful to the trier of fact For nominal damages of the nine million hits testimony offers nothing of assistance for a jury Rather the inflammatory testimony is subject to a section balancing analysis Section Florida Statutes provides that Relevant evidence is inadmissible if its probative value is substantially outweighed by the danger of unfair prejudice confusion of issues misleading the jury or needless presentation of cumulative evidence Here even ifthere is any tangential relevance to Dr Jansens counting exercise the probative value is far outweighed by the unfair prejudice of saying the words nine million hits In reality Dr Jansen cannot identify a single person who read anything about Edwards The only reason for Edwards to submit this testimony is to inflame the jury and prejudice them into thinking the nine million hits to a website equated to nine million people who read the Rothstein article changed their mind and did not hire Edwards or now think he was engaged in a Ponzi scheme with Rothstein But none of these conclusions were drawn by Dr Jansen and his internet counting Simply Edwards has a failure to connect the causation dots necessary to prove damages and wants to use the inflammatory and irrelevant testimony of Dr Jansen to prejudice or confuse the jury about damages As indicated above Dr Jansens testimony only counted hits to a publications website not actual readers of the article found referencing Rothstein and Edwards To allow this irrelevant confusing prejudicial testimony would constitute reversible error Edwards Admissions of No Reputational Damage Furthermore Edwards has testified that he has resurrected any damage that was done to his reputation On August Edwards counsel Jack Scarola made a public statement to the media which he believes was successful in discrediting Mr Epsteins charges Jansens Tr Ex With respect to reputation I believe that over the course of the last three years I have done a pretty darn good job resurrecting any damage that was done to my reputation in this community Edwards Tr Ex Do I believe that right now my reputation is better than it has been at any time in the past yes Edwards Tr Ex I have done a good job of resurrecting my reputation from the point in time where people initially believed hey where there is smoke there is fire or something this guy must be guilty of something Edwards Tr Ex As I said then have I done a good job at resurrecting whatever damage was done Yes I did Edwards Tr Ex I have not claimed an economic loss as a result of my reputation Edwards Tr Ex Dr Jansen Does Not Meet Section Dr Jansens testimony must be precluded because it has no relevance in this malicious prosecution action and only further stretches Edwards flawed defamation action not pied and not allowed Dr Jansen admitted that he was instructed by Edwards and his counsel to look for defamatory statements Because Edwards expert did not testify to damages at all his irrelevant testimony has a real danger of confusing the jury Simply Dr Jansens op1mon provides no legitimate expert testimony for the jury to consider in this action Epstein asks this Court to strike Dr Jansen from Edwards expert witness list and preclude his trial testimony RECORD FACTS On October almost eight years after filing his Counterclaim Edwards disclosed Dr Jansen for the first time on his Sixth Amended Witness List with no explanation as follows EXPERT Bernard Jansen Ph.D D.E The Courts July Order Specially Setting Jury Trial required the following information at the time of listing the expert The subject matter about which the expert is expected to testify The substance of the facts and opinions to which the expert is expected to testify A summary of the grounds for each opinion A copy of any written reports issued by the expert regarding this case and A copy of the experts curriculum vitae D.E Edwards produced Dr Jansens report on October a copy of which is attached as Exhibit Dr Jansen was tasked to respond to the following question What is the level of dissemination of defaming statements associating Mr Bradley Edwards with the illegal activities of Mr Scott Rothstein as a result of Mr Jeffrey Epsteins lawsuit against Mr Edwards Ex e.s Dr Jansen disclosed that he simply calculated the number of internet hits which associated Edwards with Rothstein In focusing his analysis to online dissemination of the defamatory statements Dr Jansen reached the following opinion The defaming statements associating Mr Bradley Edwards with the illegal activities of Mr Scott Rothstein as a result of Mr Jeffrey Epstein lawsuit against Mr Edwards have been disseminated to at least online media or other sites in separate stories or articles with a combined potential daily visitors since the lawsuit was filed to the date that I filed this report inclusive Ex e.s Dr Jansen did not even consider who was responsible for disseminating information to the press In other words did Epstein issue a press release Did Edwards comment to the press Did Edwards contact the press Did Epstein contact the press Simply put who disseminated to the press the alleged defamatory statements Nowhere in Dr Jansens report does he opine on the impact to Edwards reputation or character nor does he mention Edwards shame humiliation mental anguish or hurt feelings Finally Dr Jansen does not reference how much Edwards spent on attorneys fees in connection with the original civil proceeding Edwards himself is confused about the information Dr Jansen collected He testified at his November deposition that Dr Jansens report was based on quantifying the number of people who had seen articles associating him with derogatory and defamatory statements Edwards Tr Ex Nothing is further from the truth Dr Jansen testified at his deposition taken on December that his opinion reached in this case was that the defamatory statements against Mr Edwards linking into the Ponzi scheme of Mr Rothstein were disseminated to different media sites in different articles to daily media visitors Jansens Tr e.s Ex Dr Jansen calculated the number of times Edwards and Rothsteins names were together in an article but had no opinion regarding whether anyone actually read the articles or of any damages suffered by Edwards Ex In fact Dr Jansen conceded he performed no research into what impact if any the number of publications had on anyone Okay Did you do any research to see what impact the statements had on any of the readership A No Did you do any research into whether what opinions were formed about Mr Edwards by anyone who read any of the articles A No Did you do any research into whether the impact on the readership in forming an opinion about Mr Edwards was different after Mr Scarola made his statements in to the press A No When you did your research did you interview any readers that actually read one of the articles that you cite to in your report A No Jansens Tr Ex Dr Jansen could not even identify one person who actually read any of the publications right Can you identify one person that actually read one of the articles A I didnt look for a person so no Jansens Tr Ex Finally although Dr Jansen used the term defamatory statements and plugged in statements provided to him by either Mr Edwards or Mr Scarola he never made any determination of what was defamatory or not Jansens Tr Ex Candidly Dr Jansen testified Right So the person who made the decision to label whatever statements you researched defamatory was not you A Whether they were defamatory or not was not my decision Id at He clarified that I did an IT investigation Youre asking me kind of a legal question Id Again Dr Jansen confirmed his opinion had nothing to do with evaluation or analysis of whether any statement was defamatory or not Right Okay And so whether or not that statement was defamatory or not is not an analysis you engaged in A The defamatory part no Id at If the word defaming was removed from the task given to him it would not change his work of calculating the number of times he found statements regarding Edwards Id at APPLICABLE LAW I Litigation Privilege Precludes a Defamation Action Against Epstein The law has long recognized that judges counsel parties and witnesses should be absolutely exempted from liability to an action for defamatory words published in the course of proceedings regardless of how false or malicious the statements may be Debrincat Fischer So 3d Fla e.s Because of this Epstein cannot be sued for the claimed falsehood of any allegation pied in his original civil proceeding or any of the amendments filed against Rothstein and Edwards II Malicious Prosecution Action Focuses on Original Civil Proceeding Not Hand Picked Allegations Because of the established litigation privilege Edwards necessarily pied but does not really want to try the tort of malicious prosecution Although the tort of malicious prosecution has an ancient existence in the state of Florida the elements have not changed Compare Tatum Bros Real Estate Inv Co Watson So Fla and Debrincat supra To prevail in a malicious prosecution action a plaintiff must establish an original civil proceeding present defendant was the legal cause of the original proceeding termination of the original proceeding constituted a bona fide termination of that proceeding in favor of the present plaintiff an absence of probable cause for the original proceeding malice on the part of the present defendant and damages as a result of the original proceeding Debrincat So 3d at e.s Based on this longstanding Florida jurisprudence there can be no narrow focus in this action on a single count a hand-picked allegation or a segregated paragraph in the original proceeding or even a statement made or published in the press or on the internet to determine if it was false or true Rather this Court is bound by established law to focus on whether probable cause existed for Epstein to file the original proceeding I Damages in a Civil Malicious Prosecution Action are Not Presumed The gravamen of a malicious prosecution claim is injury to character Cate Oldham So 2d Fla A malicious prosecution plaintiff may recover damages to a person property or reputation shown to have proximately resulted from a previous civil or criminal proceeding Tatum Bros Real Estate Inv Co Watson Fla Next a malicious prosecution plaintiff may recover damages for his shame humiliation mental anguish and hurt feelings Ware United States Supp M.D Fla Shame humiliation mental anguish and hurt feelings flowing from plaintiffs prosecution are legitimate grounds for monetary relief in an action for malicious prosecution citation omitted Third a malicious prosecution plaintiff is entitled to the attorneys fees he incurred in connection with the underlying action See Burchell Bechert So 2d Fla 4th DCA summary judgment improper where plaintiff had incurred attorneys fees in underlying action It is basic hombook law that in an action for malicious prosecution the plaintiff may recover all damages that are the natural and probable consequences of the action complained of but the damages must be certain and proximate and not uncertain contingent or speculative Ware United States Supp M.D Fla citations omitted Moreover unlike a criminal malicious prosecution action where a malicious prosecution for criminal prosecution can be actionable per se a plaintiff in a civil action must prove the damages sought See Adler Segal So 2d Fla 3d DCA malicious prosecution action based on acquittal in underlying criminal prosecution court held that there is substantial authority that a malicious prosecution is actionable per se and certain kinds of damage necessarily follow from the wrongful prosecution itself and so will be assumed by the law to exist citing Tidwell Witherspoon Fla Fla An accusation of crime under the forms of the law or a pretense of bringing a guilty man to justice is made in the most imposing and impressive manner and may inflict a deeper injury upon the reputation of the party accused than the same words uttered under any other circumstances see also Restatement First of Torts comment a The institution of criminal proceedings necessarily carries with it a defamatory accusation of criminal conduct and the rules which determine the right to recover for the resulting harm to reputation and distress are the same as those applicable in actions for defamation compare Burchell Bechert So 3d Fla th DCA applying Adlers holding but dicta because court already determined damages element met by record evidence of attorneys fees incurred in defending the lawsuits A Dr Jansen Failed to Provide Any Opinion on Actual Damages in a Malicious Prosecution Action The Florida cases cited in Section I outline the damages allowed in a civil malicious prosecution action Dr Jansen failed to opine on any of these categories Significantly Dr Jansen offered no opinion on reputational injury because he had no knowledge regarding whether there was any impact on the readership in forming an opinion about Edwards Jansens Tr Ex Likewise he offered no opinion regarding whether the original civil proceeding caused Edwards shame humiliation mental anguish and hurt feelings He had no opinion of harm to Edwards reputation loss of business client departures or any other category of potential damage Finally Dr Jansen certainly had no opinion regarding Edwards incurring attorneys fees Rather Dr Jansen performed in his own words an IT investigation simply calculating by internet searches how many times the statements given to him by Edwards or his counsel appeared Jansens Tr Ex This fails to meet Edwards burden of proving malicious prosecution damages and provides no testimony helpful to the trier of fact Dr Jansens Testimony Fails to Assist the Trier of Fact if Allowed to Consider Nominal Damages in a Malicious Prosecution Action Epstein by no means abandons his opposition to Edwards argument of nominal damages a malicious prosecution action In fact the Florida Standard Jury Instructions confirm Epsteins position that while nominal damages are awardable in a defamation action they simply do not exist in a malicious prosecution action However Epstein points out that if this Court allows this argument to be presented to the jury Dr Jansen provides no helpful testimony or opinions none are needed for nominal damages Epstein will be unfairly prejudiced if Edwards is allowed to present expert evidence concerning the number of potential visitors to a website in order to establish nominal damages under section Florida Statutes If you find for claimant but find that no loss injury or damage has been proved you should may award nominal damages Nominal damages are damages of an inconsequential amount which are awarded to vindicate a right where a wrong is established but no damage is proved IV Section Florida Statutes Governs Expert Witness Testimony and Dr Jansen Fails to Meet the Threshold Requirement of Assisting the Trier of Fact or Determining a Fact in Issue A trial court has wide discretion in determining which matters are proper subjects of expert opinion testimony Bryant Buerman So 2d Fla th DCA However that discretion is not without limits Nathanson Hauss So 2d Fla 4th DCA Relevant evidence is evidence tending to prove or disprove a material fact and is generally admissible Fla Stat The concept of materiality is included within the section definition ofrelevancy the evidence must tend to prove or disprove a material fact Jordan ex rel Shealey Masters So 2d Fla th DCA When evidence is offered to prove a fact which is not a matter in issue it is said to be immaterial Id Finally relevant evidence is inadmissible if its probative value is substantially outweighed by the danger of unfair prejudice confusion of issues misleading the jury or needless presentation of cumulative evidence Fla Stat Edwards submits Dr Jansen as a damages expert However Dr Jansen fails to assist the trier of fact in understanding the evidence or in determining a fact in issue a threshold requirement for expert testimony to be admissible See Fla Stat Even if qualified in his area of expertise for an experts opinion to be admissible it must tend to prove or disprove an issue in dispute Unless Dr Jansens opinion is relevant to a fact or issue in the case it is inadmissible See Sunbeam Television Corp Mitzel So 3d Fla 3d DCA As a threshold matter the experts opinion must be relevant that is the evidence must prove or tend to prove a fact in issue Providing no opinions regarding actual or nominal damages Dr Jansen must be stricken as a witness and his testimony precluded CONCLUSION Edwards has no actual damages That is why he wants to try a per se defamation action However the litigation privilege is absolute and bars a defamation suit Here Edwards tried to use Dr Jansen to say Edwards reputation has been harmed by defamatory statements that he found on the internet yet he could not opine if the statements were in fact defamatory He wants to put before the jury that nine million viewers all thought horrible things about Edwards yet he could not say who disseminated the alleged defamatory statements Importantly Dr Jansen cannot opine if anyone read the articles or if the publications had any impact on the readership in forming an opinion about Edwards or if the articles caused any compensable damages Clearly Dr Jansen has no relevant testimony that would be helpful to the trier of fact Therefore Epstein respectfully requests that this Court strike the report and exclude Dr Jansens testimony CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on January through the Courts e-filing portal pursuant to Florida Rule of Judicial Administration LINK ROCKENBACH PA Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Angela Many FBN Primary Scott linkrocklaw.com Primary Kara linkrocklaw.com Primary Angela linkrocklaw.com Secondary Tina linkrocklaw.com Secondary Eservice linkrocklaw.com Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Jack Scarola Searcy Denny Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach FL mep searcylaw.com jsx searcylaw.com scarolateam searcylaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Nichole Segal Burlington Rockenbach P.A Courthouse Commons Suite West Railroad A venue West Palm Beach FL njs FLAppellateLaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Marc Nurik Edwards Pottinger LLC Law Offices of Marc Nurik Andrews A venue Suite One Broward Boulevard Suite Ft Lauderdale FL Ft Lauderdale FL brad epllc.com marc nuriklaw.com staff.efile pathtojustice.com Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Jack A Goldberger Atterbury Goldberger Weiss P.A Australian Avenue Suite West Palm Beach FL goldberger agwpa.com smahoney agwpa.