cynthla hopklns ffT6c2ea Page theyre claiming I never juxtaposed that with what I believe should be the proper amount But beginning with the fact that I do recognize that as the amount that they are claiming I was not aware that the costs were that high The cases were finn cases paid for by the finn I was simply an employee and I made judgment calls If somebody had told me at any given time we shouldnt serve these subpoenas or we shouldnt take this deposition I wouldnt have done it In fact with regard to well let me ask you this Were any informants did you authorize your investigators to hire informant infonnants MR SCAROLA Same objection same instruction BY MR CRITTON Did you authorize your investigators to do electronic eves dropping MR SCAROLA Same objection same instruction BY MR CRITTON You indicated that you were just an employee correct A Yes Page Okay In fact you on various documents reflected that you were a partner of the firm oorrect A Yes docwnent docwnents do reflect that title of course yeah And ifl had asked for a card during the time that you started at RRA up wttil the time of the implosion of the finn in late October of09 would your card have also reflected that you were a partner of the finn A I think you did request a card I think gave it to you and I believe that it did say partner on And you would agree that at least up until the time of the implosion of RRA you held yourself out to the public and including other lawyers as being a partner of RRA true A What do you mean by held myself out to the public Youcalledyourselfapartner Youdidnt say Im an employee Im not a partner correct You held yourself out to the public as being a partner MR SCAROLA Im going to object to the fonn of the Question to the extent that it Page suggests that those tenns are mutually exclusive THE WI1NESS lbat was a part of my answer is that I dont lmow MR CRITTON I am shocked to hear that THE WITNESS I dont know that being an employee means that you cant also be a partner There are equity partners and non-equity partners to nearly every single large finn so I was a non-equity partner otherwise known as a salaried employee lbats just the way it was BY MR CRTITON But your card just reflected partner as did your A Rather than that whole script I just told you Right Rather than the qualifying provisions A Yes youre right The qualifying positions didnt make the card With regard to the monies that was that were being paid by by Rothstein Im sorry by the RRA firm for the costs let me strike that During the time that you were at the RRA firm the seven months that you were there from April through Page the end of October do you recall any significant settlements that were coming into the firm that is that were publicized A Do I recalt significant settlements Correct A coming into the finn that were publicized Correct A I believe I cant say with any degree of specificity whether I remember anything that falls into all of those categories Now I forgot my question for a minute If I understand your answer and assuming I remember my question Mr Edwards you dont recall any significant settlements coming into the finn that were that were publicized either internally within the film or within the newspapers is that a fair statement A Fair statement Where did you think all of the money that was coming from let me strike that At that time how many lawyers were there in the Fort Lauderdale office that is during the time you were there A I dont know Best estimate A Seventy Pages to PROSE COURT REPORTING AGENCY INC Elecironlcally signed by cynthla hopkins Etectronlcally signed by Cynthia hopkins Electronlcally signed by cynthla hopkins Page Okay And the support how many floors did RRA occupy in the Fort Lauderdale A I believe six And approximately how many square feet on each floor A I dont know A lot More than square feet on each floor A I dont know And what was the support staff at the time that you were there approximately A In quantity or quality Quantity the number of people A I dont know A lot of people Did you do any hourly billing yourself at all or were you strictly a contingency fee person A percent contingency And with regard to the monies that were separate and apart from the Epstein Epstein cases where at least you now know that they cost between three and you were I assume incurring other expenses on other cases true A True All right And where did you where did you think that the money was coming from that is Page the source of the money to pay the extensive bills that were being incurred on Epstein and other cases JvIR SCAROlA I am going to object to the extent the question calls excuse me Im going to object because there is no proper predicate to the question and that is that it was a matter that was ever given a thought by Mr.Edwmds a MR CRITION Is that fonn Fonn is adequate so you dont have to instruct him MR SCAROLA Thank you THE WITNESS Whats the question BY MR CRITTON What did you consider what did you believe was the cost that is the source of the money that was used to be paying these extensive costs that were being incurred in Epstein and other cases 1R SCAROLA Objection MR CRITTON Just of yolS and yours alone MR SCAROLA Objection fom1 and compoWld TIIE WITNESS The law finn Page BY MR CRITTON Where did you think the law firm let me strike that Did you ever discuss with anyone whether it was from current cash that was being used or whether they had a line of credit or both A Didnt know Mr Edwards did you come to learn that investigators had that investigators had gone to Mr Epsteins property on March 17th A No Did you ever authorize any investigators to enter Mr property sic Mr Epsteins property on March 17th I MR SCAROLA Objection Instruct you not to answer on the basis of work product privilege BY MR CRITTON Let me just be clear Are are you aware of any investigators who entered Mr Epsteins property on March 17th MR SCAROLA Same objection as well as attorney-client privilege and instruct you not to answer BY MR CRITTON Mr Edwards did you authorize any Page investigators to trespass on Mr Epsteins property on March 17th of IO MR SCAROLA Same objection and instruction BY MR CRITTON Mr Edwards did you authorize investigators to hide in the bushes at Mr Epsteins house in order to take photographs of either Mr Epstein or any associated objects on his property MR SCAROLA Same objection and instruction BY MR CRITTON Mr Epstein Mr Epstein Mr Edwards do you know a lady name Christina Kittennan A Yes Okay And who how do you know her A She was a lawyer at Rothstein Rosenfeldt Adler when I was a lawyer at Rothstein Rosenfeldt Adler Did you have any dealings with her on any of your cases A None Vb.at did you understand her area of practice A Never lmew Pages to PROSE COURT REPORTING AGENCY INC Electronically signed bycynthta hopkins Electronically signed by cynthla hopkins Electronically signed by cynthla hopklns Page Page Did you know an individual by the name of instruction Patrick Roberts MR CRITTON Says he doesnt lmow them A Yes How can that be an instruction Okay And who is Mr Roberts during that MR SCAROLA Well because I am not going is what did Mr Roberts do for RRA to tell you were not going to permit A He was an investigator Mr Edwards to answer any questions about Did he ever perfonn investigation work on either what he did or what he didnt do that any of the Epstein files are part of the work product involved in his i 1R SCAROLA Same objection same representation of the Plaintiffs with claims instruction against Mr Epstein whom Mr Edwards is BY MR CRITTON representing Did you ever authorize Mr Roberts to MR CRITTON Did you ever perform investigation on the Epstein files MR SCAROLA So in light of that and MR SCAROLA Same objection and what I have attempted to make very clear with instruction regard to the scope of our objections if you BY MR CRITTON continue to ask questions which it is clear All right I asked you earlier about fall within the scope of my instructions to Richard Fandrey F-a-n-d-r-e-y I think you said Mr Edwards and my announced intention with you dont know who that you knew someone named regard to the scope of those instructions then Rick is that correct we will tenninate this deposition so that I can A I know an investigator named Rick seek a protective order Did Rick did Rick perform any My suggestion is that you move onto other investigation on the Epstein did you authorize Rick areas that are outside the scope of that to perform any investigation on the Epstein files instruction if you have any other questions MR SCAROLA Same objection and outside the scope Page Page instruction MR CRITTON Oh I have a lot of other BY MR CRITTON questions And I believe we talked a little bit MR SCAROLA Okay about we certainly talked about Mr Jenne did you MR CRITTON Let me be clear with you ever authorize or direct lvfr Jenne to perform any with regard to any for purposes of following investigation on the Epstein files asking any follow-up questions should the court MR SCAROLA Same objection and determine that I am entitled to this instruction information you would l_g?"ee that should the BY MR CRITTON court detennine I am entitled to ask the name Are you familiar with the company called of these individuals and possibly other Blue Line Research and Development questions is is that by not asking questions I A No am in no way waiving my right to ask as many Are you are you a-ware at the current time questions as the court ultimately detennines as that there is an entity called Blue Line Research appropriate proper and as the court allows and Development which is composed of Mr Roberts co1Tect Mr Richard Fandrey Mr Michael Fisten and Ken MR SCAROLA I absolutely agree Jenne MR CRITTON All right A No BY MR CRITTON If youre unaware of the existence of the Mr Edwards are you familiar with a entity called Blue Line Research and Development person named Alfredo Rodriguez LLC would it be a correct statement that you have A Yes never authorized anyone from Blue line Research and And how do you know Mr Rodriguez Development LLC to conduct any investigation of A Who do I know him to be How do I know him Jeffrey Epstein I met him the same well I met him after you did 1v1R SCAROLA Same objection same after you and your investigators pre-depoed him on three Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopldns Electronically signed by cynthla hopklns Electronically signed by cynthla hopklns Page various occasions for a total of about hours before we took this deposition I met him for the first time during that deposition MR CRlTION Let me move to strike as nonresponsive BY MR CRITTON My question to you is when did you first