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein EXHIBIT A JEFFREY EPSTEIN Plaintiff vs SCQTT ROTHSTEIN individually BRADLEY EDW ARDS individually and L.M individually Defendant I IN THE CIRCUIT COURT OE THE FIFTEENT.IlJUDICIAL CIRCUIT IN AND F0RPALM BEACH COUNTY FLORIDA CASE NO NOTICE OF SERVING ANSWERS TO PLAINTIFFS THIRD Edwtfrds adv Epstein Case Nb Answers fo 267PfoinUffls ThhdSci finierrogalorics.fo a lwnrds Jack A Goldbetger,Bsquire AXtcr.b.ury ldbetger Weiss P.A ralian A venue Sotit9 265ite West Palm Beach,.FL h.onc Fnx Attor11eys for cffl pstein COUNSEL LIST armet Jaffe Weiss.fog cdwatcl st9s rwn1j PL Andrew Avcnuer:Suite Fort Luud rdak FL Phone Fnx i 267oseph Ackerman Jr Esqulre Fower White Bi1rneft R.A Phillips Point-West glet:Or.ive West Palin ch FL Plione Fax Att,Othey.s:fol effrey Epstein Mntc Nurik Esquire taw:Officesofl ilarcS/Nurik On a B.rpward Blvd Suite7.0,0 FoflLaud tdale FL Phpne s.n.4sx Fax S4 5f Attorneys fo!Sco.tt 267Rothstoih I ANSWERS TO.PLAINTIFFS THIRD in response to Epsteins Requestto Produce Those darriag are ongoing and continuing in nature Explain in detail how your reputation llas been injured as a directresult of this action against you froin the filing of this actiori to the preserit With specificity identify the following a Your alleged reputation prior to the filing of this action Any arid all persons who hav inade statements abm1t your reputation after the filing of this action Any and all communications whether verbal or 267writte1i made about your 267reputation and The date manner and substance of communications in which said statements have been made:about yourreputation ANSWER See above a Excellent None are presently known except Epstein and h1s nun1erous iawyers including the attorneys presently engaged tn advancing Epsteins malicious.prosecution of Edwards and his extortionate abuse of process See 2b above See the pleadings filings and on-tlie-record sfatem 267ei:its made in this case and the RRA.bat1lQUptcyproceedings Explain in.detailhow the filing:ofthis action against you lia:s interfered With your professional relationships and for each such relationship a iden ify its nature and the perso11 with whqm you have or had the relationship specify exactly howtherelationship has been interf red with identify each person with knowledge ofthe.iriterference and identify actual damages as a resuit ofsucfrinterference ANSWER See answer to above Persons with icrfowledge of the interference inch1d_e the parties to this action all present and prior attorneys of record all persons the certificate of servi9e of Epsteins Motion to Depose Rothstein filed in the RRA bankruptcy proceedings al,l attorneys judges and observers in Court on every occasion that argumenlhas beenprescnted in support of Epsteins spurious claims against Edwards all persons exposed to media coverage of Epsteins spurious c1airns against Edwards Actual damages sustainedbyEdwards includ the costs incurred in defending against Epsteins outrageous.misconduct the.value of Edwards diverted time and attention tlie value of CQmpensatio:n for the injury to Edwards_ professional repufa as liquidated by ajury Identify each and every witness that has _knowledge of the damages you seek to recovetJn this action including but not limited to your mployer your partners your family members associates colleagues refen-al sources arid clients and for each describe the nature of his or her knowledge ANSWER Steve jaffe 267Gary Fanner Seth Lehrman have lmowledge of the extent to which Bradley Edwards time and attention were divertedbyEpstein fromgainfufprnfessional pursuits Bradley Edwards Professional reputation competence integrity and character FonnerFcdetal Judg PaulCassellhas knowledge of the same matters des 242ribed above Earleen Cote Esq has Imowledge of the same matters described above plain the basis for your claim that.your re,P.utation has been injured by tlie allegations again.st you in this action ANSWER Defamation p.tii:ii Explain the method by which you have distinguished injury to your reputation resulting directly from allegations againstyou in.this action from injury to your reputation resulting from your having been a partner it he defunct 261inn of.Rothstein Rosenfeldt Adler ANSWER rn.Qstein malicious unsupp Y!!fil!pportable false accusations of BradleY Edwards knowing involvement and active Qarticl,P.ation in a massive Ponzi scheme singled Mn Eawmlsouffromamong allotlier innocent RRAemployees Those accusations wereJhe only source falseli lilang Bnfrlley Edwar to Rothsteins criminal enter_i rise,_and aosent tliose allegations tfiere is no basis fo believe that Bradl Edwards 267imQec Professional re utation woulo have been tarnished by his brief_employmenLwith RolhsfeinRoseiifelat A:o lhdeed the vast majority of RR.A employees wer presumed innocent and have escaped any taint from their employment with the firm Identify all fees and costs that you have incurred for the defense of this action against you ANSWER See Bradley Edwards contemporaneous production If you have a written engagement agreement with the firm bf Searcy Denney Scarola Barnhaii Shipley P;A.describe the date of the agreement the scope of services and the tenns.on which your counsel are fobe compensated ANSWER See Bradley Edwards contemporaneous production If you _do not have a written engagement agreement with the firn1 of Searcy Denney S9arola Barnhart Shipley P.-A describe the tenns of your oral represchtation agreement the scope of se_rvices _and the terms on which your counsel are fo be compensated ANSWER NIA Identify any other attorney and firm with whom you have anyrelatfonship in conilection with your defense of this action ANSWER None ll Jf you or another on your behalf have paid any Jegal fees and costs inc 265ned for the defense this action provide the amountspaid and the date of each payment ANSWER See Bradley Edwards contemporaneous production State by week or month the amou 265tof hours that you devoted to your professional work since the filing of this action against you in and and describe in detail the source of this infonnation e.g time sheets personal 267diary manual ot c.omputer calendar ANSWER Unknown although Bradley Edwards estimates that in the ordinary course of his work he devotes approxi!"llately hours per week to professional activities This total regularly increases immediately prior to and cluring trials State by week or month the amount of:hours that you have devoted to your professional work during the two years prior to the filing of this action against.you in and and describe in detail 267the source of this in,.formation e.g time sheets personal giary Ual.-or computer calendar ANSWER Unknown althougi1 Bradley Edwards estimates that in the ordiriaiy course of his work he devotes approximately hours per week to professional ctivities This total regularly increases immediately prior to and during trials 1LJ State the amount of grossj11co1e thatyou receiyedJrom providing services as a lawyer for each of tljeyears and and identify the source of that ihcpme incltid1ng the payer of the same ANSWER Objectio1L Irrelevant jmmaforial not reasonably 9alcul ted to le.ad to the discoyery of admissible evidence and an unwananted invasion of Biadley Edwards right to economic privacy State the amount of gross income that you received from the provision of goods or services other than while acting as a lawyer for each of the years and and identify the source of that income including the payor of the same ANSWER Objection Irrelevant immaterial not reasonably calculated to lead fo the discovery of admissible evidence and an unwarranted invasion of Bradley Edwards right to economic pnvacy State the amount of hours that you have devoted to pm bona work for the years and and substantiate your answer with the names of the cases or causes for which you provided such.service ANSWER Objection Irrelevant immaterial and not reasorfably calculated to lead to the discovery of admissible evidence You 267claim damages for emotional distress embarrassment and mental anguish as a result of this action against you Have you sought professional medical or psychological services If so No a identify each provider of such services state the dates during which you received treatment or assistance for such services and state the amount of money you have paid for such services ANSWER If yotL have riot sought professfonai niedicaL or psychological services please explain why ANS iVER I qave managed to deal whh the einotionai and psychological stress without professional assistance a.rid have prefened to avoid the potential stigma that sometimes attaches to treatment foremotional and psychological issues J9 If you claim to have suffered any.loss ofiricome wages or other.reimineratiori as a.result of the clainis inade ag 267ainst you in ti1is action cfoscribe cletail a the nature of the lost income whether by wages or other re1nu11erat,ion e.g;.,.loss of clients Joss of amings for hours engaged in the,practice of law 267etc the amount of lost income whether by wages or other remuneration for each perfocl for which you typically receive the above e;g if you bill or otheiwise keep track oflegal services you provide by the hour the number of hours which you were unable to perfonns services for each month since the filing of this action the duration oftheloss i.e.,the date the loss commenced and concluded the basis for dcte1mining the loss Le identify the specific client and matter and the method used hr calculating your loss of income whether by wages or other remuneration for the period you have claim to have suffered dama.ges ANSWER See Bradley Edwards contempornneo production Jfyou are claiing that you have suffered loss offuture.eaming capacity as a result of the allegedly wrongful conduct describe with specificity a the duration ofth lost future earning capacity tb.e amount ofthe lost futu1;e carping capacity and the basis for your calculation ANSWER lJncietermined at this time If you are claiming to haveJost business or employment opportunities as aresulf of the allegedly wi 267ongful conduct of the plaititiff describe each with specificity and for e_ach state the amount of 1on:ey damages you seek to recover ANSWER Undeternihieci at this time Describe.the.method tised in calcufating your.loss of future earnings ANSWER N/A With respect fo each alleged lost business opportunity please state for each the following a ANSWER N/A the name arid address of tl1e employer client att or entity who offeredor presented the business opportunity that you claim was lost the nature and scope of work involved in tlie lost business opportunity the amount of compensation or remuneration you estimated that you woulc:i earn or be paid had you undeqaken the opportunity and the basis for that estimation and _the date you determined that you had lost the business opportunity State eacli instance in which youljav:e spoken fo or.communicated with the press or ny other media representative relating to Plaintiff Jeffrey Epstein Provide the identity of eac:h contact the date of the contact and a desciiption of the communication ANSWER Objection Attorney work product privilege except to the extent that Bradley Edwards is identified as a source ofinfo1matfon in published reports which are as e_asily available to Jeffrey Epstein as to Bradley Edwards through intemet searches Identify the confidential source Hsted on your Privilege Logi this case dated February.23 ANSWER Objection AUomey workproducf Identify the legalbasfo for iriCiuding a confidential soi1rce in yourPtivilege Log ANSWER Attorney work pfoduct privilege Provide an expl8:nation for your belief that law enforcement is still ii1vestigat1ng the Plaintiff/Counter-Defendant Jeffrey Epstein Identify contacts w1th government/law enforcement fuedia other attorneys or anyone else fromwhich you claim form this belief including the names 267dates substance ofcommunication etc ANSWER Objection Attorney work-:product and statutorily restricted communications with law enforcement and prosecutorial authorities Jn-elevant immaterial and not reasonably calculated to lead to the discovery of admissible evidence lclentify the basis for your claim that others still persist in prosecuting claims against the Plaintiff/Counterdefendant Jeffrey Epstein Identify the persons still prosecuting claims against the Plaintiff/Counterdefendant or with lmowl dge of the persons stiH prosecuting clai1s against him including names dates of contact wHh such persons substance of communiciition etc ANSWER Objection Attorney work-product and statutorily sfricted communications whh Jaw orcement and prgsecutodal authorities Irrelevant immaterial atid not reasonably calculated to lead to the discovery of admissible evidence Provide support for your claims in Paragraphs _9 and of the Second Amended Counterclaim in which you allege the soie ptirpose of filing civil claims was never to recover monetary damages that Plaintiff/Counteldefei1dant Jeffrey Epstein lmew he never suffered tr1om tary damages 267that he knowingly asserted baseless and unsupportable claims etc ANSWER See Bradley Edwards Motion for Summary Judgrnerit arid attachrrierits Identify all clients and list all payn1ents lilade to clients in connection with their cases against the PlairitiffiCountcr-Defendant Jeffrey Epstein ANSWER Objection relevant immaterial and _not reasonably calculated to lead the discovery of admissible evidence However to the extent.deemedrelevant since Epstein directly settled the claims and made the payments the information requested is readil available to him Identify aU third parties non-clients who rnceived or made payments in c01inectiori with the client cases or purported client cases against the Plaintiff/C:ounterDefendant Jeffrey Epstein andwith specificity explain the relationship ofsuchthirdparties list the payments made to or by each and list the date of payments.and purpose of pay1nents Your an wer should inch1de withouflimitatjon all investigators witnesses,Teforring persons referring attolneys outside coimsel outside experts It should also include any and aU payments macie to or by investors in aily of the.client cases against the Piaihtiff/CounterDefendant Jeffrey Epstein or payments made by or to any other person in connectkm with the client cases ANSWER Objection 267irrelevant immaterial and hot reasonably calculated to lead to the discovery of admissible evidence i2 Identify all attorneys who worked on the client cases against Pia!ntiff CounterDefendantJeffrey Epstein including but nofJimitedto the attorneys formerly at Rothstein Rosenfedt i dler the attorneys at Fanner Jaffe Weissing Edwards Fistos Lenrinari PL outside attorneys and referring attorneys ANSWER l3radley Edwards PaulCassell 225Matt Weissing Steve Jaffe and BiJlBerger rendered substantive seryic in the prosecution of claims agains Jeffrey Epstein Russell Ad1er was in attendance at multiple depositions but was not an active participa Identify aU members of support staff paralegals secretaries investigators etc who worked on client cases against the Epstein including but not limited to BradJey EdNards office the att n1eys fonnerly at R,olhstein Rosenfeldt Adler the office ofFanner Jaffe Weissiri.g Edwards Fistos Lehimari PL arid offices of outside attorneys and referring attorneys ANSWER Shawn Gilbert Wayne BJack Jacquie Jolirisori Beth Williamson Susan Sterling Mil Fisteri Pat Roberts Pat Diaz i Identify any agreements proposals offers discus 267sfons ricgotfattoris etc related to the sale or development of any movie book or other rights or similar deals ANSWER None ST TE OF FLORIDA Hkt Jll COUNTY OF BR0WA-Rl tfl The f9.1:cgqing Jnstmmen.t lS ackrmwfoqged 6etor.e-me:this a day January tAR.ttA fd by Braille Edwards who is p:crs:onafly knoWit to Vl1o lifls roditced type--t f.idenfiliootien ns identif1Gatkm-and who did/did not take _an oallt EXHIBIT Fing JEFFREY EPSTEIN Plaintiff IN THE CIRCUIT CCH.JRT OF THE FIFTEENTH JUDICIAL CIRCUIT INANP FORPAL BEACH GQUNT 7,FLQRIDA CASE NO COTT ROTHSTEIN individually BRADLEY EDWARDS indiyiduaJly a L.M individually Defendant I NOTICE OF SERVING ANSWERS TO ERROGATORIES Bradley Edwards by and through liis 1lnde nsel her by files this Notice of Serving Answers to Interrogatories with the Co oundec by Jeffrey Epsrein on September and said Answers to Interroga yve been fumisl1ed;to the 225attorneys Jeffrey Epstein I HEREBY CER tat correct copy of the foregoing was sent via E-Serve to all.Counsel on.the attached listrttis day of L,v a.u..-ovAROLA Florida Bar No Attorney E-Ma_il jsx searcylaw.com a11d mmccann searcylaw.com Primary E.;Mail:._scarolateam searcylaw.com Searcy nney,Scarola Barnhart Shipley iA Palm Beach Lakes Boulevard WesU?alm Beach Florida33409 Phone Fax Attorneys for BradleyJ Edwards Edwards adv Epstein Case No NC tic_e of rving Answers to Interrogatories Please describe with particularity any and all evidence cfrcu1nsta1ices and events upon which you rely in asserting that your reputation was damagedasallegedjnyour Counterclaim including,without limitation specifically describing how that damage is attributable to Epsteins lawsuifagainstyou RESPONSE lthe al gations ofERsteins maliciously filed Complaint are defamatory_pjiill Please explain in detail the a1nourit of tirrie required to be diverted th,m your professional 1esponsibities including butnot imited to the time lost each date on which the time was lost the case/matter cm which you would have otherwise spentthe time your bill ble houdy rate any you allege to have iost arid for each ca.se/matter identified please provide the amourit of income derived by you your finn or any entity acting on your behalf in that matter Please detail alLother evidence methods and calculations on which yoliiritend to rely to quantifythe damages you claim are attributable to 225time diverted from your professionalresponsibiHties as alleged iri your Counterclaim RESPONSE Time dive1tedfrom Bradley EdVvards professional responsibilities is reflected in previously produced time records and will be updated priodo the expiration of discovery Counter Plai 260ntiff;.however objects to this intermgatory the grounds that the number of ir1terrogatories propounded by the Counter-Defendant including subparts substantially exceeds.the maximum number pennitted without leave of omt For eaclt payment or distribi.1tionmade by you Rothstein Rosenfeldt Alder Farmer,/affe Weissing 267Edwards,.Fistos Lehnnan PL and/or any other law fitm through which you have provided legal services and/or any other lawyer and/01 law finri to Beth Williamson in connectiohwith any claims assertedagainst Jeffrey Epstein state identify and describe the mnount ofthe payinent the date ofpayment,the source of the payment proceeds the reasons for the payment atid any p"iomises contracts agreements understaildings and afrange1ents regarding 267said payment and all amendments mocHfi ations and supplements of the same pursuant to which such paym nt was made RESPONSE Objection The information sought is not rel vant material or reaso11ably calculated to lead to the_ discovery of admissible evide.nce Jhe interrogatory seeks to invade the economic privacy of the Counter-Plaintiff and all 267others encompassed withillthe extraordihiuily broad scope of Definition of Counter-Defendants Interrogatories Reference to the peri9d"in question is vague and ambiguous Signature of Apswering Party STATE OF COUNTY OF The foregoing instrument was acknowledged before me th!!:is bu JJ_ by iJu.,e,.r dJJwh personally known to me ho has produced and who did/did not take an oath i,?t MARIA KEUJCHIAN t,lYCOMMISSIONJGG EXPIRES laCIIMY nlbSllrJ Nie lie orida at Large My Commission expires Commission No EXHIBIT IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually Defendants/Counter-Plaintiffs I VOLUME I VIDEOTAPED DEPOSITION OF BRADLEY EDWARDS Taken on Behalf of Plaintiff Friday November 10th a.m p.m Palm Beach Lakes Boulevard West Palm Beach Florida Examination of the witness taken before Sonja Hall Palm Beach Reporting Service Inc Palm Beach Lakes Boulevard Suite West Palm Beach FL Palm Beach Reporting Service Inc with A Just an anxious feeling to get this over And you had that anxious feeling every single day from December through today November 10th A Q;.IT more reminders have and Dlli Ener:e Cs:ITTl looms Enis fal::;se aTiegation over illy head is clearly t.i.gg You said it looms this false allegation What is the false allegation looming over your head A That I was a participant in a Ponzi scheme with one of the individuals that might be the most hated person in South Florida especially amongst our profession Mr Rothstein A Right But why is there an allegation hanging over your head The case against you was dismissed in correct MR SCAROLA Excuse me Which case BY MR LINK The case against you by Mr Epstein was dismissed in was it not A Right The case was dismissed Five years ago the case was dismissed Palm Beach Reporting Service Inc CD Q3 that those things are not true The lawyers I practice with know that those things are not true world that Its the rest of the A Oh okay Your reputation is made up of what society thinks of you The people who dont know me and only got a snapshot of this person is Rothsteins co-conspirator in a Ponzi scheme and continue to spread that message from that point in time forward whether its million people or million people my reputation right there suffered damages that unl"es"s ana until Gury returns Tc:t in favor can"::t Uncione So these are the nameless faceless folks that you dont know that you have never met never had conversations with never interacted with who are that have impacted your reputation A Your question is way too extreme So you told me its anyone who knows you knows for sure that theres nothing A I didnt tell you that You didnt A No Who knows me well They have to know you well right Palm Beach Reporting Service Inc TI testimony I understand Hes the only one that complied with the disclosure rules and has a report but the rest are listed as under the actual expert witness section A I hear you So in looking at do you have the report in front of you which we just marked as Exhibit for Bernard Jansen PhD A A Yeah When was Mr Jansen retained I dont know Your counterclaim has been pending since December correct A Yes Do you know why Mr Jansen did not provide a report until A Dont know Do you know why Mr Jansen was not listed on any exhibit list from the beginning of the case the first I think it was five maybe five or six witness list to the court A certainty onU Know OillQ 251ill t_yQ Eninq IT o:e:s ill t_ypicalTy IT report i"s most useTITl rig bef trial because CTI i"s Palm Beach Reporting Service Inc quantification Q1 DI mrni15er Q1 peopl wno have seen DI articl"es associated E3 epending on DI Q1 _lawsuit wnlcn testifyingi witfi DI erogatory and efamatoryJ statements so Dr Jansen MR SCAROLA Excuse me Im sorry You interrupted Mr Edwards BY MR LINK Did I Mr Edwards A Yes I was almost finish though So his report cant be completed until well you want it to be complete as close up to the trial as possible so that you can have the final numbers I understand you can update reports But you could have retained him at any time because there were other trial settings and there would have been a witness list right A Well we have been on appeal for a while but I understand But youve had five trial settings In any event you have used Mr Jansen before correct A I have used Mr Jansen before As a Palm Beach Reporting Service Inc EXHIBIT IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually Defendants/Counter-Plaintiffs I TRANSCRIPT