meet Mr Rodriguez MR SCAROLA And you have an answer to that question THE WITNESS Its a very complete answer I the day of his deposition BYMR CRITTON Had you ever spoken with Mr Rodriguez before that time A No Okay Had anyone on your behalf spoken with Mr Rodriguez A No Mr Rodriguezs deposition occurred over a two-day period is that correct Two separate days A I believe thats right And you were present for both of those depositions is that correct A Yes Page And the first one I believe at least in looking at the transcript the first one occurred on January 29th of A Im assuming And the second the followwup was on August 7th correct A When was the first January you said Excuse me Im sorry July 29th A Okay With the follow up July rm sony August 7th A If you say so Im not quarreling with that And I will just represent that is what I read off the transcripts Between those two dates that is July 29th and August 7th of did you speak with Mr Rodriguez at all MR SCAROLA Same objection same instruction to the extent that any such a conversation may have occurred in connection with your representation of the Plaintiffs and claims against Mr Epstein BY MR CRITTON All I am asking right now not the substance but just so the record is clear I am just askin2 did vou soeak with Mr Rodri2.Uez between Page July 29th and August 7th A And if I did or if I didnt either way thats going to be protected by the work-product privilege and rm not going to give you that information because you re not entitled to it disagree even in a simple attorney-client privilege you also you identify the date you dont identify the subject but you identify the date who may have been present MR SCAROLA We understand your position and its not necessary to articulate it on the record MR CRITTON I just want to be clear And your position is the same is youre not talking MR SCAROLA Work-product MR CRITTON ork 225product correct MR SCAROLA Thats correct BY MR CRITTON Mr Rodriguez was requested to bring documents to his second deposition that he had referenced that he might have Do you recall that from the first deposition Mr Edwards A I do And in fact when he came to the second Page deposition he didnt bring any documents with him did he A I dont remember Well do you remember him producing any documents at the second at his completion of his deposition A I dont remember Do you recall him saying that he might have some sort of book or some sort oflist ofnames and addresses and/or names excuse me of females who may have come to Mr Epsteins house along with phone numbers A I dont remember if he said that or it says that in the police report but I remember that information at some point in time All right And subsequent at the conclusion well let me strike that Do you recall receiving any documents from Mr Rodriguez that were produced at his deposition that had the names and addresses and/or phone numbers of any other females A I dont know Do you We were there together I dont remember specifically I think the answer is no And I think youre right Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by eynthla hopklns Electronically signed by cynthia hopklns Electronically signed by cynthla hopklns Page A Okay We agree on that A Okay Subsequent to the deposition that is after Mr Rodriguezs deposition did Mr Rodriguez contact you MR SCAROLA Objection instruct you not to answer MR CRITTON Well this is okay This is a third party contacting Mr Edwards All right MR SCAROLA It is not MR CRITTON Its just a yes or no Im looking for MR SCAROLA It is a witness in these proceedings MR CRITTON So MR SCAROLA So anything that Mr Edwards has done or may have done in connection with his investigation and prosecution of the claims against Mr Rothstein it is our position is not the appropriate subject matter of inquiry in the context of this lawsuit and is an attempt to invade the attorney-client and work-product privi1eges I Page am instructing him not to answer If the court if the court determines that the scope of the privilege permits a response to these questions we would be happy to respond to them But we have an obligation to to Mr Edwards clients to protect their rights to a fair trial and their rights to confidentiality and for that reason we are obliged to interpret those privileges in their broadest sense unless and until the court decides that a more restrictive interpretation should be applied BY MR CRITTON Between the first and second deposition of Mr Rodriguez I think you I think you indicated that you did not speak with him is that correct A Youre asking me if I indicated to you previously during this deposition whether Right A I spoke to him or not I I dont remember Did you speak with Mr Rodriguez between his first and second MR SCAROLA Same obiection same Page instruction BY MR CRITTON Did lvlr Mr Rodriguez ever make a request of you at any time for any type of monies for testimony documents or any other information associated with any existing or potential claimants directed to Mr Epstein MR SCAROLA Same objection and instruction BY MR CRITTON Subsequent after Mr Rodriguez or from the time that Mr Rodriguez completed his deposition on August 7th of did you have an occasion to speak with either the FBI well with the FBI regarding Alfredo Rodriguez MR SCAROLA Same objection and instruction BY MR CRITTON Did you after Mr Rodriguezs completion of his deposition on August 7th did you have an occasion to speak with any representative a professional attorney professional slash attorney for the U.S Attorneys Office MR SCAROLA Same objection and instruction Page BY MR CRITTON Mr Edwards are you familiar with the the c1iminal complaint that was filed relating to Alfredo Rodriguez MR CRITTON Let me show you what I will mark as Exhibit to the deposition Plaintiffs Exhibit No was marked for identification MR SCAROLA By that question does that mean has he seen it before MR CRITTON First let me show you Exhibit Do you its a criminal complaint the United States of America versus Alfredo Rodriguez MR SCAROLA Is your question has he seen it before MR CRITION Yes MR SCAROLA Im not sure what are you familiar with it means BY MR CRITTON Have you seen this criminal complaint before today A Yes When did you first see this document A I I dont know Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopklns Electronically signed by cynthla hopkins Electronically signed by eynthia hopldns Page Did you did you see Exhibit the criminal complaint prior to the time that it was filed in the United States District Court A Did I see it prior to it being filed Yes sir A No,no Okay Did you provide an affidavit to any individual at the FBl or the U.S Attorneys Office in support of although not attached to this to Exhibit the criminal complaint A Repeat Did you sign any affidavit or give give any sworn testimony associated with the criminal complaint that was filed by the United States of America versus Mr Rodriguez A Its obvious to me that youre trying to circumvent the privileges that have been placed on the record I will answer that question that no I did not but I am not here to divulge anything that may waive my attorney-client or work-product privilege or otherwise jeopardize the claims that my three clients are pursuing against Jeffrey Epstein for their being sexually molested by him when they were underage minor females Mr Edwards are you the cooperating Page witness who was referenced in the criminal complaint Exhibit MR SCAROLA Could you explain to us for the record please how that line of inquiry is reasonably calculated to lead to admissible evidence in this case MR CRITTON I am not prepared to do that right now MR SCAROLA Then I am not prepared to allow Mr Edwards to answer that question outside the presence of an Assistant United States Attorney who can make a judgment as to whether that is information that ought to be disclosed BY MR CRITTON Mr Edwards you knew or you first Marie Villafana through the complaint you filed on behalf of Jane Doe and Jane Doe in July of a correct A No Had you spoken with her before that period of time that is before the complaint was ever filed A Yes And I am now did you know lvfs Villafana Page during your years that you had worked as a State Attorney A No Okay Did you meet her only as a result of Epstein related matters A Yes in its broadest sense I suppose Did you did you have before you began representing E.W did you know who Marie Villafana was A I dont know What what was your first association or what contact was what was your first contact with Marie Villafana ever A I dont remember But ifI understand correctly you only know her through the context of the Jeffrey Epstein matter is that correct A Her involvement with yes And that you only knew of her involvement in the Jeffrey Epstein matter after you began representing E.W A I dont believe that to be accurate What involvement could you possibly what involvement would you have had Nith Mrs Villafana before you became involved in representing someone Page associated with the Epstein matter A I believe that I had read her name in the newspaper related to some involvement with Jeffrey Epsteins criminal investigation and/or case I think thats the first time I saw her name I believe Before before you filed a lawsuit against the United States of America and I may have asked you this earlier so I apologize did you ever speak with Mrs Villafana A I believe that any communications that I would have had with respect to Mrs Villafana would have only been in the interest of pursuing claims on behalf of the clients that I represented And therefore I am going to claim a work-product privilege as to those communications Okay My my question was is only did you speak with her prior to filing that complaint Just a yes or a no and I am looking that question is not asking for the substance I am just asking for a yes orno MR SCAROLA Same objection same instruction BY MR CRITTON During the course of the litigation with the United States Attorneys Office I assume you Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopklns Page had conversations with Mrs Villafana from time to time A Okay Is that true A Is your asswnption true Correct A I have spoken with Ms ViJlafana And when you spoke with Ms Villafana let me strike that Have the only conversations that you have had with Mr Marie Villafana or Villafana have they only been in the context of Jane Doe and versus United States of America only in the context of that case MR SCAROLA Same objection MR CRITTON And I will separate out to the extent that you were at the June 12th hearing in front of Judge Marra where she was present MR SCAROLA Same objection same instruction BY lv1R