OF PROCEEDINGS DATE TAKEN TIME PLACE BEFORE Wednesday November 29th a.m p.m Dixie Highway Room l0C West Palm Beach Florida Donald Hafele Presiding Judge This cause came on to be heard at the time and place aforesaid when and where the following proceedings were reported by Sonja Hall Palm Beach Reporting Service Inc Palm Beach Lakes Boulevard Suite West Palm Beach FL PALM BEACH REPORTING SERVICE INC Mr Epstein MS ROCKENBACH Correct THE COURT Mr Scarola thank you for your patience You may proceed sir Thank you Ms Rockenbach and Mr Link for your written and oral presentations MR SCAROLA Thank you very much Your Honor If you dont mind Im going to stand at the podium that says Plaintiff Your Honor there is a very fundamental disagreement between present counsel for Mr Epstein and Mr Edwards You heard Mr Link say and I think I took down the quote exactly we have never challenged that these three cases were legitimate cases Well I can understand why it is that at this point in the litigation Mr Link wishes that they had never challenged that these three cases were legitimate cases the fact of the matter is thatj Bradley Edwards was sued for ginning u:e.J ffabricating constructing those three casesJ and others as a knowing_2artici2ant in Floridas largest ever Ponzi scheme that PALM BEACH REPORTING SERVICE INC to interrogatories in the state court matters E.W and L.M and listed additional high-profile witnesses that would allegedly be called at trial including but not limited to And then various individuals are identified And then paragraph The sole purpose of the scheduling of these depositions was again to pump up the cases to investors There is no evidence to date that any of these individuals had or have any knowledge regarding RRAs civil actions THE COURT For the record thats a quote from paragraph as opposed to argument MR SCAROLA Thank you Sir Im sorry If we go to page of the complaint subparagraph Rothstein and again this is a quote Rothstein and the litigation team knew fur should have known that their three file ases were weak and had minimal value forj the following reasons PALM BEACH REPORTING SERVICE INC Those reasons are listed Again guestioning the legitimacy-2.!J the claims Page paragraph The actions described in paragraph above herein had no legitimate purpose in pursuing the civil litigations sic against Epstein but rather were meant to further the fraudulent scheme and criminal activity of Rothstein Paragraph the last line RRA and the attorneys in the civil actions Please remember the civil action is a defined term in the complaint Its L.M E.W and Jane Does claims needed to create a fiction that included extraordinary damages However the actual facts behind her action would never support such extraordinary damages Going down to the last sentence in subparagraph A Under the circumstances her claim for damages against Epstein one of L.M many johns during that same period would be so incredible and certainly not likely to produce the extraordinary settlements promised to RRAs investors PALM BEACH REPORTING SERVICE INC hear what Mr Link is trying to suggest so that you can formulate your argument MR SCAROLA I know exactly THE COURT I will give him a minute MR LINK I dont want to take long I just want to clarify because Mr Scarola said that we have conceded that nothing was fabricated What was fabricated was not the filing of the three lawsuits in It was that there were other claims in addition to those three and that one of these three settled for million and that Mr Epstein had offered million Those are the things that we were talking about during that time period THE COURT Well the allegation though in subQ2 which was already read into the record I will read itj _gain quote Rothstein and the litigation team 2arenthetically Mr Scarola has Giisigested that the litigation team is efined as Mr Edwards returning to thcl guoted 2rovisions knew or should have known that their three filed cases were wea PALM BEACH REPORTING SERVICE INC and had minimal value and for the reasons I have already gone through in addressing what I think is to be relevant as to ffhose three individuals if the contention iaj still that these claims were not legitimate during the 2eriod of time that Mr Rothstein ad Mr Edwards worked together MR LINK I just want to make this distinction I dont want to beat this horse too much If you look at the paragraph before that paragraph it talks about the million settlement THE COURT I will take that in consideration MR LINK So its relative to that Second Your Honor MR SCAROLA Im sorry I would like in the few minutes remaining to be able to make some points before THE COURT Mr Link I am going to ask you then to save your commentary for rebuttal MR LINK I just was trying to answer your questions THE COURT I didnt know I had a PALM BEACH REPORTING SERVICE INC EXHIBIT IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO 800XMBAG JEfFREY EPSTEIN Plaintiff/Counter-Defendant vs SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendant/Counter-Plaintiff VIDEOTAPED DEPOSITION OF DR BERNARD JANSEN Taken on Behalf of the Plaintiff/Counter-Defendant and Defendant/Counter-Plaintiff DATE TAKEN Friday December TIME a.m a.m PLACE Law Offices of Edwards Pottinger LLC Andrews Avenue Suite Fort Lauderdale Florida Examination of the witness taken before Iliana Lugo Court Reporter Palm Beach Reporting Palm Beach Lakes Boulevard Suite West Palm Beach Florida APPEARANCES For the Plaintiff/Counter-Defendant LINK ROCKENBACH P.A BY SCOTT LINK ESQ KARA ROCKENBACH ESQ Palm Beach Lakes Boulevard Suite West Palm Beach Florida For the Defendant/Counter-Plaintiff SEARCY DENNY SCAROLA BARNHART SHIPLEY P.A BY JACK SCAROLA ESQ Palm Beach Lakes Boulevard West Palm Beach Florida Also Present ROBERT BARFIELD Videographer Visual Evidence BRADLEY EDWARDS Defendant/Counter-Plaintiff INDEX WITNESS DIRECT CROSS REDIRECT DR BERNARD JANSEN By Mr Link By Mr Scarola EXHIBITS FOR IDENTIFICATION Plaintiffs Exhibit No Page Curriculum Vitae Plaintiffs Exhibit No Page Report Plaintiffs Exhibit No Page Appendix Plaintiffs Exhibit No Page Article Plaintiffs Exhibit No Page Article Plaintiffs Exhibit No Page Article Plaintiffs Exhibit No Page Article Plaintiffs Exhibit No Page Article Plaintiffs Exhibit No Page Article Plaintiffs Exhibit No Page Article THE VIDEOGRAPHER Today is the 1st day of December The time is a.m This is the videotaped deposition of Doctor Bernard Jansen in the matter of Epstein versus Rothstein and Edwards This deposition is being held at North Andrews Suite Fort Lauderdale Florida My name is Robert Barfield I the videographer from Visual Evidence Inc Would the attorneys please announce their appearances for the record MR LINK Yes MR SCAROLA My name is Jack Scarola I counsel on behalf of the Plaintiff Bradley Edwards And Mr Edwards is also present MR LINK Scott Link and Kara Rockenbach on behalf of Mr Epstein Thereupon Doctor Bernard Jansen was duly sworn MR SCAROLA I going to offer a stipulation to you And that is that rather than go through the details of the witness I background training and experience we would agree that his curriculum vitae will be marked as an exhibit to this deposition and any portions of it may be read by Palm Beach Reporting Service Inc either party as if those entries in the CV were responsive to appropriate questions during the course of the deposition MR LINK Thats acceptable MR SCAROLA Good Thank you MR LINK Shall we go ahead and mark that as Exhibit MR SCAROLA Thats a good idea Thereupon the document referred to was marked Plaintiffs Exhibit Number for identification THEREUPON DOCTOR BERNARD JANSEN was called as a witness and having been previously duly sworn and responded do was examined and testified as follows DIRECT EXAMINATION BY MR LINK Mr Jansen would you please take a look at what we just marked as Exhibit and tell us what that is please A A recent CV This is my CV my curriculum vitae And is that current through today I could check every page but its a fairly Okay Mr Jansen tell me what your opinions are that you have reached in this case crne Il p_in.TIJ.rw-_ dtl_amator OJ i zyient::O-ga;:in EdWa ki:tfg ht n?Jl CID filh zyie-o:rt1 Q.thStei Il thated diffe"Ient-m ite daJ;:1 itor:s You just used the words defamatory statements Did you make a determination that there was a statement in some publication that was defamatory A I was given the gist of the statements that the statements that linked Mr Edwards to the Ponzi scheme of Mr Rothstein and then I checked for the explicit statement those particular statements in each of the articles I understand that but Im talking about the word defamatory Defamatory is a legal word is it not A I dont know whether its a legal word or not Well what does it mean When you were doing your work you said you used defamatory statements And I want to know what you concluded was a defamatory statement and well talk about A Sure the credentials you have to make that determination for to say that to a jury A As I outlined in my report in one of the paragraphs that we can go through I outlined explicitly what the statements were that I used I understand what a statement is I dont have any problem with you doing research The research that you did makes sense to me If you plugged in a sentence and wanted to see how many times it was used that makes sense to me A Uh-huh L!_in an Cth CLlJ _eClSlO ab _fil am"at5r rr_d--L va maa aecisio.n.Jh"a hateve.n JJL Q_ ere resea:g;Ji ng a a tl amator JJL II.ol ct a 247.provld as I sEft L.Il Y--.TI:POr _ha wa h_ CD JJL ts:t_ha_t_un c!:M _d ct.ID QthStei.!GJ atTS-W_ha a 247.provitl to ct2 rrty a!;,_gglITL v_h"a JJL hQ_ug a 1-il tl arnarorl hatTs-a amatorYlJ All right Is there a way that you could describe the statement from your words what you were doing Because the word defamatory is not your word is it in this report Thats one of the lawyers words A Well it was a description I used for those particular statements It was provided to me what those statements were Okay So you chose the word defamatory statements A I didnt say that no I was provided that these are the defamatory statements to look for ct C""ab _hatever sfft JJL nts yQ_ a:g;h ct amatory a ID l!fQW lil Okay Is there something about my question thats causing you pause A A little bit yeah _ct.t_d_.._aIT:I.J vesfigatio!G You re asking me kind of a legal question Uh-huh Palm Beach Reporting Service Inc A And Im just telling you that I was provided these statements And the reason Im asking is you told me your opinion was about defamatory statements And that has a lot of significance to it And I want to understand who determined what statements were defamatory whether you did that or the lawyers for Mr Edwards did that MR SCAROLA Objection repetitious asked and answered A Yeah your question is asking kind of two questions BY MR LINK A You may answer both Go ahead All right The statements linking Mr Edwards to this Ponzi scheme by Mr Rothstein I mean those were statements I looked for I looked for the explicit statement you know those particular expression of those statements At the aspect of whether they were defamatory or not from a legal aspect is not within my purview Right Okay So that must mean that the language defamatory statement was provided to you by either Mr Scarola or Mr Edwards A Well yeah yes that particular subject matter was provided yes Okay Do you have any other opinions in this case other than the one you just shared with me A Well theres supporting opinions that I outline in my report but thats the major thats what I was asked to do dissemination of these defamatory statements So okay so you keep saying defamatory statements And when you say that the reason it causes me concern is whether a statement is defamatory is for a judge or jury to decide A A Okay Then maybe Im You re not the judge or jury in this case I making that statement in a colloquial sense rather than the legal sense youre using it in So what were really talking about though is a statement and how many times that statement was picked up by the press is that right A A The press yes it was available on-line Do you a particular type of subject matter for these particular statements yes fila:y rd so l_er or nQOha__1 tft zyi a _O.Eli_amatory or nQW-_ _at ana:-l;Yfil ag ill Okay So then what are the sub-categories of opinions that you have A Well we can go over my report but and I provide those I have your report but I want you to tell me what opinions you re planning to provide to the jury MR SCAROLA And you should understand that to the extent that it assists you in providing an accurate response to any question that is asked during the course of this deposition you re free to refer to anything that youd like to I have a copy of your report here If you want to look at that you are free to do that As long as Mr Link knows what it is youre looking at if it helps you to give honest and accurate answers you re free to look at that MR LINK Jack I dont agree to that I dont want you to hand him exhibits MR SCAROLA Im sorry that MR LINK and tell him what he can do MR SCAROLA Im sorry that you dont agree MR LINK I dont MR SCAROLA but that happens to be a matter of law He has a right to refresh his recollection to refer to anything that he wants to during the course of the deposition as long as you are aware of the fact that hes referring to something and have a chance to look at it yourself MR LINK I dont want to argue with you Please let me take my deposition the way I want to MR SCAROLA You re free to do that BY MR LINK So what I asking is what your opinions are A Uh-huh And we get to your report And if you dont remember something just tell me you dont remember But I want to know as you sit here what youre going to tell the jury And I understand opinion number one is that you took a statement given to you by Mr Edwards and Mr Scarola and you did your research to see how many times you could find it in the press right A A statement yes or similar statements that related to it yes Got it What other conclusions or opinions did you reach other than that one A Well the other sub-supporting sub-opinions Palm Beach Reporting Service Inc that support that particular opinion A Im asking what are they sir Okay Well that the statements were distributed to different on-line sites that I calculated the traffic to those particular sites The sites that I couldnt verify the traffic or didnt feel I had reliable traffic nwnbers I didnt include The articles I looked through each of those articles for defamatory statements using that colloquially I outlined different steps of why that is a conservative estimate that and give several examples in my report Okay So that just sounds like the numbers that you found when you did your singular opinion which is to see where this statement provided to you by the lawyers was replicated in the press and thats the number of times that you saw that is that right A Well that was one of my main opinion but you asked for the sub-opinions and Ive outlined it that the sir Yeah A was a conservative estimate Okay Any other opinions A We can go through paragraph by paragraph in report but I gave you the Thats it broadest opinion A Okay When were you retained in this case A By October on or about MR LINK Okay Lets go ahead and mark the report as Exhibit Thereupon a brief discussion was held off the record after which the deposition continued as follows Thereupon the document referred to was marked Plaintiffs Exhibit Number for identification BY MR LINK Ready Lets turn to page sir On page you outline what your assignment was And who provided you with the assignment Who gave you whats in paragraph A A That would be Mr Scarola Mr Scarola gave you paragraph Yeah Its a and I added some words to the thing to make it more in line with what I had to do but thats basically just to looking for A Okay those types of words All right So the person that you had contact with in deciding whether you would be retained in this case was Mr Scarola not Mr Edwards A That is correct Did you have contact with Mr Edwards about the content of your report A Yes And did you have contact with Mr Edwards about what the way your report is written A Well yes he Mr Edwards reviewed a draft of the report And gave you comments on the writing of the report A Yes basically Made some changes to it A Made some suggestions yes Okay And did you accept his suggestions A Most of them wording changes yes and there was one recommendation that he asked if I could include in my report And did you do that A Yes Okay So you took his wording changes and you made a material change to your report based on Mr Edwards asking you to do so is that right A He asked if I could include something and I felt it was in line so yes Okay So back to paragraph for a second The question that you were asked by Mr Scarola and Mr Edwards is What is the level of dissemination of defaming statements Did they give you any definition of what defaming means A The again this defaming is kind of a legal thing youre harping on here I use it in a colloquial expression And they gave me what the statements I was to look for Right So is the word defaming here really superfluous from your standpoint What you really needed were the statements and not an adjective to describe them for you to do your work A For me to do my work Yes sir A cr::n ct ft__tl!_roen k-fc IS67T he;:wora7cte fa.min-a wasrt:n n;n e-tt l_O a ha!fg fil!ObQp__:Cd tfg-:Y 6rk1 l_ci--tt7 Okay Turn to page please Look at paragraph if you would Palm Beach Reporting Service Inc A Yes It says The defaming statements associating Mr Edwards with the illegal activities of Mr Rothstein Do you see that Yes A A What is the statement that you searched for Well it was it varied slightly you know document to document but it was an association with that Mr Edwards was somehow knowingly involved with the illegal activities of Mr Rothstein A What was the word search that you used Well again to find the articles or the statements in the articles I want to know the word search that you were looking for As I understand your assignment it was to take the connection of Mr Edwards with Mr Rothstein and Mr Rothsteins illegal activities and prepare a report and identify every place that there was a reference to Mr Edwards and Mr Rothstein and the illegal activities Is that right time A A Youre going to have to say that one more Okay Sorry I thought I understood that the assignment that you had was to simply take Mr Rothstein Mr Edwards and the concept of illegal activities and then search and see where in the Internet the newspapers that combination of words exists MR SCAROLA Im going to object to the mischaracterization of the answer that was previously given which included a reference to the fact that Bradley Edwards was a knowing participant in the illegal activities A MR LINK Thank you for that clarification MR SCAROLA You I re welcome Well I can take your question two different ways okay One what I used to look at these documents and those I outline in my report BY MR LINK A Uh-huh And then the actual statements in each of these documents And those statements vary slightly you know article to article But it was somehow there I as a reader of these articles would that the article expressed that Mr Edwards was somehow knowingly involved in these illegal activities of Mr Rothstein Okay So is that the key to this The article needed to show that Mr Edwards was knowingly involved with Rothstein illegal activities Is that is that right A That Mr Edwards was involved with these illegal activities and that so you I re writing it down like that was the only statement I searched for But as I said in each of these articles that verbiage changed likely article to article Okay Well Mr Scarola corrected me and added the word knowing That I why I added the word to my sentence Was that not a word that was important to you in determining whether the statement you were supposed to find was included in an article A I don I understand the question Well I just asked you if the statement that you were asked to locate to see how many times it was disseminated was the one that reads like this That Edwards was knowingly involved with Rothstein I illegal activity A And I going to refer you to paragraph that clearly states Defaming statements associating Mr Bradley with illegal activities of Mr Rothstein Okay So whether it was Mr Edwards knew about it or not was not germane to your research A That I not what I said Well I just read what you wrote here and it just says associating him It doesnt say whether he knew or didnt know And Im trying to really understand if you were looking for articles that simply say Edwards and Rothstein And Rothstein has illegal activity Or you were looking for articles that said Mr Edwards was a known participant in the Ponzi scheme MR SCAROLA Object to the form of the question as it excludes the possibility that both were included A The MR LINK Good coaching BY MR LINK A coaching A Go right ahead I dont understand the comment about the No it was just for Mr Scarolas purposes Okay Could you repeat the question I probably cant I dont remember what I asked