CRITTON Has Ms have you spoken have you had an occasion to speak with Ms Villafana with regard to the criminal complaint Exhibit No I involving Alfredo Rodriguez Mr Rodriguez 2s Page MR SCAROLA Same objection same instruction BY MR CRITTON Mr Edwards have you ever been interviewed by the FBI or the U.S Attorneys office with regard to any of your clients MR SCAROLA Any of the three clients who have claims against Mr Epstein a MR CRITTON Correct MR SCAROLA Same objection same instruction BY MR CR1TION Do you know Agent Nesbitt sir A Yes And how do you know Agent Nesbitt from the FBI A I can answer if you want MR SCAROLA Okay Thats fine MR CRITTON Nesbitt Kirkendahl THE WI1NESS I dont know her last name but I do lmow the first name is the first name is obviously an unusual name so I do know who that is I met her outside of the courtroom related to the Jane Doe and versus United States of America case Page BY MR CRITTON Did you speak with Agent Nesbitt at that time A Yes Okay And what did what did did she initiate the conversation or did you A The court initiated the conversation Did the court say go outside and talk A Right The court being Judge Marra A Correct And who else was present for that conversation A I dont remember Marie Villafana Okay Vvbat was the discussion about that the court ordered A The failure of the U.S Attorneys Office to meaningfully confer with the numerous victims of Jeffrey Epsteins sexual abuse prior to negotiating a plea in his criminal matter How long did the conversation last A Less than ten minutes Was Agent Jason Richards there as well A There was a male agent there I dont know his name but there was another FBI agent Page Did Agent Nesbitt Kirkendahl did she say anything Did she participate in the conversation A No Okay Was it just Mrs Villafana A There was another U.S Attorney there A U.S.AO there A Yes Do you remember a he or a she A He Do you remember his name A Lee Lee A I think thats his last name Dexter Lee Did Mr did Dexter Lee is he the one who conducted the conversation with you A Yes What was his response to your statement A That this conversation is more complicated than the time constraints that we have right now will allow We are not going to come to a resolution at this point on any issues that you or your clients believe are pertinent to the case you filed That was the end of the conversation A I mean I am not quoting verbatim but yes that was the summary Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopklns Electronically signed by eynthla hopk.ins Electronlcally signed by cynthla hopklns ff76c2ea Page And did you go back in front of Judge Marra that same day A I cant remember Did he issue an order based upon that hearing A The the record in the case will speak for itself I really I dont remember right now Have you had any other conversations with Nesbitt K.irkendahl other that Well I mean any other face-to-face conversations with her other than that one day back in July of July or August of A No Have you seen Nesbitt Agent Nesbitt Kirkendahl since July July or August during that short conference as physicaJly seen her someplace A Unless she was at the hearing we all attended on your motion to stay that day when there were a lot of people in the courtroom the answer is no Okay Have you seen Agent Jason assuming the male agents name was Jason Richards or Richard have you seen him since that day in July or August A I do not believe I have Page Have you spoken with either Nesbitt Kirkendahl or Jason Richard relating to any Epstein related matter since July or August of MR SCAROLA I am going to instruct you not to answer on the basis of the privilege as previously described BY MR CRITTON Mr Edwards have you spoken with any rep has any representative of the FBI attempted to speak with you regarding your association with the RRA firm A No Has any member of the U.S Attorneys Office discussed with you any aspect of your tenure or employment at the RRA firm A No In any conversations that you that you had that youve had with the United States Attorneys Office at any time has anyone ever asked you any questions about Scott Rothstein A Youre presupposing that I had conversations but I will answer the question whether I have or have not had conversations Nobody has asked me any questions from the State Attorneys Office U.S Attomev Office FBI or other airencv related to Scott Page Rothstein So it would be a correct and I am going to expand it would it be a correct statement that no representative of the federal government and by that I mean the Department of Justice FBI any other law enforcement agency nor any state governmental agency has ever asked you or quizzed you or questioned you about your association with Rothstein Rosenfeldt and Adler during the seven approximately seven months you were there is that correct A Thats correct Mr Edwards has has anyone from the United States Attorneys Office discussed the topic well let me strike that Have you been granted immunity with regard to any aspect of your work associated with either the Epstein files or the Rothstein prosecution A I dont understand your question Okay Youre aware that Mr A I can answer no I havent been granted immunity to anything so it doesn matter what your question is Okay Have you ever had any conversations with any of the probation officers in Palm Beach Page County regarding Mr Epstein A No Have you directed that anyone have any discussions with the probation officers in Palm Beach County regarding Mr Epstein A That is clearly calling for work-product privilege information Im not going to answer the question Have you had any discussion with any of the other lawyers who represent clients in the Epstein in Epstein related matters regarding Mr Epsteins probation MR SCAROLA Same objection same instructions and I would add to those objections the objection based upon a joint prosecution interest BY MR CRITTON Mr Edwards among the Plaintiffs lawyers is there any type of joint prosecution agreement related to Mr Epsteit1 MR SCAROLA Same objection same instruction BY MR CRITION Did you have did you engage in weekly or monthly meetirnzs among the Plaintiffs Jawver to Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopk.lns Electrooically signed by cynthla hopklns Electronically signed by cynthla hopkins ff76c2ea lSl Page share investigative material regarding that you had obtained regarding Mr Epstein MR SCAROLA Same objections and instructions BY MR CRITTON Did you provide any of the investigative materials that had been acquired by you to any other person outside of the RRA firm and the Fanner Jaffe firm up through the current date MR SCAROLA Would you read that question back BY MR CRITTON let me ask it During the time that you were with RRA excuse me and had investigation done on Mr Epstein was any of your investigation that you had perfonned turned over to any person outside of RRA or your clients MR SCAROLA Same objection same instruction to the extent that that would encompass other attorneys with a shared interest in the prosecution of Mr Epstein If any of those materials were turned over to persons who did not have a direct interest to lawyers who did not have a direct interest in the prosecution of the claims against Page Mr Epstein or to clients who did not have to persons who did not have a direct interest in the pursuit of their claims against Mr Epstein then you can aMwer to that extent THE WllNESS Privileged BYMR.CRITfON And I just want to be clear is is there any written agreement and I know you I want to make certain that the objection is there is as we both know there are a number of claims lbere are a number of claims that are outstanding against Mr Epstein brought by a number of different laVv ers MR SCAROLA The objection extends to both written agreements and oral agreements THE WITNESS Yes We both know that there are a lot of claili against Mr Epstein for basically the same conduct BY MR CRITTON And my question to you is is is there any written agreement between the Plaintiff lawyers who have filed claims against Mr Epstein regarding the sharing ofinfonnation MR SCAROLA Same obiection same Page instruction BY MR CRITTON Mr Edwards do any of the investigators let me strike that Did any of the investigators who worked for RRA refer any Epstein client to you A What is an Epstein client I am sorry Did any of the investigators who worked for RRA refer a perspective claimant against Mr Epstein to you A No Did any of your did any of the RRA investigators ever meet with your three clients MR SCAROLA Same objection Same instruction MR CR11TON Okay And rm looking for is ayes/no MR SCAROLA Correct Same objection same instruction BY MR CRITTON Mr Edwards during the time that you were with RRA did you yom e-mail was your only e-mail address bedwards rra-law.com A I only had one mail address All right Did you ever receive any Page inf onnation regarding your cases at your home e-mail A I dont remember Okay What is your home e-mail address please THE WITNESS Do I give this MR SCAROLA Mr Scarola nods his head THE WITNESS hotrnaH.com BY MR CRITTON Did you have a separate fax number at RRA when you were there that is,just so a fax would come directly to either yours or an area where you were located A No In any of the directions that you ever gave to the investigators did you ever put that in the form of a memo that is would you give them written directions MR SCAROLA Same objection same instruction BY MR CRITTON To your knowledge did any of the investigations that were done regarding Mr Epstein were they provided to any other person at RRA A Excuse me Pages to PROSE COURT REPORTING AGENCY INC Electronlcally signed by cynthla hopkins Electronically signed by eynthia hopklrn Electronlcally signed by cynthla hopklns Page You have testified that investigations were done during the time on Mr relating to Mr Epstein during the time that you were at RRA A Right My question to you is did you first of all did you receive written reports in addition to oral reports A From the investigators Yes sir THE WITNESS Answer MR SCAROLA Yeah THE WITNESS The reports were yes I did BY MR CRITfON And were the reports provided by e-mail or were they provided by in the form of a memo that would be sent from the investigator to you or both A I I do not remember there being any in the form of an e-mai I Does not mean that there was not I did communicate by e-mail with other members of the firm and other members of the investigative team on all cases as has been my practice along practicing law There were memos though that were given to me that were not e-mail form that were the standard memos that I would incorporate into a witness memo file Page And again that would just be in your would that be in your electronic storage as well as in the hard copies A The version I saw was the electronic So that would be stored in the Fortis program A Thats correct All right And again other individuals in the firm other lawyers in the finn might be able to access that program you just dont know A Right Well the program obviously thats the program that the firm used Now whether they could access if you could go across cases that werent cases you worked on I really just dont know As an example could Mr Fisten on the on the Fortis could he access your your file on an Epstein case A I dont know If someone accessed your file accessed your electronic file would you necessarily know that A No All right So A I dont believe so It wouldnt show up that Michael Fisten Page and Im using just as an example is that he came in or Scott Rothstein came in and looked at a particular file of yours whether it related to Mr Epstein or not you dont know A I cant answer that question accurately Okay Did you ever send investigative reports to other lawyers regarding Mr Epstein that is if you got an investigative report from Mr Fisten or Mr Jenne or whomever would you send those on to certain lawyers on a regular basis MR SCAROLA You can answer that question THE WllNESS No BYMR CRITION What lawyers other than yourself were involved in the Epstein cases during the time you were associated with RRA A What do you mean by were involved I guess all What what lawyers actually worked on the file I know Mr Berger worked on the F.pstein cases correct A In some limited capacity correct Okay Mr Adler I know attended Mr Epsteins deposition correct Page A Correct Did did any other lawyers other than Mr Adler or Mr Berger attend any depositions A Your memory is going to be as good as mine there ltn thinking Mark Epsteins deposition was attend by Russell Adler He went with you to New York A No He didnt go with me to New York He attended the deposition and I also attended the deposition Both in person A Right Was he there for another file or did he meet you there to specifically attend Mark Epsteins deposition A Coincidence that he was in New York during the time when his deposition was being taken Any other lawyer that you can recall being at a deposition other than Adler Berger and yourself A Not right now If you remind me I may remember I dont remember right now Did other lawyers in the finn at RRA perfonn services on the files that is and by that I mean did they were they involved in drafting Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthia hopkins Electronk:ally signed by cynthia hopkins l:lectronlcally signed by cynthla hopkins Page motions research appeals pleadings papers that were filed MR SCAROLA You can you can answer whether they were there were other lawyers involved in drafting tasks without identifying what those may have been TIIE WI1NESS Other lawyers contributed to some extent to the prosecution of those cases BY MR CRITTON Who Names rm not asking for tasks MR SCAROLA You can answer MR CRITTON I am asking for names THE WITNESS Bill Berger Judge Stone Russell Adler Rob BuscheL BY MR CRITTON A I dont know how to spell it B-u I dont mow how believe All right Is he currently with you now A No Any other lawyers A And youre asking for no matter how minimal just anything done by any lawyers Correct A Michael I think his name is Michael It was Page another lawyer Thats thats those are the ones that I can remember right now Were there ever meetings that occurred well not were there ever specific meetings that were attended by various lawyers to discuss Epsteins cases MR SCAROLA You can answer whether there were meetings THE WITNESS There were meetings to discuss every case including Jeffrey Epsteins cases BY MR CRITTON And when you say there were meetings to discuss every case were there routine meetings that were held to discuss your cases or cases in general A Its how the finn worked If you wanted to discuss cases or the case was a case that was thought to need more than one or more than two attorneys then a meeting could easily be assembled within RRA to sit around the table and discuss issues related to any case And yes that happened with respect to cases filed against Jeffrey Epstein And so there could have been additional lawyers in addition to Adler Stone Berger and Rob Busche and yourself that would have conented on an Page Epstein case A When I was giving you that list of names I was picturing one of the couple meetings related to Jeffrey Epsteins case Could there have been other lav,ryers in the room yes but I think that is the exclusive list Did Mr did anyone ever attend by phone meetings associated A I understand that involved Mr Epstein A I understand No Did Scott Rothstein ever attend any meetings wherein strategy was discussed regarding the Epstein cases A No The one meeting that you had in Mr Mr Rothsteins office with Russell Adler and some unknown person on the phone were you given any direction at that time that certain discovery should be done or certain tactics should be used with regard to prosecuting the Epstein cases MR SCAROLA Same objection same instructions BY MR CRITTON Did you ever receive any e-mail Page correspondence from Scott Rothstein that detailed or that set forth discovery that would be that should be undertaken with regard to the Epstein cases MR SCAROLA You can answer that with a yes orno THE WITNESS No BY MR CRITTON Did you ever have did you ever receive any correspondence directly Mr Mr Rothstein to you during the time that you were at RRA A Yes Did any of the correspondence ever involve Epstein or communication ever involve Epstein MR SCAROLA You can answer that THE WITNESS To some extent yes BY MR CRITION Okay And what did what did what infonnation did Mr Rothstein send you that involved Mr Epstein MR SCAROLA Same objection same instruction BY MR CRTITON Is the infonnation that you received or the communication you received from Mr Rothstein re2ardiM that involved Mr Epstein was that by Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopkins Electronically signed by cynthla hopklns Electronically signed by eynthla hopkins ff76e2ea AN K?Ár?-ݦ?ND?h?m?0?p VL Bz bx Zb dл C??i Gq xu ڇ?S0 ZDؤ gW M?.V A eL EO??Q?Aɳ LЇ Xcim_I9?K?m?Տ 9m?猃?p?ԲM me GVN;P bƳ D?u Z?z k?w D?t 4pHz SAJ C?W 7vU1Sml?c k?N WX o?F??k0م CT RGl Q8 v?Q hhR zX A JŪ?k?f??hN?ו?H?vT m?l h?w Fm?s xC r?P HGf D??Z 1US?R tZvl 4ڵm tx m?DbKjUR?xlu ASї M?Ի j?g?,Z d.Ȋ P?zU N?B?э?Sk?P Ȯ?r kp?S D6 i y?d U?L fy AF 4_ c5 A ty LD?GݴuN FX k??t??aN dA i i H?L9 VƜX L?y LP B_İ T?r w?ǯ??yX Ehג L?Rk ۈ?q 4h?i a?k r?X 9Q nW cl??G w?W?B?G?i ii MxS?d?P ѷg m?l w?6ѫ?z?G?8Re RT Uf n??r?C 4W5W?i l??H jPcM Jq?k?_ EG yR??Һ G?C x??kʳ O?Q t8?mY 4;XF N?ܛ mɳ NN X?O?M?b?v Y??sX GC b??q gu??k vJ w?;?C?WKl 5M Z1 kZ l?c?Ww ڀ6xj!qj:?V1??i BB e?N h?2U J?Ag?bX9r?u6Z HL BC P?x?ȉ KOIJi?x?Oӄ?A IՖc Vx??TD u??C FF j?k VO열 dw/jR Vv j3 N?L A w4?Tz SQ5??p Sl ǃGư gt4?ڌ vY mr?0I L_7v n?k hqr??c dO RW ƁB 5g Y?FE?fL?F pP aE w?kaa ɤW ZI?2 kg Nm mo ΰ?Dp.F?s iqP R7n B6o?L??H?džL bH?1 q?H ڣb m?ý U?g n?dzB Z?wX?u?u1??ʀ Hl Te oq i pLP?/?Gr e??w?iG fu 0?GCG?jQ U?J K??K??inrAm p?X W?ApRj a"E?O x?hŀ??P w8 N??Z?d D??J?Yp ko?3 Xf Ҵ?sM?LC v??_yK?l?o Q?U?n Asر D1 kΪ?-Loy hŪ jj xBV 6W k??f rt U!s?uk s?Q4 k??H KiՁ??Y?5?oݸ?qϻ?5 F7 D?Z??a 2e jJx??P h2 z_ i??j mU G5gh?A ZXa8?0 HE??"F d2 bf?S?ސ 9f e?dM5JS ˤz yr?O4 ad qR?v e?y 权??_kc?ӬP B?FV uYĿoQ?ie7 N?O uNTWG yG tL?vU/?;a?c L:sTZ ηT??o??n?TW t9 kOb ca d?ԓ YLα N?P ɤ;?Ib K?i?m 4FkDB z?n _M kp A p?X??ߍP ܧ??xw5mg i?DX 2H?i?gɯ4n-?1dJ W?H?n?a _ZrY?Y g1 RsIF lj_ M?N!ؽ?ҍ mC?CH B??C N2j 1Ĵ K?b?/Y7ш A A ۇ?K dG L??i e?a LPY3H I?;M y?c wM4?ۊ nD tf??kw??A??p ogNK nr 4ߕ a?P?UpLf EA p??J ɢ2 lа?Q d߈?clW n壼 jyz?A A Gh j?O.C?GD l?r M?ԝ BX?2?h A I?PN!?g i츯W?/L?p GU a:h tF M?N??nF V侘n 䓏1 RL s??W E??I E??V uu yV8 MUu P;c?C v??c Asa?rC?e a ӧf m?b xpC L?U RweHh i,?YXD?䴭H fk BX?G?w?h Rj k??iU OΡ A N?â f3J?W mg dw FG8 RSz r??C?rIu 4豱 ԣ??Kl h"ϗ?u U2A t??x!S H1?k ѩp U?x?U oG A v?E X??Ө iX Q.a?V q??ٺ bg di8o?A Iψ?W??K늅?8o 4??i?dТĩP?QC?RmS?K?qk7?9l i t?й wU?1?K?T?o jo e?6e VZD q?t F?xl X?O2 u??d u?qq r??o?xt?i yjgY?x 77iԭ?K Sq?p q?h.2A d6 1?𗻫V E?xC?f l?J E?pc w?r1r I6?V?j ʺR x_?tzԎR H??o?j Pz g?1gEI Ȫ9 o?g"?G?G wx _Ғ Р?E rD lAmPԪ Al I Sx?B BH bHFh?9 V?T?g S?Ӄ iFn W?S Xqz Gf V?8J wa?e Hb?쎻 1MI??w Hwj a?h u"?b S?Wgt LO?U?wC?S Q??e hF c?t?c,ĸK?sR03Ȝ WLO??-?h h?O 3s?i H?y PA 4kr?y_ l?zB t?L Iϻa?X ހ?p?D4 gX d?fs 1je mL 1d?v?xf6u h?ېXݑ??X.?pzQz1H Gu2 v?T_ Y??wXU w?c?6b БO ykގm k??E k?Wi Bu Q?t zO?KIl?aFt?l Q?ś 5ח/e dzN P??Z?h P?x gL,sB?yc vS?1We trU?w Fπ I J,?g??mm HY2 I i?n 6P?kR7??qfiUf Ja!D??k0 a H?ĭ Ya?ƚ H?C?Lz6 si Kț bhņR I??o r?Q f?J1 늴?A Zp hH?yM չr I1 EqW sN TA?Q?Ҵ y?K nU??fAC bna aJhH px;L M?a?9ZH?zE?1p ҟXO a x0T"w?ڸ ԯ?9t?j 湶Y C?tn0?xǒ-Q rݒ ¼H ࢭ?t ǭy?3ylP 5U?Wm π"E ny t?7j q3 Page way of mail A Did you ever receive any memorandum from him that is a typewritten memo that was then sent to you through office mail that was not electronic involving Mr Epstein A No At the meetings that you at the meetings a that occurred where these various lawyers Berger Adler Stone Rob Buschel were present and Epstein was discussed was the discovery that discovery and/or investigation regarding Mr Epstein was that ever discus.sed MR SCAROLA Same objection same instruction BY MR CRITTON Mr Edwards are you aware as a fonner state prosecutor that there are laws against a conducting certain financial transactions in money thats derived from a crime A I dont 1.mderstand your question Okay Well you were a former state prosecutor is that correct A Right Yes Right Are you aware that there are Page certain Jaws both state and federal that that are that preclude conducting certain financial transaction transactions in money that is derived from a crime A Still dont understand your question But first before I try to answer your question are you taking me back to a time when I was a State Attorney and asking back then did I know and then your question Yes A Back when I was a State Attorney did I know that there are crimes related to money transactions No MR SCAROLA Could help you Do you want to ask him whether he was aware of the existence of a state RICO statute MR CRITTON No MR SCAROLA Okay MR CRlTION I am okay with that first but I am still going to ask my question BY MR CRITTON I assume youre aware of the existence of a state RICO statute correct A I dont know that I was aware of that back then I just cant remember whether I knew about RICO back at the State Attorneys Office I never prosecuted Page RICO claims But you certain have brought RICO claims against Mr Epstein A I know about one now Okay At the time that you were at the State Attorneys Office