now but I come up with another question MR SCAROLA Id be happy to help if youd like MR LINK No no MR SCAROLA cause I remember it Palm Beach Reporting Service Inc MR LINK I figure it out MR SCAROLA Okay MR LINK Ill figure it out BY MR LINK Im trying to understand what was important to you in doing your search A Uh-huh because I understand the numbers That makes sense to me Thats sort of the easy part of this What Im trying to understand is what you were searching to find so that I can then talk to you about whether the articles you located satisfy the search request you were seeking Does that make sense And when I read your sentence in paragraph if thats what you were looking for then whether Mr Edwards knew or didnt know would not be important to you in your search A Nah I you know well you can argue and interpreter it how you would like But as I explain in my report you know I looked in these in the articles where that Mr Edwards was involved knew about contributed to that somehow had to get across in these articles to me one A A to Okay So the exact yeah Involved knew about and I missed the third Involved knew about Somehow involved is that what it was MR LINK Jack do you remember MS ROCKENBACH Contributed to MR LINK Contributed to MR SCAROLA Knew about MR LINK Involved knew about contributed MR SCAROLA Contributed to MR LINK Got it Thank you BY MR LINK Okay So so then you were focused on not just that Mr Edwards was employed at the Rothstein firm and that the Rothstein firm was involved in illegal activities You were looking for articles that connected Mr Edwards to that illegal activity A That is a very good example Yes there were articles that for example said that Mr Edwards was employed in Mr Rothsteins firm and those articles I didnt include It had to be somehow that he was somehow associated with this With the illegal activities A With the illegal activities Got it Okay All right Will you turn to page please When you were identifying articles in which there was reference made to Mr Rothstein I illegal activities and Mr Edwards I involvement or contribution to or knowledge about those activities did it matter to you where that information came from And here is what I mean Did you exclude for example press statements by Mr Scarola A Well there I two questions there Let me deal with the last one I mean I don recall any press looking at any press releases from Mr Scarola so I don think I included those How about statements to the press by Mr Scarola A The well let me answer your other question which was which right now I forgot Okay So let deal with the question of when you were A Well I want to make sure I answer your question It was a it actually was a very good question and now I We I re going to get back to it MR SCAROLA Do you want the earlier compound question read back to you THE WITNESS Yes the earlier compound question read back MR LINK Read it back How about it Objection sustained Thereupon the following was read by the Court Reporter Question All right Will you turn to page please When you were identifying articles in which there was reference made to Mr Rothstein I illegal activities and Mr Edwards I involvement or contribution to or knowledge about those activities did it matter to you where that information came from And here is what I mean Did you exclude for example press statements by Mr Scarola A Yes to the first question Yes it did matter where it came from BY MR LINK Okay Explain to me why and what you did to narrow the field A For example I ignored several there I a lot of documents court documents about this case that are available on-line I didn link those bells You know I just hit I Palm Beach Reporting Service Inc You did not A Specifically court documents no I did not include those Theyre identified in your report the court documents A Where are they identified Okay We will look at that So you excluded court documents A Yes Now if the only disclose just to clarify that if an article referenced a court document or had a snippet from a court document you know like from a news article then I included it But if it was just you know about some Florida Court Association repository no I didnt include those A All right Any other limitations They if for example there were articles that just mentioned the case A Uh-huh but didnt mention that had the statements about Mr Edwards being involved in these illegal activities I didnt include those There may have been some other examples But my real my real aspect was to focus on some type of explicit publishing of these statements All right And so I take it then that you were not eliminating articles that for example if Mr Scarola or Mr Edwards spoke to a reporter which led to an article being written or they invited a reporter to a hearing or had lunch with a reporter to talk about the case which created an article you didnt exclude those from your analysis MR SCAROLA Excuse me Objection no proper predicate and compound BY MR LINK A You can answer it In each of the documents I looked for the expression of the statement that linked Mr Edwards to these illegal activities So that if so that if some of the statements or articles or interviews were created by Mr Edwards or Mr Scarola those are still included in the number of items you identified with statements MR SCAROLA Objection no proper predicate assumes facts not in evidence no good faith basis to suggest such things ever happened A Can I have the question back MR LINK Please Thereupon the following was read by the Court Reporter Question So that if some of the statements or articles or interviews were created by Mr Edwards or Mr Scarola those are still included in the number of items you identified with statements BY MR LINK Okay Let me ask the question again I think we missed a couple of words Let me see if I can break it down So let I take it then for example the first article listed on page Do you see that that an October 4th article A Well I just want to that I a this is a search result a snippet linked to an article Right And I assume that that article that I referenced here is one that you included as a hit in looking for a statement that I why you I re showing it A Well no because in Figure I just give trying to explain what I did in terms of search queries I would have to check that particular link if I included that first link in my report Well this okay so all you I re doing in this example and maybe I read it wrong is it says Figure This is Figure I think right A That is correct Google search results for search edwards epstein Ponzi scheme Right A Yes So these are the items that popped on that search and then you would read the article to see what it said A Yes these are the first well these are the first five articles from that particular query And then I open into the article and then read what the article said Okay And were you provided any parameters from Mr Scarola or Mr Edwards for the time frame that you should search for A From them specifically I was not provided with a time frame Okay Did they ask you to limit your search to the time period that Mr Epstein I Complaint against Mr Rothstein and Mr Edwards was pending A Not explicitly no Okay Did you limit your search to that time period A Yes All right So that your search should not contain any articles that go past Palm Beach Reporting Service Inc A That is incorrect All right So then you did search for articles that came into existence after Mr Epsteins Complaint against Mr Rothstein and Mr Edwards was dismissed A Let me let me go back I misunderstood your question A Uh-huh All right I the lawyer talk of claims counterclaims is throwing me a little bit I did it from the original lawsuit from Mr Epstein against Mr Rothstein and Mr Edwards and one other person A Uh-huh So yeah thats what when you said the lawsuit thats what I was So you started your search December 7th Thats when the lawsuit A Correct was filed And when did you end your search to look for articles that would have been related to that lawsuit A The well I stopped searching in around October So I included every article that I ran into And were you aware when you did your search that the December 7th lawsuit was dismissed in A I dont know exactly what you mean by dismissed But in articles Ive read I read the lawsuit was no longer pending And that was that information that the lawsuit was no longer pending in important to the gathering of the articles that contained information about Mr Edwards and Mr Rothstein A Mr for what I had to do no Okay Do you know the time period that Mr Edwards filed his counterclaim against Mr Epstein when that happened A Except for here no I do not Did it influence any of the research that you did that Mr Edwards filed a public counterclaim lawsuit against Mr Epstein within days of December 9th A I again all the lawsuit stuff I dont know All right Did you find any articles between December 7th and when Mr Edwards and his lawyer Mr Scarola filed their counterclaim lawsuit against Mr Epstein A I have no idea what that means Okay You have an appendix to Exhibit which is your written report in this case that identifies copy MR SCAROLA Did you mean to give me this MR LINK I meant to MR SCAROLA Oh okay MR LINK I meant to And the reason I did is all of these articles are going to correspond to the actual article itself Jack so we can tie them in together MR SCAROLA Got it Thank you MR LINK Let I go ahead and mark this Exhibit Thereupon the document referred to was marked Plaintiff Exhibit Number for identification BY MR LINK All right We I re looking at Exhibit which is the appendix to the written report you prepared in this case is that right A Yes And under Reports and Articles Referenced those are the reports and articles that you found contained the statement about Mr Edwards and Mr Rothstein and illegal activities is that right A Well no not exactly How do I have it wrong A These reports and articles are articles that I referenced in my report as footnotes and things like that to support the textual things I writing Well were there additional articles that you did not list in your report that you reviewed that contain the statement that you were searching for A Yes there were Okay So I thought I heard you say that there were approximately articles you reviewed On here it lists Which of the articles that you reviewed that contain the statement have you not identified in your appendix sir A Well one correction It I Thank you A And I do include the articles So then when I asked if every article that included the statement about Mr Rothstein and Mr Edwards and illegal activity that is part of your calculation if it was included in the appendix the answer is yes A Well that I not the question you asked me If you I re asking me if all of those articles are listed here in Appendix then the answer is yes Palm Beach Reporting Service Inc Okay Great So lets start with item number which is MR SCAROLA Could I make a suggestion MR LINK Yes sir MR SCAROLA Because I think maybe you re a little bit confused and it might be helpful if we clarify something MR LINK Please MR SCAROLA Theres a separate appendix that appears at page You are referencing an appendix at page MR LINK Yeah MR SCAROLA Its the list that begins at page which is specifically labeled Links to Articles Containing the Defaming Statements Do you see that MR LINK Yeah but those are not the articles MR SCAROLA If youre going MR LINK Those are just links to them You cant actually get the article from doing that We tried MR SCAROLA Well okay Im just suggesting to you that maybe MR LINK I understand MR SCAROLA maybe you want to clarify the relationship between Appendix and Appendix You might be you might be better able to focus on where you want to go if you do that MR LINK I think Im okay MR SCAROLA Okay MR LINK This is the only way we can get the articles up because they were not attached THE WITNESS I provided all the articles MR LINK Right Some of them actually some I got some were not there THE WITNESS No I provided hard copies electronic copies of every single one MR LINK To THE WITNESS Someone from your law firm who contacted me MR LINK Okay Well we printed them It doesnt really matter I think we have them So we will go through them And were looking at number What are we on THE COURT REPORTER Uh-huh MR LINK Which should have a number corresponding to number on here Jack did I give you an article MR SCAROLA No MR LINK Let I go ahead and mark this as Exhibit please Thereupon the document referred to was marked Plaintiff Exhibit Number for identification THE WITNESS Can I stand up and get my water MR LINK Absolutely MR SCAROLA Want to take a short break We I ve been going for about an hour THE WITNESS Yeah that would be good THE VIDEOGRAPHER The time is Going off the record Thereupon at a.m a recess was taken until a.m after which the deposition continued as follows THE VIDEOGRAPHER The time is We are back on the record BY MR LINK All right So Jansen Exhibit which correlates to number is this an article that contains a statement in it that you then looked to see how many touches or how many people logged on to read it A I don know I can check it if you want Would you please A I don see a statement Okay So this would not be an article then that would be included in your numbers A If it doesn I contain the statement no it would not be included in the number Could you explain to me why it I commented upon in your written report if it doesn I contain the statement A Again back to this section here These are reports and articles that were actually referenced in my report as citations for some statements This is not the list of articles that contain the defaming statements I understand that but you told me all of them are listed in this section of the appendix A No I did not It in Web Page Printouts section of this appendix So if I turn in your report to page MR LINK Mr Scarola is going to help me MR SCAROLA BY MR LINK that I the list of articles is that right A It actually in two places I have it in that appendix with a nice list of each of the articles and the domains And then I also have it in Appendix Palm Beach Reporting Service Inc here in Web Page Printouts which is a different section of this appendix Web Page Printouts Okay So if I go to Web Page Printouts those are the articles A Yes sir Okay Good That helped All right So Im on the right appendix wrong place A A So it starts with what I have numbered as Okay Very helpful Thank you Yes sir I dont have here but I have So lets take a look at that MR LINK Lets go ahead and mark this as Exhibit Thereupon the document referred to was marked Plaintiffs Exhibit Number for identification BY MR LINK Okay So Exhibit correlates on page to the handwritten number MR SCAROLA Are you testifying MR LINK No Im making sure that Im not Im making sure that you understand what were looking at MR SCAROLA Because that didnt sound like a question MR SCAROLA Its not Its to make sure that the record is A I dont think Ive seen this before this particular printout BY MR LINK A A You havent seen this article No All right I dont recall seeing it Okay So then if you havent seen it then it would not have been referenced in the data that you collected A A Well this article I mean Okay this link is so Okay And then you dont believe that this article that is marked as Exhibit is the article to that link A A A I can almost tell you its not All right I can explain that if youd like Sure Go ahead Yeah this PressReader is I included all I grabbed the screenshots for each of these articles and provide the link in the report and an actual screenshot of the article in the collection of documents in my report that was provided to I guess both attorneys MR LINK All right Okay Let mark this as the next exhibit Exhibit Thereupon the document referred to was marked Plaintiff Exhibit Number for identification BY MR LINK This Exhibit I do it a different way now This Exhibit does that correlate to the handwritten number on page of Exhibit A Well the URL is not here but the title is the same So I mean yeah the title is the same The URL is not here so I can I say for sure it I the exact same article but the title is the same Okay And is this the article that you would have reviewed A I can remember all articles But like I said the URL is not here so I can I really say for sure but the title is the same Do you see this MR SCAROLA Let me also point out that what you have marked as Exhibit Number clearly is only a portion of this article MR LINK Oh I understand that I just trying to make sure we I ve got the right articles MR SCAROLA Okay Well you don I have the right article if all you I ve marked is a piece of the article We know that that I the case Correct MR LINK I not asking him to comment on the article Just if I I ve got the right BY MR LINK Is this the forget what all of the information contained in the article Is this the article title and author that is ties into handwritten number if you can tell A Yeah to be really honest with you I can I tell because the URL is not here You know the title is the same MR LINK All right Let I mark this as Exhibit Thereupon the document referred to was marked Plaintiff Exhibit Number for identification BY MR LINK Exhibit is an article from the New York Post October 5th Does that tie is this the article if you look at the top pressreader.com that ties into handwritten number Palm Beach Reporting Service Inc A Yes the URL is the same This looks like one of my screenshots So I believe this ties into number that youve annotated on this appendix Okay So is this one of the articles that you located that contained the statement you were searching fol A I recall I recall this particular article so yes All right And what is the statement in here that you found to fit the description of what you were looking for A If I recall this correctly I believe it was paragraph that excuse me paragraph is why I included this A Okay Anything else in here The article included at least one statement I mean I can read the entire article but looks like paragraph there met my criteria Okay And you say that this article came out in October of this year just a couple of months ago A Yes I see that All right And do you know where the information for this article came from A The New York Post No I understand that I mean for Lia Eustachewich the author of the article A I didnt investigate where the reporter or Or the source or where the information came from or who she spoke with A No I did not Do you know whether there are any quotes in any of the articles you reviewed that were made by Mr Epstein MR SCAROLA Separate and apart from Mr Epsteins statements in the Complaint MR LINK Yes Im asking about the article MR SCAROLA Im just asking to clarify the question BY MR LINK Did Mr Epstein give any quotes in any of the articles that you researched A Well I wasnt looking for that so I really I dont know Did Mr Epsteins lawyers give any quotes in any of the articles that you researched A I cant say for sure but there seem to be plenty of lawyer quotes so I agree there are lots of lawyer quotes Im asking if Mr Epsteins lawyers not Mr Edwards lawyers Mr Epsteins lawyers were ever quoted and the information they were quoted on included one of the statements you were looking for A I can I I wasn I specifically looking for that I can I recall Okay So who made the statement was not important to you simply that the statement existed A That it occurred within the article correct And since this one was in that I about five years after Mr Epstein I lawsuit against Mr Rothstein against Mr Edward was dismissed right A I don know Well you know that is five years more than A Yes I can do the math Okay When was the first article that you found from I talking about from a timing standpoint What is the date of the first article that you found that contained one of the statements you were looking for A I can I recall Is there something you can look at that will tell us the date of the first article that came out that contained the statement that Mr Scarola and Mr Edwards asked you to find A Well if we had all the electronic copies of the articles we could look at the dates that they were published Do you have something with you that you can look at A I don I have I provided I provided those particular documents so I don have them with me You didn I keep a copy or on your computer or anything A Oh yes I have it You have it A I have the documents Okay So is there a way of looking at this appendix or the report to determine the very first time and which article you were able to locate one of the statements you were searching for A Not by looking at the report no When you go through when I looking at this report I see dates on here a lot of Can you identify one of these that has a publication date A I mean I can look through each of these URLs if you want me to A Just I don know Palm Beach Reporting Service Inc By taking a look at your appendix can you make that determination A A Well let me look at the URLs Okay Now just you know a lot of these URLs doll have dates I understand In looking at whats available to you today can you find one of these that existed in A Well let me look MR SCAROLA Have you done the search of dates Because if youve done it and you tell us that its not there for Im willing to stipulate to that BY MR LINK A Go ahead You can keep going No Based on the URLs looking at the URLs I cannot come to an article from if I recall the question correctly Okay And in looking at the URLs can you tell me how many of these articles were in existence before when the lawsuit against Mr Edwards was dismissed A Well I could go through and look at them again but its probably just very similar And to kind of outline in my reports you know there are certainly documents that are no longer available Yeah looking at these URLs no All right Thank you Thereupon a document was marked Plaintiffs Exhibit Number for identification BY MR LINK Exhibit I believe ties into handwritten number Could you take a look and see if I have that right So far I think Im about for Maybe for But Im definitely not making the Hall of Fame A The URL is cut off but this looks like what you have annotated here as number All right And this is an article that you have included as one of the articles that contains the statement about Mr Edwards you were searching for correct A Yes Can you show me where the statement is that caused you to select this document A Paragraphs and Paragraph that starts with the words Edwards worked at A No Epstein filed its original lawsuit And then Edwards worked at Okay So what is it in paragraph Im going to put a bracket would you put a bracket around the two paragraphs for me please Or just identify them with a star however you want to so we know which ones were looking at A Witness complied Okay The first paragraph what is it in that statement or in that paragraph contains the statement that you were searching for A Well alleging the attorney was involved in false claims made by Ponzi schemer Scott Rothstein And then explains the illegal activities And then on the next paragraph it addresses Edwards as being the attorney Okay A that the previous paragraph referenced And this was a article April 22nd A That is the date And in what paper was this article written A Based on the URL the Palm Beach Daily News Are you familiar with that newspaper A No I not Do you know what its subscription is the number A I can look at my report Okay Where in your report does it say that A Yes On page number Palm Beach Daily News daily traffic Okay I sorry I was distracted Can you do that one more time for me I apologize A Yes sir Page Page A And there a table at the top Uh-huh A And item number Yeah A The Palm Beach Daily News Is that the correct And then ct.ID lte receive On that day A ell iE..,s yp_M::_a_I_ly-..have som Q_l!.