what kind of how long were you there A Three years And what kind of crimes did you prosecute A Beginning with DUrs through attempted murders and everything in between No well not no very few economic crimes some insurance fraud cases but very few otherwise drugs guns robberies burglaries attempted murder aggravated batteries those types of crimes false imprisonment Well were you ever do you know what money laundering means in a criminal context A In some basic sense I do know what money laundering means Wbat do you understand that to be A That you that the criminal takes money and through some illegal means attempts to make bad money legitimate MR CRITTON Let me show you wbat I will mark as Exhibit which is the complaint that Page was filed against Mr Rothstein yourself and L.M Plaintiffs Exhibit No was marked for identification BY MR CRITTON Youre familiar with this complaint sir A Unfortunately I have read this frivolous complaint MR CRITION Move to strike as nonresponsive Youve seen all I want is a yes orno Are you familiar with this document MR SCAROLA I am going to object to the fonn of the question It is vague and ambiguous I dont know what familiarity means He has seen it before BY MR CRITTON Mr Edwards you have seen and read the entire complaint along with the attachments Exhibit A Ive read the complaint I have never read in the entirety Exhibit Are you familiar do you know what an information is A Yes Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopklns Electronically signed by eynthla hopklns Electronlcally signed by cynthla hopklns Page And thats Exhibit attached to the complaint correct A Correct And youre aware that and this is the information that was brought by the United States of America U.S.A versus Scott Rothstein coITeCt A Yes And youre aware that within the well let me strike that Are you aware that Mr Rothstein has pied guilty to excuse me the infonnation that was brought against him by the U.S.A A I am aware that he pled guilty to something With regard to the complaint brought by the U.S.A I am sorry the information brought by 1s U.S.A against Mr Rothstein I assume you have read the allegations associated with the racketeering conspiracy the pattern ofrack.eteering activity correct A I havent Okay If you tum to Page Paragraph were you aware were you aware prior to coming in here today that Mr Rothstein was that the charges that were brought against him were for under under RICO but with regard to mail fraud wire fraud Page laundering of monetary instruments engaging in monetary transactions and conspiracy to launder monetary instrwnents and engage in monetary transactions A I I have read that in the newspapers I have been told that by numerous people So yes I was aware of that And within the complaint at Paragraph it says the Defendant A The information or the complaint Im sorry Within the infotmation Exhibit to the complaint in Paragraph where it speaks in terms of the Defendant and his co-consp1rators conspirators agreed agreed to engage in a pattern of racketeering activity through its base of operation at the offices of RRA Do you see that A Yes Okay Do you know who the do you know any of the co--conspirators in addition who are associated with Mr Rothstein A Assuming that they are fonner employees of RRA which I would presume several of them are I am sure that I probably know them And youre aware that the government has Page asserted that the firm was a racketeering enterprise correct A Not necessarily no Well if you look in Paragraph see where the firm is identified as the enterprise of the racketeering conspiracy A Law firm Paragraph of the inf onnation says Rothstein Rosenfeldt Adler P.A was a law finn with offices located at I East Las Olas Boulevard Fort Lauderdale Florida and elsewhere The law finn employed approx.imately attorneys and engaged in the practice of law involving a wide range of specialties including labor and employment law Are you in Paragraph A Of the information yes Im sorry I am looking at my apologies On Paragraph under Count I my error A Okay See where the law finn is identified as the racketeering enterprise A Im sorry Your question is am do I recognize that the law firm is categorized as an enterprise Yes in that paragraph I see that Have you had an occasion to discuss with any with either Mr Adler or Mr Rosenfeldt any of Page the allegations directed to Mr Rothstein A No in the criminal complaint A No Since the implosion at the finn have you had an occasion to talk about or speak or discuss any firm business regarding Mr Rothstein and the ponzi scheme that he was running at RRA A Have I had an occasion where I could have talked No rm sorry Have you had an occasion to discuss with fr Adler since you left the finn or since the implosion any aspects of the of the ponzi scheme that Mr Rothstein and his co-conspirators were running through the firm MR SCAROLA Are you asking whether he did have such a discussion or whether he had an occasion to have such a discussion BY MR CRITTON Did you have such a discussion A No Okay Have you discussed that or have you seen Mr Adler at all other than hi hello since A Yes So the occasion existed We just didnt have that discussion Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthia hopkln1 Electronicatly signed by cynthla hopkins Electronically signed by cynthla hopkins ll Page Have you and if I understand correctly you havent discussed any finn business with Mr Adler since the implosion is that correct A Firm business Any firm RRA business A Right no How about with Mr Rosenfeldt have you had any discussions with him A None since the implosion of the firm in late October of A No If you wanted if you had any other than your existing partners have you had an occasion to speak with any other partners or former partners of the firm regarding the implosion well let me strike that regarding the ponzi scheme that was being nm by Mr Rothstein through the finn A I have spoken to my current partners about it Are your current partners are you aware of any of your current partners being a target of an investigation as a potential co-conspirator with Mr Rothstein A No,way Youre not aware of or no one has told you Page that correct A I am not aware of that and nobody has told me that Mr Rothstein founded what was what ultimately became RRA in approximately Were you aware of that fact A No How long did you think Mr Roth.stein had been well let me strike that How long did you think RRA had been in existence prior to your joining the firm What were you told A I dont know what I was ever told I think that I learned that inf onnation when the implosion as you call it occurred And were you in temlS of what the revenues of the firm were were you ever advised what the revenues of the firm were A No Okay Wereyou,wereyoufamiliarwith what the expenses were associated with operating the RRAfinn A No Were you in anyway--well let me strike that With regard to let me take a five minute break and Jet me collect mv thousmts Page THE VIDEOGRAPHER We are now off video record MR SCAROLA That will be a refreshing change TIIE VIDEOGRAPHER We are now off video record at p.rn A brief recess was held MR CRITION Mr Edwards THE VIDEOGRAPHER Were back on video record It is p.m BY MR CRJTION Mr Edwards when you joined RRA ifl understood your earlier testimony with regard to the Epstein cases and your other cases when you came there as far as you were concerned is you had the ability to spend whatever money was necessary to prosecute the Epstein cases fair statement A I dont know that thats true or its not true I mean Well A My judgment was never questioned Correct And therefore whatever monies you spent either in investigation in doing discovery that was your decision and your decision alone true Page A Whatever money that I spent was my decision No Whatever money you spent on investigators on doing depositions on requesting transcripts on doing what was necessary to prosecute the Epstein cases that was your decision A No The actions were my decisions in tenns of how to prosecute the case TI1e amount of money to spend per exercise was not my decision nor was I privy to that information Well but you were the one who directed that the particular task be taken correct MR SCAROLA This is this is repetitious MR CRITTON I am setting a stage MR SCAROLA This is repetitious of areas of examination that were covered thoroughly in the earlier portions of this deposition THE WITNESS If I wanted a witness interviewed I could ask an investigator to interview The investigator how they were paid how much they were paid whether they were paid is not something that I had any knowledge of at all BY MR CRITTON Okay When you ran your own finn you Pages to PROSE COURT REPORTING AGENCY INC Electronically slgried by cynthia hopldns Electronically signed by cynthia hopkfns Eleetronlcally signed by Cynthia hopklns Page obviously knew what whether hiring an investigator or what a particular cost was because you had to pay it correct A Ya Okay And I think as you described earlier is that there had been very little discovery up until the time you started working for RRA in your three cases true A Not very little discovery Obviously we had gone through interrogatories responses request for production responses or lack of responses however the majority of the depositions that were taken the cases just happened to be right last summer for most of those depositions to take place and thats what happened Not only depositions but as wel1 the investigation as you have descnbed your investigator that you hired as an outside person didnt really start until late March or early April in cortjunction with the other investigation that you did during the time you were with RRA correct A Fair statement All right And when you were at RRA you described earlier and I wont belabor it but you described the compound I think is the word that you used that Mr Rothstein kept himself in when he was Page at the finn correct A Correct Right And he was not accessible to everyone else true A Right And was he on your floor or was he on a completely separate floor MR SCAROLA As opposed to a partly separate floor THE WITNESS For the most part he was on a separate floor BY MR CRITTON Okay And were there guards during the time that you were at at the RRA firm RRA were there ever guards that patrolled the hallways A Yes And was that from the day you started A I believe so And had you ever been in a fum where bless you Had you ever been in a furn where there well let me strike that The guards were what Broward County Sheriffs Officers A I dont remember the agency but they were annoo unifonned police officers I believe Fort Lauderdale Page Okay Were they all on the were they were they A Some were B.S.O as well Some were Broward Sheriffs Office Some were from Fort Lauderdale It was both With with regard to the police officers and the Sheriffs Deputys that were present where they on every floor of RRA A It seemed that way And had you ever been in a in a law firm either as a visitor or as an employee or partner where you had seen armed guards from either a Sheriffs Office or a police department roaming the halls A No Had you ever been to the RRA offices before you accepted the job A No When you got there and you saw the armed guards patrolling the floors did you ever have a conversation with Russell Adler or anyone else as like what in heavens name is going on here A I didnt see them when I first got there How much time passed before you saw the guards Page A When I first started I believe that the people patrolling Im not sure that they initially were Broward Sheriffs or Fort Lauderdale police I think that may have been a month after I began From what I remember seeing and I can envision the people in my head they were private security people At least that was the appearance or the interpretation that I had And I didnt question it at the time who they were Within A I dont think Within a short period of time though you recognized that they were either Sheriffs Deputies or police officers A At the point in time where I recognized that they were armed unifomied police officers in the firm yes I questioned it not only to Russell Adler but to anybody else anybody else because all of the lawyers in the finn thought it was strange Okay And what did Adler tell you A That Scott Rothstein has a lot of money prior to you being here a female attorney was murdered and he wants to make sure that his friends and family are as secured as possible that while he has this extra money to spend on security he is going to do that for all of our safety Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by Cynthia hopklns Electronically signed by cynthia hopklns Electronically signed by cynthla hopkins Page Did you understand as well that he bad that the finn was paying for anned guards to guard hfa house hours a day A No When did you learn that fact A After the disbandment of RRA Did Mr Adler tell you that Mr Rothstein had amazing or substantial wealth A I dont know in those words but I I definitely understood that Okay In meeting Mr Rothstein initially initially for the ten minutes as you were contemplating taking a job and on the two other occasions or the one other occasion when you saw him out in the restaurant I think you described him as flamboyant A Im not sure I used that word but probably one synonymous and yes I would describe him as such Was he someone that at least well let me strike that Were you aware that he had a a watch collection of hundreds of watches A No Did you see him wear expensive jewelry when you saw him that is the few occasions that you saw him Page A Never I didnt take notice of that Okay When you saw him was he dressed in a suit or was he dressed in business or in casual more casual clothes A Always a suit And looking like a million bucks A Looking ridiculous But something that looked very expense flashy showy A couldnt tell how expensive it was but flashy and showy yes It may be a pink shirt with a purple tie and a blue suit something that you would never expect a Jawyer to be wearing yes And in terms of the in temis of the of his personal wealth or his his personal assets were you aware of where he lived A Was I aware when During the time you worked for RRA A Yes Okay And were you aware that he was living in a multi-million dollar house A When when I went to the house I I recognized itas such You said you want to the house Did you go to Mr Rothsteins house Page A I went there one time For what occasion A I dont remember the occasion but it a gathering that he had at his house and he asked during the course of me working there were ten occasions where everybody was invited to go to his house for various events and on one occasion I went Oh all right And from being in his house did you recognize immediately that this was a multi-million dollar house A Yes Okay Was it on the water A Yes And could you tell from the interior design or the decorations that existed that this was at least a man a man that had significant wealth A Yes All right And could you did you have an opportunity to see his collection of automobiles A No During the time that you were in the house did you have an opportunity did did you walk around the house A No How many people were there best estimate Are we talking like ten or A No no no Did you talk to Mr Rothstein at all A Not even for a second Page Could you walk anyplace in the house that you wanted A The party at least to the extent that I participated in it was outside So I I dont know if I could have walked around the house but did not walk around the house nor did I really walk inside the house other than to go in the front door straight out back and then leave the exact same pathway that I entered What his property located on Castillo Island A I dont know Were you aware or did you become aware that Mr du1ing the time that you were there that Mr Rothstein had investments in multiple real properties A No Were you aware at the time that you met him first at the BOY A restaurant that he had an interest in BOY A restaurant A When I met him no Did he have an interest in BOVA restaurant Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopldns Electronically signed by eynthla hopldns Electronically signed by cynthla hopklns Page at that time A heard that sometime after I began working there He certainly acted like he did Did you learn that he had investments in other business entities whether they were other restaurants or other business entities A Through during the time that you worked at RRA A 1nrough rumors And rumor was he bad his fingers in many lo different businesses A It sounded like hundreds And did you understand that he had a substantial collection of automobiles A What do you mean by substantial selection or collection Well were you during the time that you were at RRA were you aware that he had Ferraris A No Multiple Ferraris A No Were you aware that he had a Bentley A Yes Were you aware that he had a Bugatti A heard that Page Were you aware that he had a Rolls Royce A No Were you aware that he had multiple Corvettes A No Either a Corvette or multiple Cotvettes A No Were you aware that he had multiple Mercedes Benz A No Were you aware that he owned a yacht A Yes Okay And was that parked behind his house A Yes Were you aware that he also and did it if was to say it was approximately an to 90-foot yacht or in fact an 87-foot yacht A I wouldnt qU3lTel with that Did it also appear that he had a substantial sport fishennan that was parked out there as well A I didnt see that Were you aware that he had 33-foot Aqua Aauaviva Page A No Were you aware that he had multiple jet skis A No Were you aware that he had a foot Sea Ray A No Were you aware that he owned a Lamborghini A No Again during the time that you were at RRA A I understand that The answer is no In addition to the to the business of owning BOVA what other business ventures did you understand he had I think you said you thought he was in hundreds of businesses A Through a rumor Right A I understood that he owned a Vodka I understood generically that he owned or pw-chased various patents m1derstood I didnt know what the patents were I understood that he owned other restaurants I understood that he owned or was partial o-.mer of Cafe Iguana Page At some point in time I learned that he was owner or partial owner of the Versace roam.ion And I think in general it was always explained to me or I overheard he had he has his hands in aU of these this assortment of businesses and those business ventures have done very well and that is the source of his apparent extreme amoW1t of wealth Who told you that A I dont I dont know More more than one person I mean that was just kind of the word around the campfire so to speak Did you inquire as to let me strike that Did you ever see any docwnents that reflected or documents or read any infonnation about Mr Rothstein that preexisted which was kind of the start of the RRA firm A I dont understand Okay Well I think we established earlier that your understanding was that RR.A kind of started as a fitm in the time frame A Well you told me that and I have been told that after the implosion that that was the time period that RRA started I didnt know anything about Scott Rothstein until the year at all Did you do any research with reizard to Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthia hopkins Electronically signed by Cynthia hopklns Electronlcalty signed by cynthia hopklns ff76c2ea Page Mr Rothstein prior to going to the finn and by research I mean people Google Did you Google him A No Did you did the finn have a brochure A I dont know Did you ever see brochures in the waiting room or the reception rooms that described the firm when it V8S fOlmded background of the finn et retera A No Was it on your web site A Was what on my web site The history or the background of the firm Let me strike that RRA had a website A RRA had a website Thats no longer in existence true A True And A To my knowledge Did you ever go on the website and checkout the web site for the history or the background of RRA and Mr Rothstein A I went on the website I dont know that the website even had a history If it did I dont remember ever looking at it Page Did it did at least from what you saw and observed of Mr Rothstein did it appear to you that the his wealth far exceeded the type of business that it appeared to you that the firm was doing A have no understanding whatsoever No thats not something that ever crossed my mind Well under throe circur.n,twlCCS is is when you went to the finn you had the ability to your discretion to spend whatever monies you wanted lo in prosecuting your personal iJ1iury and Epstein cases You no one ever turned down a request either for a reimbursement or told you not to expend any money true MR SCAROLA Objection compound and repetitious TIIE WITNESS I dont understand the question BY 1R CRITTON No one as to any expenditure that you ever made on an Epstein case MR SCAROLA Isnt this about the fourth time that youre eliciting exactly the same testimony Isnt it very clear the extent to which Mr Edwards had control over financial matters with regard MR CRITTON Form MR SCAROLA to cases MR CRITTON Fonn Page MR SCAROLA No no Ifs a its a speaking inquiry BY MR CRJTION Mr Edwards did you ever have any dealings