-.knQ iE..,s average over a 2J k-or--mQfil ng.-ilk Ifa_D CTE..,s:-tY _M::_aJClY here,.s not yQ_l.!.-.9_an,.E:TISok-at a._p_arCTCU cta_m Over what period of time did you consider So this is an April 22nd article Palm Beach Reporting Service Inc A Uh-huh What time frame did you consider in determining people reviewed this article A The I went to SimilarWeb went to the appropriate time period and then got the daily unique tri:iffic And so for that time period there was an average daily traffic for the paper or for this article A As I explained in the report for the paper For the paper A C!h b:sitE ts--9:JlQ manY:-PfillP n:bPf 2Ifd Oirrea adeI"SlliP-::h_Umbers-a q0yp_i _y_aj;:J Qie-f Cill Ci:!fdiVldiia;Ort:icl Okay Can you tell me of the people that looked at The Shiny Sheet during some period of time in April how many actually read this article A The let me kind of go back I thought you were referring to the palrnbeachdailynews.com not this Shiny Sheet But this particular these numbers are used for the particular readership So it would be a way of looking at it would be this would be a max but a conservative nwnber on the number of readerships Okay Lets try this again As I understand there were people approximately because you did an average based on some period of time right A Well its not I did an average Thats typically how its done if youre looking for a particular period you know there _au pecD:fI1y 251-fil!:fg-:t,aQJO.li a nQW;-rc YP_i aJ;1 _y_a;tni.tfl CD for a--.mQfilli or a give.n periocfj So these traffic services they do the averaging many times Oh so the was provided to you by a service A Well yes I use its one of the traffic services I use Cill D_Ld_:y0w-ftk mQfilh-OriQfOr!IlatlOn tfd-:then et"s CDJ a _UmQ..her er day atfd_:_tQt.AOha__CPp an ClID tthfili::di vi"de-it tA CIBih Q"j O-g Verag da;tJY K_a,ff1c But did you do that or did you pull it from a service is what Im asking you A I believe SimilarWeb gives a monthly calculation so I did the average All right So you came up with doing the math A Correct And thats the approximate number of people that logged into the on-line site A Or visited that particular site Or visited that particular site But its hitting the site not this article A That is correct All right So you cant tell me how many of the folks that logged on to the Palm Beach Daily News on April 22nd actually even read the article about Mr Epstein and Mr Edwards A I did find out exact readership is difficult to nearly impossible especially when it comes to on-line newspapers and things like that because the way people read I understand that So isnt my statement true you cant tell me how many people on that day actually read this article A No thats not exactly true What I think the way to look at this number is this is an approximation a good approximation of the readership and it specifically addresses my particular assignment which was to major a dissemination of these particular statements Well as a part of your assignment as I understand it the number you came up with would be the number of individuals who this information was disseminated to A That is correct Which means they had to read it right If its going to impact me and Im going to form an opinion about Mr Edwards based on that read if I dont read it then it hasnt impact my view of him Do you agree with that A It depends what you mean by read Well if I dont read this article I dont see the statement do I A Well if you you know I get many e-mails from different newspapers and I go to different newspaper sites and a lot of times there will be mini stories on the pages and Ill read the headline and the snippet from the particular paragraph and then read some stories And so but you re asking a question that I was not asked to actually investigate the exact readership of these particular articles I was asked the dissemination of these particular statements And Palm Beach Reporting Service Inc that was my But youre not telling us that number of people actually read any one of these statements are you A The exact readership no Okay And you cant tell me as you sit here today how many people actually read this article Exhibit dated April 22nd can you A I could say its you know the number that were disseminated to was But no I cant say the exact readership of that particular article Okay And you cant tell me the exact readership of any of the articles that you located can you A Im going to go back to my role as an expert I mean this is not like counting loose change in your pocket I mean its theres multiple theres traffic numbers And so these these particular traffic numbers are whats used in the industry for readership in audits So let me try my question one more time Sir you cant tell me the actual number of people that read any one of these articles that you have identified can you sir A Al though as I tried to explain but on the technical aspects of it but no the exact readership no Take a look at this next one MR SCAROLA Exhibit number THE COURT REPORTER Yes MR LINK Yes sir Thereupon the document referred to was marked Plaintiffs Exhibit Number for identification BY MR LINK All right If I have done this right Exhibit I believe correlates to item handwritten number A Okay Let me check Yes it looks like this is that particular article All right Can you please tell me the number of hits on October to the Palm Beach Daily News on-line paper for that day A Well there was we just looked at that It was And you told me that was for a month period of time in This is two years later So Im asking youre not telling us that two years later the exact same number of people were touching the website are you A The in my report if an article multiple articles were from the same website I just included one traffic number Okay So was it your assumption that the exact same number of people that looked at the April 22nd article looked at the October 20th article A It could have been more It could have been less It could vary day by day a little bit Only a little bit over a two-year period of time A I did not look we could look at a particular site but if you look at if we can look at the table I mean this particular newspaper published seven different articles on this that contained the defaming statements I only counted one and so used one unique physical period Okay So you just used the term defaming statements again Is that because that I what you were told by Mr Scarola and Mr Edwards A I using that as a way to look at it as maybe some shorthand for the statements that were set forth in the articles Okay So really what you were looking for were statements without giving them any color is that right or characterization A The statements that associated Mr Edwards with illegal activities That what I looking for So I just trying to figure out the thoroughness of what you did A Sure So I understand that in you looked at a month of log-on activity and then divided that number by to come up with 0-some-odd number that we looked at right A Well I calculated the unique daily visitors Again this particular website that you I re pointing out published seven different articles Yes sir but not I apologize I must be doing a lousy job of asking questions and communicating today I thought we had really hammered this home which was that in you personally went to a service and got days of hits on the Palm Beach Shiny Sheet website at A A A now Yeah and then did the math That I correct You didn I do that in Let me let me I see where you I re getting So yes Yeah for the particular sites that Palm Beach Reporting Service Inc published multiple articles yeah I cant remember the exact particular date I used in this one They had seven different articles published on these statements so I ignored six of them and just used one occurrence A Okay So you ignored them I got it Lets take a look at Exhibit Can you clarify that statement I dont understand by I ignored them A A You dont understand what Your statement Which statement sir The statement that said I ignored them And I want to make sure that you understood my response correctly I think you used the word ignored Thats what you said you ignored you looked at one and ignored six Thats what you said A Okay MR SCAROLA The record will reflect what the testimony was THE WITNESS Yeah BY MR LINK A yourself A Thats what you said So let me You dont like that choice of words by If youre focusing on that particular word well you know what you re right I guess I did ignore I did ignore six articles A A Thats what you said Yeah Okay So now lets look at this article Sure What statement in Exhibit did you identify that met the parameters of your search A A I believe it would be paragraph Okay Will you put a star by the paragraph Witness complied One two three four five the one that starts with Among A Yes Okay Any other statements in here MR SCAROLA Could we read that into the record Sorry MR LINK Thats an exhibit in the record already I dont think we need to read it BY MR SCAROLA A Were there any other statements in here Well I can read the rest of the article but if the article contained one statement I included it But I can look So in doing your search if you found a statement then you would stop reading the article is that correct A I didnt say that I just said I would include it if it contained the statement Did you read the entire article once you identified a statement A Sometimes I did Sometimes I did not Okay There you go sir Thereupon the document referred to was marked Plaintiffs Exhibit Number for identification BY MR LINK Lets look at Exhibit please and I believe this ties in with handwritten item A article Yes Okay So you see this as an August Yes that was in the Palm Beach Post Yes A A And this article announces that Mr Epstein has dropped his suit against Mr Edwards correct A Says Billionaire sex offender drops Billionaire sex offender drops suit against Scott Rothstein and one of his partners Yes Okay Can you tell me in this article that announces that Mr Edwards is no longer a defendant in the lawsuit brought by Mr Epstein what is the phrase that you isolated or located to fit your search A Let me read the article Uh-huh A Yes That would be the combination of the first three paragraphs Okay And turn to page if you will of the article This is in October I sorry August correct A Yes August All right And do you see Mr Scarola quoted in this article A Yes And do you see where Mr Scarola says Despite three years of trying Epstein never produced any evidence to shore up his allegations said attorney Jack Scarola A Yes I see that Okay And you see Mr Scarola in the next paragraph is quoted as well that He meaning Epstein filed these baseless scurrilous and Palm Beach Reporting Service Inc thats a word only Mr Scarola could get out of his mouth in an articulate way claims for the purpose of trying to extort Mr Edwards into abandoning the lawsuits on behalf of Mr Epsteins young attorney sic Do you see that A A Oh Mr Epsteins young victims Young victims Thank you Yes I see that MR SCAROLA So that the record is clear the first paragraph attributes a statement to me but its not a quote Agreed MR LINK Yes sir MR SCAROLA But the second paragraph is a quote MR LINK I agree The second one is a quote MR SCAROLA Although I would acknowledge the statement attributed to me is at least an accurate summary of what I said say MR LINK Sounds like something you would MR SCAROLA It does MR LINK I agree BY MR LINK Did you take into consideration when you were looking at articles after August the fact that Mr Scarola had publicly denounced what Mr Epstein had done and said to the world that Mr Edwards was free and clear of any taint or allegations essentially that Mr Epstein brought MR SCAROLA Im going to object to the question as compound A I was going to say you kind of lost me on the main point there BY MR LINK Let me try it again So there are two statements in here that are attributed to Mr Scarola and one direct quote Do you agree with that A Yes I agree And Mr Scarola is making it clear that what Mr Epstein filed against Mr Edwards had absolutely no basis true A Yes that seems to be the point taken And did you take into consideration when doing your Internet research that on August 17th there was a public statement by Mr Edwards lawyer that he had essentially been SCAROLA uccessfur _discrediting 1teins-that9 MR LINK I take that MR SCAROLA I knew you would MR LINK That was really good Did you write down the next question That was excellent That was excellent THE WITNESS You two have a relationship here MR LINK For years Some days good some days bad Depends on how we re doing THE WITNESS Yeah thats a long relationship MR SCAROLA Its more a moment by moment MR LINK I think it is a moment by moment but always very much in respect of this gentleman THE WITNESS Thats right Thats the way it should be BY MR LINK So let me try that again MR LINK Did you write that down MR SCAROLA No I didnt but its on the record A I think I follow that BY MR LINK Okay A I just looked if the article contained the statements that I was looking for and whether whatever else was in the article filay PLd_:y-Q._ dQ a"tf fil a,rCh o-see-wQaj CID i-rn.paQO.h ft__t!_m nt fad n--roeth aders_ntp:lJ A NQ a,ftn:.iht hfil-her whaJ CD 251Pi-!iWn ere-fOI1 abQ_U__CM EdW nY9n h9 act any-oet11--orticl Cl cm A NQ a,ftn:.iht hfil-h crn i-rn.pa rw-h acters.ntP tn--forro.t:t:fg Pi-!iW bQUJ Wa _differe fter _s _a,rO mad i CD tft__t!zyient ader na rrua,Il act o.ne-oet11--ortrc1 haJ CDJ yOU-Cit o-iti:YQ._U pQ ill A NQ Can you quantify the total number of people that have read any one singular article about Mr Edwards just one article out of all of the ones that you have identified A A I dont understand quantify Yeah you found articles Correct Palm Beach Reporting Service Inc flgh.DJ ctentlf n_ persorw-naJ Q_t__Tia;Il ad n_e-6et_h 4-a;rt:icles Okay Well beyond me A Well you read them as part of your assignment Thats correct A How many hours did it take you to locate all of the articles A I can ballpark it Thats fair A Thats a ballpark A Yes Because theres also some other stuff going on there Hes better than you MR SCAROLA Hes a scientist at ballparking BY MR LINK You cant get it a little tighter than that Thats as good as it gets A I had to eliminate some times that I wasnt actually looking for articles And how many hours in total have you spent in developing your opinion that youre providing today A A A In developing the opinion For today Up through today I assume Oh you cant talk about the future Yeah I said I billed And then you know I did read some re-read my report and stuff for deposition so it would be three or four more hours A A something like that 20-something okay And you charge how much an hour All right Do you have any other opinions that youre working on in this case A In this case no And you have worked as an expert for Mr Edwards before correct A A Yes In what case was that sir That was the Giuffre Maxwell case Again it was a little I dont know Yeah the whole lawyering how you lawyers handle this I dont understand But yes as a lay person I would say I worked with him on another on that case Well its a case that you list with Mr Edwards name on in your resume isnt it A Yes Thats what I mean He kind of originally retained me but then went to another law firm so I just didnt understand Explain to me what you mean by that please So Mr Edwards originally retained you and then what happened A Then a different law firm I kind of dealt with a lawyer almost exclusively from a different firm So you know I dont know I listed them both All right And what work were you asked to do in that case A In that particular case I was asked to Ms Maxwell called Ms Giuffre a liar and so I had to look up the dissemination of those particular statements on-line So you were essentially doing the same work in that case for Mr Edwards that you re doing in this case for Mr Edwards A Other than the statements being different its very similar And there were some other things in this particular case Im sorry I didnt understand you A What Im saying there were a few other things but the basic process and procedures were the same Okay And the statement that you were provide in the Maxwell case was that that you were supposed to research was that provided to you by Mr Edwards A Not by Mr Edwards no By his co-counsel A Another lawyer involved in the case yes MR LINK All right I dont have any other questions Jack CROSS EXAMINATION BY MR SCAROLA You were asked questions about articles that quoted me and whether you had seen any articles that quoted defense counsel Do you recall that A Yes I recall that Go back to Exhibit Number if you would please A Yes sir In this exhibit there is in paragraph a direct quote attributed to me A Yes correct A I see that Palm Beach Reporting Service Inc It says quote This has been a long time coming and we re extremely anxious to have the opportunity for the first time to lay out in detail the terrible nature of Jeffrey Epsteins serial abuse of dozens and dozens of children unquote correct A Correct Its not possible to make a determination from whats included in this article whether that quote was from a statement made in court or out of court is it A Not to me no Okay Going down two more paragraphs it reads At a calendar call on Friday Crow told lawyers for both sides that he would have to specially set the trial because of several factors its estimated length Mr Epsteins criminal issues Ponzi-scheme allegations surrounding Edwards former boss and the expected length of the time it will take to select jurors I want you to assume that the Crow that is referenced as is described in the fifth paragraph is Circuit Judge David Crow Okay A Okay The next quote that appears is a quote from the Judge himself quote With Mr Scarola doing the voir dire its going to take a long time to get through the process Scarola said So we know that the Judge is being quoted as well correct A Crow Uh-huh correct And it is probably a reasonable MR LINK And I second the statement by Judge MR SCAROLA Both you and Judge Crow are likely accurate in that regard BY MR SCAROLA But apparently theres some court proceeding that was going on at which the Judge made this statement reasonable assumption A Reasonable assumption based on those two paragraphs yeah Then the next paragraph reads quote The people involved are pretty well-known said Chester Brewer one of the Epsteins attorneys after the scheduling session A Do you see that Yes I see that So we know assuming the accuracy of this report that Mr Epsteins lawyers were speaking or one of Mr Epsteins lawyers was speaking to the press outside the courtroom correct A That would be a taken yes Or at least after the scheduling session A Yeah Whether the conversation took place in the courtroom after the court proceeding or outside the courtroom this report A Yeah suggests that the lawyer was speaking to the press after the court proceeding And it goes on to say quote So it going to take a lot of prospective jurors to find somebody that doesn I already have an opinion in regard to some of the people involved Correct A Correct Okay Then we have the specific paragraph that you identified as a paragraph that qualified this article for inclusion in your count correct A Correct And if we go down to the bottom of the page we then have the following statement one paragraph up Fred Haddad Epstein I attorney declined to say whether his client will be in the courtroom and/or whether he will testify Then we have a direct quote attributed to another one of Mr Epstein I lawyers according to this article Fred Haddad quote We re defending this and we make decisions based upon what the plaintiffs do Haddad said When you I re on the defense you have to see what the offense does first The trial will be very interesting There are a lot of legal issues as well as factual issues Did I read that accurately A It seemed accurate to me yes Okay So going back to a question that was asked of you by Mr Link earlier he asked to whether there were quotes from Mr Epstein I lawyers in any of the press articles we have now confirmed that in at least this one article two of Mr Epstein I lawyers were both speaking to the press outside the courtroom correct A Correct Okay Did you actually read each of the articles that you were able to identify to be sure that there was a statement included in each of those articles that linked Bradley Edwards to participation in Scott Rothstein I massive Ponzi scheme A Yes I read either the entire article or up to the point where I found this statement All right So Mr Link has gone through a few of those and I not sure how he selected the ones that Palm Beach Reporting Service Inc he selected but hes gone through a few But if we were to go through each of these articles you would be able to identify a specific statement that associated Bradley Edwards as a participant in this massive Ponzi scheme is that correct A Thats correct I did it You have reached the conclusion that that information was disseminated to an audience of over million people correct A Correct Did you come to a conclusion as to the likelihood of whether the actual number of individuals to whom that statement was disseminated exceeded million people MR LINK Object to the form A Well yes as I MR SCAROLA Im sorry Before you answer the question whats the problem with the form MR LINK It assumes that the way you asked that readers actually saw the statement versus it being disseminated in the web page that people touched He testified he could not identify who in fact or the number that saw the statement MR SCAROLA Okay Well I think youve mischaracterized my question but just to be sure let me make sure that I ask the question in the way I intended it to be answered BY MR SCAROLA Can you tell us whether the conclusion you reached that these statements were disseminated to an audience of million people is a conservative MR LINK Same objection BY MR SCAROLA A conclusion Yes its a conservative very conservative number as I outlined in my report And describe for the benefit of the jurors if you would please why it is your opinion that the more than million number to which you have testified is a conservative assessment of the number of people to whom these statements were disseminated A Okay MR LINK Object to the form A I think to address this properly if I can just refer to my report By all means A as the best way to address it Well I had like reasons why I took a very conservative approach to the dissemination number calculation So likely much much more than The first is that obviously I couldn I locate all the articles by the time I filed my report So there I certainly articles out there that I haven I located by the time I submitted the report I only looked at on-line sources I didn deal with prints or broadcasts or anything like that I didn I So for example and I apologize for interrupting you But one of the websites that we ve particularly focused on is the Palm Beach Daily News also phone as The Shiny Sheet But what you looked at were electronic accesses to their website correct A That is correct You did not include the number of individuals who subscribe to that newspaper and have it delivered to their home correct A That correct I did not include those You didn I look at the number of times that people went to their local retail store and bought a copy of The Shiny Sheet That I not included in your calculations correct A Correct And the same would be true with regard to each of those websites which also has a corresponding hard copy publication the Palm Beach Daily News the excuse me the Palm Beach Post the Sun-Sentinel the Miami Herald The New York Times or any of the other periodicals that have both hard copies and website access correct A Correct Okay So you were describing the reasons why your number of distributions is conservative and I interrupted you So pick up if you would please A Yes I also didn I include statements in the book Filthy Rich that was distributed written by Mr James Patterson Okay There was an exhibit marked that made reference to that book That was Exhibit Number And while this exhibit makes reference to the book it is not one of those articles that contained Exhibit Number is not an article that contained an express reference to the relationship between Bradley Edwards and the Rothstein Ponzi scheme correct A That I correct But do you know whether the book itself contains express references to allegations that Bradley Edwards was a knowing participant in the Ponzi scheme A Yes I know it does Okay But you didn include any of those James Patterson books that were sold in hard copy that got distributed through electronic means or wound up as Palm Beach Reporting Service Inc audio books None of thats included correct Correct A And obviously you dont know how many times people who bought that book loaned it out to their spouses their friends and neighbors so that they coUlct read it correct A Correct Okay I have been given a notice that we are almost about to run out of tape so well break right there We take a short break let them change the tape THE VIDEOGRAPHER The time is We re now going off the record Thereupon at p.m a recess was taken until a.m after which the deposition continued as follows THE VIDEOGRAPHER The time is We re back on the record This is the beginning of Tape BY MR SCAROLA At the point at which we took our break you were describing for the benefit of the jury why the more than million number is a conservative estimate of the number of people to whom the statements that you have identified were distributed acknowledging that whether they read them or not is not something that youve looked at but these were people to whom they were distributed So why why else do you consider the number to be a conservative number A Yes I didnt include any face-to-face dissemination of people talking about the statements I didnt include any private on-line correspondence like e-mail and stuff like that There are more than likely sites that had the statements that I can no longer access And actually I ran into a few of those I just couldnt get the article the activities a few things like that So I didnt include those Of these sites that contained the article I only included traffic for percent of them because the traffic number for the other sites the other sites I just didnt feel comfortable that the numbers were valid So of the sites of that million plus even though the article I know the article was posted on the sites I only included the traffic for percent of those sites And why did you consider the other traffic numbers not to be reliable What distinguished those from those that you felt were sufficiently reliable A As I mentioned talked about this in my report They were typically sites that were very very large or very small So like you know some the larger sites it I that maybe I ll give you a good example here Like the PressReader for example that is a site that presents a lot of articles from a lot of different newspapers And so the traffic numbers that I was getting were you know very inflated I felt so I did not include those numbers On the other sites there are a lot of blog sites and stuff like that from individuals that didn I get a lot of traffic Again I felt that those traffic numbers were not reliable or I couldn I get them so I did not include those Okay Continue if you would describing A Yes the basis for your assertion that the million dollar numbers excuse me the million number is a conservative number A Yes I didn include sites that had articles where they didn I have the statements but a link to an article that had the statements So unless it actually appeared exactly in the article I didn I include it So someone could be at a different site follow the link and could actually see it but I didn include those Many of these sites publish multiple articles on multiple different days that contains the statements And there is an aspect of return readership So I didn I want to double-count traffic so just to make it very conservative even if they published seven articles or five I only counted it one time So I didn count the multiple days And then also search results Some of the queries that I was using you could submit the query and you could see the actual statements in the search results You didn need to go to the site So like on my report on page I give some examples there that just enter a query and you see the actual statements in the search results You don even need to go to the site to I mean you don I even need to technically read the article You just like search and type in the query Did you take into account in any way that multiple individuals may be accessing the sites simultaneously Come on over here and take a look at my monitor and see what I being reported about Brad Edwards A No I did not include those And what about the private forwarding of Palm Beach Reporting Service Inc website information did you take that into account at all A As I mentioned no I didnt do any e-mail or private forwarding or anything like that In conducting this work did you rely upon sources that are generally relied upon and considered to be credible and authoritative within your area of expertise A Yes Did you utilize methodologies that are generally accepted within your area of expertise as accurate means by which to reach the conclusions that youve reached A Yes And are the opinions that you have expressed both in your written report and in your sworn testimony today opinions that you hold to a reasonable degree of scientific certainty within your area of expertise A Yes MR SCAROLA Thank you I have no further questions MR LINK Just a couple REDIRECT EXAMINATION BY MR LINK Take a look at Exhibit that Mr Scarola was asking you about please A Yes sir Its The Shiny Sheet article October 20th Do you have that in front of you A Yes sir Mr Scarola pointed out a couple of places where Mr Epsteins lawyers were either quoted or had a statement attributed to them correct A Correct Would you please point to anywhere in this article where Mr Epsteins attorneys said anything about Mr Edwards A Well let me just look in the article I dont see a quote All right And Mr Scarola pointed out three different statements One by Mr Brewer and two by Mr Haddad And is there anything in what Mr Brewer or Mr Haddad said to the press that fits one of the search parameters you were looking for A A From those statements Yes sir that you were searching for No I thought that my question was you mean in terms of the article or in terms of the statements from those lawyers No the statements from the lawyers Mr Scarola went through in a painstaking way to show you the three references in this article to Mr Epstein lawyers And I asking you if Mr Epstein I lawyers made any statement about Mr Edwards that would have triggered a hit in your search results A Not that I see no Can you point to any article that you reviewed that contains a statement a quote by Mr Epstein I lawyer that would have triggered a hit on your search request A Okay Again I was just looking for the particular statements I didn analyze if it was a quote from a lawyer but I don recall any And do you recall any quotes from Mr Epstein himself in any of the news articles that you reviewed all that you told Mr Scarola that you read the entire article that had a quote from Mr Epstein that would have hit your search request A Before I answer this I just want to clarify You said that I I said that I either read the entire article or read it up to the point where I found the statement but I don I recall a statement from Mr Epstein Do you remember seeing a press release by Mr Epstein related to Mr Edwards in any way A A press release from Mr Epstein Yes sir A I don I recall a press release from Mr Epstein MR LINK Okay I have no other questions MR SCAROLA And I have no further questions MR LINK Thank you MR SCAROLA We will read THE VIDEOGRAPHER The time is We are off the record This concludes today deposition Thereupon the taking of the deposition was concluded at a.m Palm Beach Reporting Service Inc EXCEPT FOR THE CORRECTIONS MADE HEREIN ON THE ERRATA December DR BERNARD JANSEN c/o Searcy Denny Scarola Barnhart Shipley P.A Attn Jack Scarola Esq Palm Beach Lakes Boulevard West Palm Beach Florida In Re Case No Jeffrey Epstein Scott Rothstein et al Depo of Taken on of pages Dr Bernard Jansen December Held Until January Dear Dr Jansen This letter is to advise you that the transcript of your deposition taken in the above-referenced cause has been completed and is awaiting your reading and signing Please contact our office to make arrangements to read and sign your deposition transcript Our information is as follows Palm Beach Reporting Palm Beach Lakes Boulevard Suite West Palm Beach Florida Telephone If the reading and signing has not been completed prior to January we shall conclude that you have waived the reading and signing of the transcript Your prompt attention to this matter is appreciated Sincerely Iliana Lugo Court Reporter cc Scott Link Esq Esq Jack Scarola Esq Palm Beach Reporting Service Inc EXHIBIT IN THE CIRCUIT COURT or THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants VIDEOTAPE DEPOSITION OF BRADLEY EDWARDS May 15th A.M P.M East Las Olas Blvd Suite Fort Laudcrdnle FL Stenogrnpltically Reported By WENDY ROBERTS RPR Notary Public State offlorida Empire Legal Support Inc Fort Lm1derdnle Office Phone APPEARANCES A1TORNEY FORMR EPSTEIN TONJA HADDAD COLEMAN ESQUIRE lonja Haddad PA SE 7th St Ste Fon Lauderdale Florida Phone Fax E-Mail Tonja tonjnlladdad.com FRED HADDAD ESQUIRE Fred Haddad PA Financial Plz Ste Fon Lauderdale Florida I Phone Fox E-Mail lfaddadfin aol.com JACK GOLDGERGER ESQUIRE Atterbury Goldberger Et Al A11stralian Ave Ste West Palm Beach Florida Plione Fax E-Mail Jgoldbcrger u1 225wpa.co1n ATfORNEY FOR BRADLEY EDWARDS WILLIAM KING ESQUIRE Scarc;y Denney Scarola Et Al Palm Beach Lakes Blvd West Palm Beach Florida Pho11e Fax E-Mail Wbk senrcylaw.com ALSO PRESENT JElP EPSTEIN PLAINTIFF DEBRA FEIN l.,A CLERK Page INDEX WITNESS Page BRADLEY EDWARDS Direct fammination by MR HADDAD EXHIBITS PLAINTIFFS EXHIBITS Description Page No I part of Farmer Jaffe Wcissing Web site No from the Web sile No from the Web site No from the Web site No from National Trial Lawyers Web site No fromAVVO A-V-V-O No from the Fam1er Jaffe Wcissing Web site No from lawyers.com No from for under No interrogutories directed to Mr Edwards and responses No transcript ofthe sentencing proceedings for Alfredo Rodriguez No pica agreement between the United States and Alfredo Rodriguez Page Page Videotape Deposition taken before Wendy Roberts Registered Professional Reporter and Notary Public in and for the Slate of Florida at Large in the above cause TIIE VIDEOGRAPHER We are now on the video record Todays date is May 15th The time is a.m This is the video deposition of Bradley Edwards taken in the matter of Jeffrey Epstein Scott Rothstein Case No Were located at East Las Olas Boulevard Fort Lauderdale Florida The court reporter is Wendy Roberts the videographer is Anthony Estevez both with Empire Legal Would counsel please state their appearances for the record MR KING William King Searcy Denney Scarola Barnhart Shipley fol Mr Edwards MR HADDAD Fred Haddad on behnlfof Jeff Epstein MR GOLDBERGER Jack Goldberger Atterbury Goldberger Weiss on behalf of Jeffrey Epstein MS HADDAD COLEMAN Tonja Haddad Coleman on behalf of Jeffrey Epstein Pages to EMPIRE LEGAL SUPPORT INC Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts I Page produced this time record With resP.ect to reputation fbelievethat over the course of the last three nave aone a P.re!D darn good job resun-ecting any damage hat was aone to reP.utation in this communi Well lets lets start with that You dont you never had a reputation damage did you MR KING Objection form BY MR HADDAD Okay What damage if any did you initially have done to your reputation by the filing of a lawsuit against you that suggested that you were so aggressive as a lawyer someone was going to sue you A No the lawsuit that was filed against me MR KING Object to form argumentative A The lawsuit that was filed MR HADDAD Twas paying a compliment MR KING Yes Go ahead A The lawsuit that was filed against me said that I was part of some racketeering scheme said that I was involved in a Ponzi scheme that I was co-conspirator of Scott Rothsteins and that I was committing fraud and conspiracy to commit fraud A bunch of.criminal actions were alleged against me In fact I think the complaint was entirely crimes that I Page had committed as a lawyer which is the exact opposite of the type of reputation that you want as a lawyer With that being said that complaint the various motions making those allegations about me being some form of co-conspirator in a Ponzi scheme was repeatedly filed and stated on the record and in hallways over at the bankruptcy comt because every lawyer who was anybody in South Florida had something to do with the bankruptcy proceedings over at the bankruptcy court So had to go over there continuously and fend off these lawyers who believed that there must be some merit to it because somebody who has a lot of money is hiring lawyers who have a pretty good reputation to say these things theres got to be something to it BY MR HADDAD Name one case in which you were impleaded because of your alleged involvement with Scott Rothstein A I did not lose a single client Name one no name one person who impleaded you one other person in bankruptcy court whether it be the clawback scheme whether it be Shears whatever the hell he calls what he did whatever you call any of that stuff name one person that imp leaded you or asked you joined you as party or a A It didnt happen defendant or anything A That did not happen Name one person other than this lawsuit which well get into later other than this lawsuit Page what newspaper aicle what Daily Review article what any article accused you of being involved in the Scott Rothstein debacle A I cant recite them off of my head ls there any A I believe that newspaper a11icles were written when the lawsuit was filed about me and Scott being accused of being some co-conspirator in a Ponzi scheme yes All right There were newspaper miicles written quoting a pleading as opposed to someone suggesting you committed a criminal act is that correct A I dont know the distinction that you are trying to make Wel I worry about that later Im just asking you do you know whether or not it was someone quoting a newspaper a a a legal pleading or was it a individual making an accusation that you were a Page criminal A The legal pleading made an accusation that was a criminal and that was reported on Im asking you was there anything other was there any person reporter anyone any of the people you had all of these thousands of e-mails with anyone who suggested that you were a criminal other than the pleading filed that suggested because of Rothsteins inclusion of your cases as part of the basis for his Ponzi scheme that you were involved other than that lawsuit A People believed that I was involved Who expressed that to you Youre a young lawyer youre in the courthouse every day or almost every day youre around town correct A Yes You go to different 267estaurants Name one person that came up to you and said I cant believe you are not in jail you are a Ponzi scheme or you are anything name one person A There were lawyers over at the bankruptcy court when I had to sit there listening to the things that were being said that told me you are