with Deborah Villegas A No Am I saying it right A I dont know A Ive seen the name Did you know who she was A In what way As it related A I knew that she worked for the finn What did you understand her position was A Rothsteins Sarah Kellen Did you understand her to be the COO of the company of the fum A Right I dont know if COO or whatever but his right-hand man thats the person who gets him what he wants Thats at least in a broad tenn what Page understood her position to be Did you understand she was a financial person A No Or an administrative person A My understanding was administrative With regard to Mr Rothsteins that is his real property his vehicJes his boats hls business interests would it be a correct statement sir that you werent concerned about the source of his wealth A You went through a list of the things that I knew or did not lolow him to have in terms of assets And I told you for the most part I didnt even know that he had those things In fact while you were out of the room I just educated myself by reading the information on some of the things he had and I didnt know until right now that he had those tlrings But certainly while I was working at RRA I didnt know that he had those things Then let me be specific With regard to the with regard to the house that you knew be had with regard to the yacht that you knew he had with regard to the vehicles that you knew he had with reswd to the business interests at least BOY A and Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cyothla hopklns Electronlcally signed by Cynthia hopklns Eledronlcally signed by cynthla hopklns ll el Page at least what was rumored to be his business interest did you believe that the source of his of his apparent wealth was as a result of the law finn A be1ieve that the source of his wealth was the law firm as well as the what I have described as an assortment of businesses that he had bis hands in of which only a fraction I was aware Well what did you understand to be the source of the funding of the of the Epstein cases and the other lawsuits that you had A The checks I believe were written by the law finn Okay And what did you believe was the source of the monies that the law finn got to expend some.just on the three cases that you had with Mr Epstein some three to I mean separate and apart from all of the your other personal injury cases and separate and apart from all of the other lawyers who were in the law finn who also had cases A didnt have a belief at all as to the source of any of the monies that were used for any of the case Was it your position it really wasnt your concern that is wherever the money came from it didnt bother you all you knew is that the finn was Page funding your cases MR SCAROLA Objection argumentative THE WITNESS Yeah At the time I believe that I am working at a well recognized law finn with good people and that is a successful law firm and this is the way that law finns at that level operate and right I didnt BY MR CKIITON Didnt care A Right I didnt care I didnt question it With with regard to let me ask you some names and see if you recognize the names Do you know a person by the name of Barry Bekkadan B-e-k-k-a-d-a-n A Never heard the name Wltil right now AJ Discala A Again same answer Clockwork Capital Advisers A No never heard of them Razorback Funding A Nerve heard of it Michael Sufranski S-z-a-f-r-a-n-s-k-i A Heard that name And A only after inmlosion and throillZh papers and Page things of that nature And thats my question to you Did you hear these names before or during the time that you were at RRA as distinct from now A Of that list you just read until right this second Michael Szafranski is the only one that I have ever heard of and that was after implosion of RRA And again this question is specific to the time frame A Sure that you were there Dominic Ponatchio P-o-n-a-t-c-h-i-o A No Moto M-o-t-o Ban B-a-n Adon A-d-o-n A No Ever heard ofBen07,0n phonetic Varon V-a-r-o-n A No Onyx Capital A No Onyx Options Consultants A No BWS Investments A No Pirulin Group Page A No Shimone phonetic Levy L-e-v-y A No Obidia Levy O-b-i-d-e Im sorry d-i-a A No Daniel Minkowitz M-i-n-k-o-w-i-t-z A No Fortress an entity know as Fortress Investments or Fortress Capital A No Drawbridge A No Capital or funding A No Do you know an individual by the name of have you ever heard of heard during that time period did you hear of or know a person named George Levin L-e-v-i-n A No Banyan Investment Fund A No Did you know or hear of the name Frank Preve A No Okav Mr Preve is numortedlv was Pages to PROSE COURT REPORTING AGENCY INC Electronicalty signed by cynthla hopkins Electronieafty signed by cynthia hopklns Electronkally signed by cynthia hopklns ff76C2ea a Page purported to have an office within RRAs offices Have you seen that A Have I seen what Have you seen that in any of the news media that Mr Preve had an office within RRA A That name doesnt sound familiar at all So no the answer to your question is no I havent seen that Bill Brock A Yes Okay Who is Mr Brock A In the law firm he went by the name Uncle Bill Okay All right Who is Uncle Bill A Who do I understand him to be dont know who he really was At this point in time looking back there is no telling what anyone what anyone or anything was But at the time I believe that he was a relative of Scott Rothsteins What did he do What did what did Uncle Bill do A Some at the finn A Something with money Did he have an office at the firm Page A think the trustees are still trying to figure out what he exact did do Did you have any dealings with him A Dealings no I didnt have dealings Dealings of any kind A I talked to him Did you ever discuss any of your cases Was he he wasnt a lawyer A Far from it All right Did you ever discuss any of your cases with him A No Just a hi hello A Hi hello and I was one of the lawyers who would come in often and work on weekends and he would be there Thats when I would see him and he would kind of hey how are you doing on a weekend And do you know a Dean Kretchmar A No Same question again do these names during the time period Doug Van Allman A No Ted Morse Page A No EdMorse A No Richard Pearson P-e-a-r-s--o-n A No Steven Levin L-e-v-i-n A No Ira Sochet S-h or Sachet A No Mark Melvin A No Jack Samoney phonetic A No LawrenceKing A No Steve Jackel A No Have you ever heard an attorney name Michael Legamaro A No Kevin Draher D-r-a-h-e-r A No David Boden do you know David Boden A Yes Okay Who is Mr Boden an associate Page A Are you asking me what I know now or what thought then Who did you understand Mr Boden David Boden to be when you became employed or associated with RRA in April of09 A In April of09 I had not heard the name but lets just skip to it Sometime in lets say June or July I am guessing sometime during the summer I understood him to be a lawyer at the finn Did you understand did you understand he was a Florida lawyer or you just understood he was a lawyer A I understood he was a lawyer made the presumption or assumption at that time that since he was a lawyer for RRA that he was a Florida lawyer I have subsequently learned otherwise Did you know did you ever have any business dealings with Mr Boden A Never spoke a word to the guy What did you understand that he actually did at the finn A Had no idea How about Andrew Barnett A Dont know who that is There was an individual he is described Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopkins ElectrOnlcally signed by cynthla hopkins Electronically signed by cynthla hopklns l1 Page as the director of Cruporate Development for RRA A I dont know even know what that means Have you ever heard of the Centurion Credit Fund or the Platinum Management Fund A No Alan Sakowitz A No Wait Alan Sakowitz I have heard that name recently I dont know why I believe actually heard that name in a response Never mind In some nonresponsive answer that your client gave I heard that name MR SCAROLA Keep going BY MR CRITTON Mr Edwards with regard to your phone did you have a direct line at RRA A Yes What was that phone number A I dont remember And is your cellphone today the same as it was back then A Yes And whats that number please MR SCAROLA Cellphone number THE WITNESS Page BY MR CRITTON Did you ever have a finn cellphone or just your own personal cellphone A No Just my own personal cellphone During the time that you were at the firm were you ever involved in making any type of a presentation to anyone regarding the Epstein cases A 1nc1uoing omer lawyers Within the tlm1 Let me rephrase it I am going to rephrase You already told us that you have talked about the Epstein cases with other lawyers correct A Right Were you ever present in a meeting where there was a person whom you did not know wherein the Epstein where the Epstein cases were discussed A No At the Owhen you met with Mr Rothstein in his office when Mr Adler or whoever asked you to come up that one time and there was Adler Rothstein and yourself you said there was an individual on the phone A Right It was another lawyer with the 243inn And how do you know it was another lawyer with the firm A It was either Marc Nurik or Mark Fistos Mark Page Fistos is my partner now Marc Nurik is the la who represents Scott Rothstein now I dont know which it was but it was one of the two Okay Wm you ever present at a meeting where someone who you didnt know was pro:;cmt when the Epstein case was discussed A No Were you ever asked to get on a phone call where the Epstein cases were discussed that you didnt that you couldnt confirm who you may have someone who may have said this is Joe Smith on the other line but where you discussed the Epstein case over the phone with another lawyer from your firm A I dont understand that question Did you ever make a phone call or did you ever receive a phone call where you discussed the Epstein case with another lawyer in your firm that is that person A Yes outside of the office A What Okay Obviously you would get calls within A Evenyou the confines of your office Right I Page understand that A You fall in that category I am having a hard time The question is did you ever have were you ever oonferenced in on a call that was supposed to be among RRA lawyers regarding an Epstein case A No Did anyone ever request that you prepare a swranary of any of your Epstein cases that you in turn sent by either e-mail or memo to anyone else A I dont believe so After you joined the RRA finn in April of did there come a point in time when you requested that that you requested the depositions be taken out of state of a number of witness Well let me ask you this question MR CRITTON Let me let make it easy Let me show what I will mark as