going to be a target of mine given this infonnation that we that that is being told to us by Jeffrey Eostein and Pages to EMPIRE LEGAL SUPPORT INC Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts LE?GQe Vf cGΛ zz s6?E Ẇw z2 d?Zc?3?T R?A?!z xw:ϒ 6O f䒪 ue 2p a ʒ?M Θv L?U t?DŽ yit?t P?N mI eO o??K G??U sf 7A szM I a xR??E Page Page BY MR HADDAD A Maybe I should pay more attention to those Well let me ask you this In things I dont know about all those old people A Do I believe that right now my_r putation isi Well you do have I look at it from what oetter tlian ifnas oeen at an_x time in the QaStiyes you do with them Come on Brad you have an ego All right And as a matter of fact since the everybody does At any rate you are considered in the Rothstein case youre now included probably one of the top under in that group comet youngest guys there is in Best Lawyers in America A Right correct And have you ever looked on the Web site for A Probably that group to see the type of lawyers that are included All right There are not many guys that have in that been practicing years to be included in that A No A I agree Okay And you have that distinction of being And that is percent for old people like included and you promote it with your as most lawyers Goldberger for the most part You are included in that would correct based upon peer review and nothing else A Personally I dont but I know that my law A Thats true finn does I mean we do have a PR firm for our law You finn A I mean I dont ac actually don know the Oh is that who does all of that stuff answer to that if you are saying thats what it A Yeah is it might be I mean this is about a months worth All Did you solicit anybody to become in that right A No A You looked at a lot more than have Did you receive a letter saying you have been I have to do something to earn the money I nominated for Best Lawyers in America make A I dont think so A Thank goodness right Page Page No you just got a notice one day that you Now you are also there is another service A Right called A VVO are you familiar with that are included correct A Yes A Right thats true All right And thats another unsolicited Out of the whole world out of thousands of out of the top under you cant buy your way into lawyers practicing law years you are notified hey that one either you didnt know you were getting that you are one of the best lawyers in America for what you correct do A Thats true A Right You get a notice hey you have just been Okay Now you also are one of the top included in all of this stuff whether you like it or lawyers under correct not you are conside1 one of the top lawyers in A Right Florida You are years old A Thats true A Correct Okay Then you have A VVO where people can And you are considered one of the top trial arrest arrest see arrest records two secrets lawyers in Florida under your name here I guess that is part of the A Right adve1tising that goes with having a Web site or There is a group called the Top Trial something Five Farmer Jaffe Weissing attorneys Lawyers in America correct recognizes the best lawyers in America that is pretty A think so good for a bunch of young lawyers yeah Thats part of what you are in A Yeah A Okay And A WO another one Do you participate in Yeah they have the top trial lawyers for their promotion A VVO they promote lawyers I think do old guys like Goldberger Scarola prut of his finn and you participate in that at all all those old people correct A Not really Pages to EMPIRE LEGAL SUPPORT INC Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Page me let you finish your question Page doesnt exist con-ect A Donald Baker is that the MR KING Objection MS HADDAD COLEMAN No its different THE WITNESS Oh different BY MR HADDAD Oh you got sued twice A Apparently All right And then did let me ask you about the I had it right here A I convicted some guy he went to prison and then sued the judge and every all the police and eve1ything else MR GOLDBERGER Here you go MS HADDAD COLEMAN This guys name is different MR HADDAD Yeah Shaarbay Sharbasom I guess that must be fv1R GOLDBERGER Spell it MR HADDAD the Arab guy S-H-A-A-R-B-A-Y versus A News to me BY MR HADDAD valious persons Were you ever served with a lawsuit Among the persons sued was A No Page Pete Weinstein Michael Gates Finkelstein Satz Dan Callahan Brad Edwards A No I dont recognize that persons name have never been served with that lawsuit to my recollection To your recollection okay A No All right But you said there was another one who else sued you A Oonald Baker sued me and Mike Satz and Michael Gates and all of the Hollywood Police Department And what happened with that case A It was dismissed All right Would those predate the time that you were sued by Mr Epstein A Yes Okay Now tell me how A Well I dont know about this new one that you just told me about it it may have been yesterday for all I know All right A I am unaware of it Emotional distress embarrassment mental anguish humiliation I will start with those because we know loss of reputation and standing in the community BY MR HADDAD You concede that MR KING Objection argumentative BY MR HADDAD Well would you concede never mind we went through it already A Yeah we we talked about this I understand Can you detail for me the emotional distress embarrassment mental anguish and humiliation A Okay that you have A Where I was beginning before Yes.sir A when we were talking about reputation I do believe that I have always practiced with the utmost honest integrity And when a lawsuit was filed against me accusing me of being dishonest and being a criminal or to truncate this and I had to continue to go to court and see lawyers who for a period of time and I do believe that once the case was dismissed against me that window closed but for a period of time they believed the allegations against me I think that there Page was probably a point in time based on some of the e-mails that I have seen that your co-counsel Tonja believed that which in tenns of hurt feelings type of things yeah that that wasnt that wasnt something that I appreciated either But having to be in a courtroom where lawyers believed that I had done these things that I had not done it was humiliating Now there is another aspect of it which I consider to be much more significant because as weve discussed the case was dismissed against me and I do feel that separate and apart from any involvement that I have had Jrosecuting cases against Jeffrey Epstein i have done a good job of resurrecting my reputation from he point in time where people initially believed hey where there is smoke there is fire or something this must be fil!il!Y of something And that was my perception of things and thats a reasonable perception based on what was filed All right And I dont want I am not going to be argumentative with you obviously but based upon what the entirely of what the Ponzi scheme is just being involved in it just being in that finn with your cases there would give that perception to people wouldnt you agree A No think that most lawyers escaped fairly Pages to EMPIRE LEGAL SUPPORT INC Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts EXHIBIT I IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA GASE NO JEEFREY EPSTEIN Plai11tiff vs SCOT.T ROTHSTEIN indiyidually a,nd_ BRA_DLEY EDWARDS individually Defendants I VIDEOTAPE DEPOSITION CONT ID OF BRADLEY EDWARDS VOLUME II OF II PAGES liO Obtobe 10th A.M East Las Olas Blvd Suite Fo Lauderdaie FL Stenogtaphit 1lf 6rted By WENDY ROBERTS RPR Notary Public State of Florida Empire Legal Support Inc Fait La 265derdale Office Phone EMPIRE LEGAL SUPPORT INC f4cfd Page are you claiming MR KING You asked the same question last time MR HADDAD I dont remember it I thought the last time we said you taking time away from your family and that stuff for economical MR KING He went but he went into great detail as you might recall where he talked about the fact that you know he would go to the he would go over to the Courthouse and lawyers would look at him and his reputation was was impacted by that and what what he was able to do to truncate that later on MR HADDAD Youre right BY MR HADDAD Do you still maintain that stuff A Ad aid thenJ ave I done a good job atj esurrecting whatever damage was done esJ 0idJ Is there is there What was the what was the impact to you from supposed and I dont mean that pejoratively damage to your reputation by being sued for being with Rothstein A Uh what for being falsely accused of committing crimes I didnt accuse by Epstein EMPIRE LEGAL SUPPORT INC f4cfd Page If newspaper articles that were printed after the filing of the claim against me is something that would support that then I guess to that extent yes but if you are asking about medical documents or anything like that then the answer would be no Im not exactly sure what you are getting at but I Well for example you are claiming your reputation was injured A Right And based on the elements of proof required to prove injury to damage to reputation there are certain factors that you must meet Right A Im asking if you have any physical documentation or any youve objected to all your financial information so I guess my question in plain English is How are you going to prove that you have any kind of pecuniary pecuniary loss as a result of an injury to your reputation if we dont have any documents to back that up A have not claimed an economic loss as esult of my reputatio I havent And the only thing that I can say to answer your question is I know who has hired me I will never know who would have hired me but elected not to because of what it was that they EMPIRE LEGAL SUPPORT INC f4cfd EXHIBIT I INTRODUCTION I have been retained by the law firm of Searcy Denney Scarola Barnhart Shipley PA to provide expert analysis and opinion on behalf of Mr Bradley Edwards in the case originally styled Jeffrey Epstein Plaintiff vs Scott Rothstein individually Mr Bradley Edwards individually and individually Defendant CASE NO which is pending in the Circuit Court of the th Judicial Circuit in and for Palm Beach County Florida II QUALIFICATIONS I am an adjunct professor at the College of Information Sciences and Technology at The Pennsylvania State University University Park Pennsylvania since where I have been employed since I was a tenure-track professor at The Pennsylvania State University from through departing as a tenured full professor in I am a principal scientist at the Qatar Computing Research Institute I was a Senior Fellow at the Pew Internet American Life Project which is part of the Pew Research Center from I was a University Expert at the National Ground Intelligence Center from through Prior to my employment at The Pennsylvania State University I was a Lecturer in the Computer Science Program at the University of Maryland Asian Division for year and before that I was an Assistant Professor in the Department of Electrical Engineering and Computer Science at the United States Military Academy a.k.a West Point for years In addition to my academic credentials my professional experience includes years of practice in the U.S military serving in the Infantry as an enlisted soldier and then as a communications officer working primarily in a variety of information technology-related positions I have authored approximately academic publications focusing on the areas of Web data digital analytics Web analytics Web searching Web search engines social media and related areas Approximately of my publications address aspects of search analytics Web analytics online advertising search engines or Web searching My recent research work focuses on online news analytics which is the investigation of the online qualitative and quantitative attributes of news stories with other digital content and social computing analytics which is the investigation of social behavior using algorithmic methods I am also the editor-in-chief of the international academic journal Information Processing and Management which is a top journal in information science field and former editor-in-chief of the journal Internet Research a top ranked journal in the web science domain I have authored co-authored or co-edited four books including Web Search Public Searching of the Web Understanding User Web Interactions via Web Analytics and Understanding Sponsored Search A copy of my complete Curriculum Vitae which includes a list of all publications I have authored in the past years is attached as Appendix A My fields of professional expertise include web analytics search engines web searching social media online advertising and related computer science and data science areas In the course of my academic career I have worked with a variety of search engines and information searching applications in order to understand user searching behavior on the Web and other environments For example as part of my Masters program in Computer Science I designed and coded a text-based search engine For my Doctorate program in Computer Science I developed a program interface for Web search engines and implemented it on the Gigabyte search engine In subsequent research I have worked with the Microsoft Internet Information Services IIS and Verity commercial searching systems As a computer scientist I have engaged and am experienced with the classic computer science areas such as programming software development algorithms and networking I have done extensive server set-up and log analysis As my masters project for example I designed and coded a tool for network performance evaluation and monitoring I have taught a wide variety of computer courses including microcomputing programming in various languages and the eh/Internet at both the undergraduate and graduate level Concerning user searching behaviors on the Web and web analytics I have worked directly with real-user searching data from several web search engines Ive also analyzed web data of visitor traffic and other attributes from a variety of websites and social media platforms Ive analyzed real-user data from online search marketing campaigns and user referral traffic to websites I have conducted research and teaching concerning aspects of websites including search engine keyword advertising Ive developed web analytics models and processes for analysis of business goals and I have used web analytics data in both my research and teaching Ive also conducted other research on user searching behaviors I have advised government agencies and companies in consulting and expert witness matters A list of cases in which I have testified as an expert in deposition or trial in the past four years is attached as Appendix I am being compensated for my work on this case at the rate of per hour I ASSIGNMENT AND MATERIALS CONSIDERED In providing my expert opinion I have been asked to respond to the following question What is the level of lisseminatwn oaefaming statements associating Mr:""Braalcyj Eilwaras with the illegal activities o"Mr:""Scott Rothstein as a result Jef!j-ey_ Epsteins lawsuit against Mr:""Eilwaras For brevity I refer to the statements associating Mr Edwards with the illegal activities of Mr Rothstein as a result of Mr Epsteins lawsuit as the defaming statements the statements or the defaming statements associating Mr Edwards with Rothstein illegal activities The defaming statements associate Mr Edwards with the illegal activities of a Mr Scott Rothstein who is a notorious Ponzi schemer Now a debarred lawyer he is serving a year prison sentence for operating the billion fraud from his Fort Lauderdale law firm office including forging the signatures of three federal judges on fake legal documents Prior to prison in addition to spending money lavishly via the fruits of his fraud4 he paraded as a philanthropist resulting in some recipients having to return his charitable gifts After originally fleeing the US with a reported million in US dollars he returned to the US agreeing to work with prosecutors in exchange for a reduced sentence However prosecutors withdrew the reduced sentence offer as they determined Mr Rothstein lied during the investigation and was attempting to hide assets My analysis is based on my experience training knowledge and education and is formed through the application of that experience training knowledge and education in the Ponzi schemer Scott Rothstein lied to feds and should serve 50-year prison term prosecutors say Miami FL Ponzi Schemer Scott Rothstein Gets 50-year Sentence Florida Ponzi schemer jailed for 1.2billion fraud currently serving a 50-year sentence and his wife officially divorce http ixzz4w3nn9pfa Miami FL Ponzi Schemer Scott Rothstein Gets 50-year Sentence scott-rothstein-gets-5 0-year-sentence Rothstein Reveals How Billion Ponzi Scheme Money Was Spent ponzi-scheme-money-was-spent The Ultimate Ponzi Scott Rothstein Book Excerpts Reveal Juicy Details https zi_ html Scott Rothsteins Cheating Life South Florida lawyer Scott Rothstein faces arrest in Ponzi scheme scott-rothstein South Florida lawyer Scott Rothstein faces arrest in Ponzi scheme Scott Rothstein Charged with Racketeering Ponzi schemer Scott Rothstein lied to feds and should serve 50-year prison term prosecutors say Rothstein Sentenced to Years Behind Bars Ponzi schemer Scott Rothstein lied to feds and should serve 50-year prison term prosecutors say principles of web data collection web analytics web search search engines websites web traffic analysis and related market analysis The materials that I considered in preparing this report are listed in Appendix IV SUMMARY OF OPINIONS Based on my research and analysis in connection with this assignment which is described in more detail in the body of this report along with my own experience training knowledge and education as stated I have reached the following opinion Theclef aming statements associating activities ME,ScoltRolhslein as a resulfo Jefif.Epstein s_lawsuit g,gainst Hr:Eawaros meaia or other sites in SeRarate stories or afficleswiih a comb7ilecF9 ROtentialaaily_ visitors since thelawsuit was tilecitolhecla ihat Tfileclthis report inclusive This number is conservative and it is more likely than not that the defaming statements have received wider dissemination due to factors discussed in more detail later in this report such as a It is a reasonable assumption that I have not located all references to the defaming statements on every website by the time of the submission of this report So there may be more sites with articles containing the defaming statements that are not included in my calculations The focus of my analysis was the online dissemination of the statements Therefore I examined only online sources and not the dissemination of the statements made via print or broadcast media It is reasonable to assume that the statements made were disseminated via these other channels I have not included dissemination of the defaming statements in the book Filthy Rich by authors James Patterson and John Connolly Therefore this source of dissemination is not included in my analysis In my analysis I have not attempted to measure face-to-face dissemination of articles containing the defaming statements Therefore these sources of dissemination are not included in the count of daily unique visitors Since I do not have access to certain online sources where articles containing the defaming statements may have been disseminated e.g email messages personal social media messages articles behind firewalls etc these sources are not included in the count of daily unique visitors Given the nature of the Web there are possibly sites that have hosted the defaming statements that I could not locate or where the statements have been removed Therefore these sources of dissemination are not included in the count Also there are sites that hosted the articles containing the defaming statements where the visitor data is not accessible or where I could not confirm the number of visitors In these cases even though I had confirmed the site had posted one or more articles containing the defaming statements I did not include these sites in my calculation of the unique daily visitors I did not consider the dissemination via social media platforms of articles containing the defaming statements Therefore these sources of dissemination are not included in the count of daily unique visitors James Patterson and Jolm Connolly Filthy Rich A Powerful Billionaire the Sex Scandal that Undid Him and All the Justice that Money Can Buy The Shocking True Story of Jeffrey Epstein Little Brown and Company There were many sites that published multiple articles on multiple days that contained or referenced the defaming statements however I did not use these multiple articles from the same site with different publication dates in my calculations in determining the number of daily unique visitors who have been exposed to the articles containing the defaming statements I did not include unique daily visitors to articles that link from that article to one or more of the articles containing the defaming statements unless the article directly referenced the defaming statements I did not include it in my analysis I did not include the number of individuals who after reading the articles shared the articles or contents contained within those articles with others which would include multiple individuals reading the same article at or about the same time at the same computer as well as all individuals who learned of the content of the articles from others who had read the articles Finally I did not include the counts of those who may have been searching and saw the defaming statements made in the search results listing BACKGROUND WEB ANALYTICS FOR TRAFFIC ANALYSIS In the course of forming this opinion I implemented numerous web analytics and related techniques commonly used in the industry In order to more clearly discuss these techniques I define the following terms Direct Traffic visitors to a website that come from entering a website link into a browser location bar e.g not coming via a link on another website Dissemination the act of spreading or the circulation of information or articles Domain a specific Internet website that are administered as a unit and defined by an Internet Protocol IP address Reach the percentage or number of people who visit a website out of the total targeted population Referral Traffic visitors to a site that come from websites other than search engines Repeat Visits visitor traffic to a website in a given period that just includes multiple visits from the same set of IP addresses i.e IP addresses with more than one visit provides a count of the people who have visited a site more than once in a given period An individual is usually defined by a combination ofIP address and browser within a given period but can also be defined by more sophisticated methods Search Engine a program and associated hardware and processes that allows people to find information on the Web typically via the submission of queries consisting of terms Search Traffic visitors to a site that come from search engines rather than from other websites or via direct navigation Search a submission of a query to a search engine usually in the form of terms forming a query Share sharing of an article or webpage typically via some social media platform Social Media content that is shared via a social networking website nigue Visits visitor traffic to a website within a given period that includes only the first visit i.e subsequent visits are ignored which excludes repeat visits provides a count of the individuals who have visited a site in a given period Unique Daily Visitors visitor traffic to a website who visits a site at least once in a given 24-hour period Each visitor to the site is counted once during the reporting period which means it excludes repeat visits provides a count of the individuals who have visited a site on a given day Visits a count of all the traffic to a website in a given period including both unique and repeat visits Web Analytics the measurement collection analysis and reporting of web data In forming my op1mon I utilized accepted web analytics and related methodologies To that end I employed various publicly available online analytic services as well as subscription-based services in conducting my research including Alexa an online service that provides web traffic data and analysis Google Keyword Tool an online service that provides the number of searches for a given set of keywords in a given month on the Google search engine Google Trends an online service that shows how often a particular term is relatively searched on the Google search engine in a given period Quantcast an online service that provides web traffic data and analysis SimilarWeb an online service that provides web traffic data and analysis These tools offer a variety of data and analysis services and they are frequently utilized by industry professionals in the search engine optimization web analytics and search engine marketing fields for the market customer and competitive analysis Furthermore where possible I did my own assessments as outlined below in order to validate the data and analysis results I also utilized search engmes primarily Google and Bing to assess the dissemination of articles containing the statements When necessary I used multiple data sources which is a data verification technique known as triangulation where one uses multiple and disparate sources for analysis and then compare the results from the separate analysis If the results are similar it reinforces the conclusion that the overall data analysis is valid In situations where I believed that I could not adequately verify the number of individuals or did not have confidence in the numbers in those situations I did not include those numbers in the calculation Concerning the accuracy of the analysis the number of domains where the statements have been disseminated is reliable as this is straightforward to verify i.e the article is either posted on a site or it is not and the article either contains the defaming statements or no If anything this is an undercount as some domains for example may have removed such articles making them no longer available There are possibly articles containing the defaming statements that I have not been able to locate by the time that I submitted this report Concerning traffic numbers for domains the traffic services I used are the de facto industry standard with billions of dollars in online advertising spend being based on these and related numbers Therefore I consider them reliable for the purpose employed here Triangulation social science 28social_ science U.S Digital Advertising Will Make Billion This Year Says EMarketer My analysis is based on my experience training knowledge and education and is formed through the application of that experience training knowledge and education in the principles of web data collection web analytics web search search engines websites and related areas VI To isolate these articles of interest I generated a series of queries that specifically targeted news articles from the case that addressed the defaming statements e.g Jeffrey Epstein Scott Rothstein and Bradley Edwards lawsuit to retrieve a set of articles that directly related to the defaming statements I employed a modified snowball technique starting with one seed query adding and modifying terms until I was not retrieving new results I also located some articles via navigating from the set of retrieved articles An example of a search engine results page in response to one of these queries is shown in Figure Figure Google search results for the search edwards epstein Ponzi scheme edwards epstein edwards epstein Ponzi scheme brad edwards Ponzi brad edwards lawyer Ponzi brad edwards dirty lawyer Jeffrey Epstein Scott Rothstein and Bradley Edwards lawsuit Edwards Epstein Attorneys Suit Against Billionaire Allowed as Long as Justices Say Its OK Just an Ordinary Guy Lawyer Dishes on Surviving Rothstein Battling Epstein In addition to the queries I located some articles via direction navigation Google I edwards epstein Ponzi scheme All News Images Videos More Settings Tools About results seconds Jeffrey Epstein paid to settle lawsuits I Page Six https://pagesix.com/2017 Oct Rothstein is serving a 50-year sentence for running a billion Ponzi scheme Epstein had sued the Florida attorneys claiming Edwards Jeffrey Epstein paid women million to end sex lawsuits w.palmbeachpost.com/news/crime epstein 8GEJk4YYa2X4ffig4HAqyJ Oct Palm Beach billionaire Jeffrey Epstein paid million million that Edwards had nothing to do with Rothsteins Ponzi scheme PALM BEACH PERV Jeffrey Epstein Paid Victims MILLIONS w.gossipextra.com/2017 Oct Epstein has sued both lawyers alleging that Edwards invented the sex-slave narrative to perpetuate the Ponzi scheme overseen by Rothstein Newest lawsuit against Epstein expected to include victim epstein CZ14sOESbOQ4rib7njc1hL Oct One or more victims of Palm Beacher Jeffrey Epstein are expected to testify criminal issues Ponzi-scheme allegations surrounding Edwards Billionaire Jeffrey Epstein shells out more money in latest sex abuse w.nydailynews.com Dec Epstein has filed a suit charging that Edwards took part in a Ponzi scheme in which his former law partner Scott Rothstein gulled investors by ti II I I then personally verified that each article contained the defaming statements by reviewing each article used in my analysis to ensure that the articles directly referenced in some way the defaming statements So articles relating to the overall story that did not mention the defaming statements were not included in the analysis In the end I had a set of online news articles or stories to the date that I filed this report that specifically referenced the defaming statements to conduct my analysis as outlined below These articles are listed in Appendix Each of these online articles was posted online The online articles were distributed among unique domain websites i.e some websites posted multiple articles that contain the statements These domains are also listed in Appendix with the specific articles links As seen from the list of domains that have published articles or stories containing references to the statement many of these domains are those of major news organizations or sources including BuzzFeed Forbes New York Daily News Page Six Radar Online The Daily Mail The Telegraph etc There are regional Florida newspapers where Mr Edwards law office is located that published articles containing the defaming statements including The Palm Beach Daily News and The Palm Beach Post I then used a variety of web analytics traffic services and other sources to get the unique daily visitor traffic for each of these domains I used multiple services when necessary to get the unique daily visitor traffic for each of these domains as these traffic services may use different techniques to arrive at their traffic numbers In end I used primarily SimilarWeb as the service was generally providing the most consistent results across websites In cases where I determined I could not get unique daily visitor traffic numbers or the unique daily visitor traffic was not reliable in my opinion I did not include the unique daily visitor traffic numbers for that domain in the numbers This usually occurred for the sites with a smaller number of daily visitors or sites with an extremely large number of daily visitors Unique daily visitors measure is an industry standard web analytics metric for measuring people that visit a website in a given day also known as unique audience It is generally averaged out over multiple days with a given period such as week or month as there are normal daily fluctuations Table shows the unique daily visitor traffic for the listed domains that posted articles or stories referencing the statements and the associated unique daily visitor traffic for each of those domains along with the number of articles containing the defaming statements posted on that site Table Domains that published articles or stories containing the defaming statements with the domains number of unique daily visitors and the number of articles containing the statements published on that domain to the date that I filed this report Domain Unique Number No Domain Visitor Traffic of Articles Daily Published a aangirfan.blogspot.qa a able2know.org abovethelaw.com absolutewrite.com amlawdaily.typepad.com a anonhq.com archive.org articles.sun-sentinel.com books.google.com.qa cannonfire.blogspot.qa a casetext.com deeppoliticsforum.com a docplayer.net docuri.com forum davidicke com fullcontentdail com a Nielsen Online Ratings Metrics Guidelines Domain Unique Number No Domain Visitor Traffic of Articles Daily Published girlsiustwannahaveguns.com ijr.com ionathanturley.org law.justia.com lawnewz.com mondoweiss.net nesaranews blo gspot qa novaordemnews.blogspot.qa a pagesix.com a radaronline com seeker401 wordpress.com a sites.eveyo.com static squarespace com tabublog.com a theawarenesscenter.blogspot.qa a thegoldwater.com themillenniumreport.com w.4dca.org a w.abaiournal.com w.alecomm.com a w.browardpalmbeach.com w.buzzfeed.com w.courthousenews.com w.dailybusinessreview.com a w.dailymail.co.uk w.democraticunderground.com w.documentcloud.org w.facebook.com w.fairfaxunderground.com w.floppingaces.net a w.floridabulldog.org a w.forbes.com w.freerepublic.com w.garyeto.com a w.gossipextra.com w.gpo.gov w.ieyenews.com a w.justice-integrity.org a Domain Unique Number No Domain Visitor Traffic of Articles Daily Published w.law.com w.1aw360.com w.librarything.com w.nydailynews.com w.pacificpundit.com w.palmbeachdailynews.com w.palmbeachpost.com w.pressreader.com w.reddit.com w.rigorousintuition.ca a w.scribd.com w.slideshare.net w.sott.net w.talkleft.com a w.telegraph.co.uk w.the5thestate.asia a w.veteranstoday.com w.yumpu.com a Unique daily visitor traffic not available Unique daily visitor traffic not verifiable As shown in Table there are domains that hosted articles containing the defaming statements against Mr Edwards with these defaming statements begin disseminated to conservatively a potential daily visitors to these websites I used each domains unique daily visitor count to calculate the dissemination of the articles containing the statements to various websites and potentially to visitors to that site i.e as visitors to the news sites these individuals could have been exposed to the articles containing the statements using the unique daily visitor number only once for each domain regardless whether that domain published more than one article referring to the statements VII RESULTS FOR ANALYSIS OF THE DISSEMINATION OF THE DEFAMING STATEMENTS AGAINST MR.EDWARDS Based on my analysis as outlined above my opinion is that the defaming statements associating Mr Edwards with the illegal activities of Mr Rothstein as a result of Mr Epsteins lawsuit against Mr Edwards have been disseminated to at least online media or other sites in separate stories or articles with a combined potential daily visitors since the lawsuit was filed to the date that I filed this report inclusive This is a conservative number and more likely than not articles containing the defaming statements made have been disseminated to more individuals VI WHY THE NUMBER IS CONSERVATIVE This is a conservative number and it is more likely than not the defaming statements have received wider dissemination due to factors such as a Although I spent considerable effort to locate published articles that contained the defaming statements it is reasonable to assume that I have not located all such articles by the time of the submission of this report So there are most likely more sites with articles containing the defaming statements that are not included in my calculations which would increase the dissemination of the articles on domains and increase the traffic count The focus of my analysis was the dissemination of online articles containing the defaming statements and I examined only online sources and not print or broadcast media I have not included dissemination of the defaming statements in the book Filthy Rich by authors James Patterson and John Connolly As Mr Patterson is a well-known author the book had an initial printing of is well ranked in Amazons electronic book James Patterson and Jolm Connolly Filthy Rich A Powerful Billionaire the Sex Scandal that Undid Him and All the Justice that Money Can Buy The Shocking True Story of Jeffrey Epstein Little Brown and Company FILTHY RICH PATTERSON JAMES CONNOLLY JOHN CON MALLOY TIMOTHY CON NE Y-JOHN-CON-MALLOY-TIMOTHY-CON trkparms and other sections and also a top USA Today top selling book The book is available and/or has been reviewed on at least websites including USA Today New York Journal of Books The Daily Beast and the New York Post and is available from major online retailers including Amazon Wal-mart Barnes and Noble and eBay among others as shown in Appendix This source of dissemination is not included in my calculation In my analysis I did not attempt to measure face-to-face dissemination that may have occurred after individuals may have read articles containing the defaming statements which would increase the count Therefore this is not included in my calculations Naturally I could not access certain online sources where the defaming statements made may have been disseminated e.g email messages social media messages articles behind firewalls etc Therefore these numbers are not included in my calculations Also there are possibly sites that have hosted articles containing the defaming statements where the articles have been removed Therefore they are not included in my calculations For sites where one or more of the articles containing the defaming statements are posted but where I could not locate or not determine reliable daily unique visitor traffic I have not included these sites in my calculations I did not include the dissemination of the articles containing the defaming statements directly to social media platforms Filthy Rich A Powerful Billionaire the Sex Scandal that Undid Him and All the Justice that Money Can Buy The Shocking True Story of Jeffrey Epstein https w.amazon.com/dp/BO 1EFL9BMC/ref dp-kindle-redirect encoding UTF8 btla Patterson takes on sordid Jeffrey Epstein case in Filthy Rich https://w.usatoday.com/story filthy-rich-jeffrey epstein patterson I did not include articles that link to one of the articles containing the statements in my calculations of dissemination Unless the article directly mentioned the statements I did not include that article in my calculations Many sites published multiple articles on multiple days that quoted or referenced the statements however I did not use these multiple publication dates from the same site in my calculations of unique visitor traffic If a domain published only one article containing the statements then I directly used the unique daily visitors number If a domain published multiple articles concerning the statements I did not count the traffic for the subsequent articles containing the statements made even though research shows that repeat traffic to websites is generally only about meaning that of the traffic would be unique However I was not comfortable using this figure given the nature of these sites which might have higher repeat visitors day-to-day Therefore I did not include the visitors to multiple articles in my calculations Finally I did not include the count of people who may have been searching and may have seen the statements made in the search results without needing to visit the actual articles which can easily happen as shown in Figure Figure Example of search results with the defaming statements appearing in the result snippets requiring no need to visit the website hosting the articles themselves Teevan Adar Jones and Potts History repeats itself repeat queries in Yahoos logs In Proceedings of the 29th annual international ACM SIGIR conference on Research and development in information retrieval SIGIR ACM New York NY USA Google I edwards epstein Ponzi scheme All News Images Videos More About results seconds Jeffrey Epstein paid to settle lawsuits I Page Six https://pagesix.com/2017/10/04 uits Settings Tools Oct Rothstein Is serving a 50-year sentence for running a billion Ponzi scheme Epstein had sued the Florida attorneys clalming Edwards Jeffrey Epstein paid women million to end sex lawsuits w.palmbeachpost.com/news/crime epstein 8GEJk4YYa2X4ffig4HAqyJ Oct Palm Beach billionaire Jeffrey Epstein paid million million that Edwards had nothing to do with Rothsteins Ponzi scheme PALM BEACH PERV Jeffrey Epstein Paid Victims MILLIONS Oct Epstein has sued both lawyers alleging that Edwards Invented the sex-slave narratiVe to perpetuate the Ponzi scheme overseen by Rothstein Newest lawsuit against Epstein expected to include victim epstein CZ14sOESbOQ4rib 7njc1 hU Oct One or more victims of Palm Beacher Jeffrey Epstein are expected to testify criminal issues Ponzi-scheme allegations surrounding Edwards Billionaire Jeffrey Epstein shells out more money in latest sex abuse N1.nydailynews.com Dec Epstein has filed a suit charging that Edwards took part in a Ponzi scheme In which his former law partner Scott Rothstein gulled investors by tt __ __ XI SUMMARY OF OPINION The defaming statements concerning Mr Edwards have been disseminated to at least online media or other sites in separate stories or articles with a combined individual unique visitors to the date that I filed this report inclusive More likely than not this is a conservative estimate Right to Amend Although I have had access to materials publicly available pertaining to claims in this dispute I have not been able to review all the material by the deadline for completion of this report I reserve the right to review and rely on any such material including at the time of trial I also reserve the right to issue a supplemental or an amended report if my review of such material results in any significant change or addition to my opinion DATED October Respectfully submitted A Dr Bernard Jansen Adjunct Professor College of Information Sciences and Technology The Pennsylvania State University University Park PA Email jjansen acm.org URL 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