Exhibit Plaintiffs Exhibit No was marked for identification BY MR CRITTON Before I get to that Mr Edwards were you aware of any cases that Mr Rothstein himself settled for over million while you were employed at the firm Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthfa hopkins Electronically 225ioned by cynthia hopkins Electronically aigMd by cynthla hopkins ll Page A I was never aware of any cases that Rothstein even handled much less settled Were you aware of whether did anyone ever tell you whether Mr Rothstein even did legal work at the finn or whether he was just a rainmaker A I no no one ever told me one way or the other Would it be a correct statement that you never saw him perform any legal work during the time you were at the finn A lbats a correct statement Would it be a correct statement as far as you knew he was kind of a gadfly going to his various business ventures and then he would hole himself up in the office A He VaS the guy on the billboards and at the Triple A arena and everything else marketing the firm and bringing business in and thats at least what I believe he did If its true or not I dont know to this day With regard to Exhibit do you recognize this e-mail A I I dont recognize the e-mail Do you recognize and I will represent to you that I received the e-mail It was sent to me Page as well although I am not shown as a recipient I received e-mail THE WITNESS Are you talking about the fax MR CRITTON I am sorry the fax MR SCAROLA Exhibit Exhibit MR CRITTON Exhibit Let me start again Exhibit fax THE WITNESS Correct MR CRITTON Dated July 22nd THE WITNESS I recognize that BY 1R CRITTON And do you recognize on Page it says very truly yours Rothstein Rosenfeldt Alder and then there is a what appears to be a signature and under that it says Bradley Edwards Esquire partner fort sic the finn Do you see that A Yes I see that Do you recognize the signature A No Is that how you sign your name A No Do you know whose signature that is or purports to be A I have absolutely no idea Page Do you recall sending or directing that this facsimile be sent Or let me strike that Who was your secretary at that time Who is well BJE is you Who is the MOL A Vho is the MGL Lets see On Page There are your initials Bradley Edwards BJE and then MGL Do you recognize that A No I mean as you are very aware problems with secretaries during that period of time I I had more than my share and that could have been a time period where I did not have a legal assistant at all And I do not recognize the initials MGL to identify anybody that I lmow With regard to the indlvidua1s who were listed in Exhibit specifically Donald Trump Leslie Wexner Bill Clinton with those individuals you sent out this facsimile or at least your office sent out the fax Exhibit requesting dates for these individuals to be deposed correct A Yes AU right Prior to your joining RRA you had never requested either that the deposition of Mr Trump be taken Mr Wexner nor Bill CJinton correct Page A I never requested a deposition to be taken includmg any deposition of those three individuals I understand but all right A The answer to your question is yes All right Thank you Paula Heil do you know who that person is A Do I know who it is I know that its somebody who was involved with Bear Stems at some potn1 in time You also requested dates and in fact served a subpoena on Alan Dershowitz the Harvard law professor correct A Correct AndMr Dershowitzyou were aware was one of Mr Epsteins criminal defense lawyers correct A At some point in time I knew that in the past he had been an attorney of Mr Epstein Well you had you had certain records from the State Attorneys Office didnt you or from the police report A And thats what Im saying yes involved in the civil cases with us no I didnt know that he had involvement But yes I did know he wru a fonner Im sorry go ahead A I did know that he was a former attorney of Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopklns Electronically signed by cynthla hopklns Electronically Signed by cynthia hopklns ff76c2ea Page Jeff Epstein Well you also under.stood Mr Epstein has had ongoing criminal law i even during the time of the civil correct A No Sure Well you were aware that Mr Epstein was operating under the nonprosecution agreement that he was bound by the a nonprosecution agreement correct A Im aware of the existence of a nonprosecution agreement Well and in fact you came into possession of the nonprosecution agreement sorretime in because Judge Marra ordered that ordered the United States Government to turn over to all of the attorneys and the clients who were listed as alleged victims correct A Yes So you had possession of the N.P.A as of sometime in the year correct A Right AH right And so you and you were aware that under the nonprosecution agreement Mr Epstein was required to meet certain requirements that Mr Epstein had a requirement to meet certain Page standards or certain provisions of the agreement otherwise the U.S.A could potentially declare there was a breach of the agreement true A I suppose Well youre a former prosecutors too so you knew what a nonprosecution agreement was true A No I had never seen a nonprosecution agreement in my life before this one When you got the nonprosecution agreement you reviewed it A Yes I did So you were familiar with A Right And you understood from at least looking at the police report that you had access to that ls Mr Dershowitz had represented Mr Epstein with regard to negotiating his plea that ultimately was reached in negotiations with the federal government true A I knew he played a role Now with regard to Mr with regard to the depositions of well let me strike that Also listed both on your on Jane Does and L.W.s and W.s updated interrogatory answers which were provided during the vear an individual named Page Tommy Mottola was listed Do you know who Mr Mottola is A Gener21Iy I think I know who that is Who did you understand Mr Mottola was A Something to do with the music industry All right And the name David Copperfield was also retbrcnced a a potential witn in the case correct A That is correct All right And did you and you in fact attempted to coordinate a deposition for Mr Copperfield is that correct MR SCAROLA Are you asking about whether communications occurred with you MR CRITTON Sure MR SCAROLA regarding such a deposition BY lv1R CRITION Let me rephrase it With regard to the lawyers in the case including myself you attempted to coordinate a time for completing or talcing the deposition of Mr Copperfield Mr Mottola who I will represent is the fonner president of Sony Records fonner president Bill Clinton Alan Dershowitz Donald Trwnp and Leslie Wexner true Page A False Which of those as to which one of those is that false A Tony Mottola So but you did attempt to coordinate the depositions of Donald Tnlip Mr Dershowitz former pre::;ident Clinton David Copperfield and Leslie Wex.ner correct A believe so And with regard to Mr well let me strike that In setting these depositions that is in requesting these deposition be taken sometime in June and July of or requesting dates for them did you have discussions with other attorneys in your fmn as to the benefits that would exist in your case your three cases against Mr Epstein by taking these individuals depositions MR SCAROLA Objection Same as grounds previously stated instruct you not to answer BY MR CRITTON Mr Edwards were you involved in the discussions regarding the deposing of any of the people of these individuals Mt Trump that is in discussions with any other lawyers in your firm includiruz Scott Rothstein Pages to PROBB COURT REPORTING AGENCY INC aectronically signed by cynthla hopklns Electronically signed by cynthla hopklns Electronically signed by cynthla hopkins Page A Weissing Or RRA Mr Howell or Mr Cassell have any interest in those cases A No At any time Jet me strike that You are aware that Mr Alfredo Garcia has pied guilty to an obstruction of justice charge based on the news A I dont know Alfredo Garcia at all Sorry about that The head of Alfredo Garcia With regard Mr Rodriguez Alfredo Rodriguez are you aware through news reports that he pied guilty to obstruction of justice A Yes At any time have you been given access to the pamphlet book and/or any of the yellow pages that have been referenced in the criminal indictment MR SCAROLA I am going to instruct you not answer that question on the basis of attorney-client and work-product privilege BY MR CRITTON Has the have you been have you had any contact with the criminal defense lawyer for Mr Rodriguez MR SCAROLA You can answer yes or no Page TIIE WITNESS No BY MR CRITTON Have you had any communication not a conversation but any communication with the criminal defense lawyer about obtaining a copy of the pamphlet and/or the pamphlet book or the yellow pages that are referenced in the criminal indictment that were at one time in the possession of Mr a Rodriguez and that he apparently was trying to sell to the cooperating witness lo MR SCAROLA I am going to instruct you not to answer any question about anything that you may have done in COilection with the fulfillment of your responsibilities as counsel for the Plaintiffs in the three pending cases BY MR CRJTfON Again of course youre going to continue to follow Mr Scarolas direction A On what I have done or what I have not done all of that is work-product Well you have filed a motion to obtain a copy of the pamphlet book and the yellow pages of Mr Rodriguez correct I am sorry either a motion well strike that You have filed a motion in federal cowt to obtain a coov of the of Page the information that is held by the FBI which would include the pamphlet and the yellow the pamphlet and the yellow pages true A I have Adam Horowitz has and I may or may not have piggybacked his motion But as sitting here right now I I dont remember drafting that motion Are you sure he hasnt piggybacked your motion A rm not sure If you show me my motion I can tell you whether I drafted it or not Have you A That that was certainly an idea Have have you also you have also served a motion to obtain FBI files that relate to Mr Epstein is that correct A Correct Okay Have you spoken as a result of the motion that you filed has the government have you spoken with the United States Attorneys Office or representatives for the FBI with regard to the irotion which you filed MR SCAROLA Objection privilege and instruct you not to answer BY MR CRITTON Have you received any type of response Page from the United States Attorneys Office or the FBI with regard to the motion that you have filed MR SCAROLA You may answer that only with respect to those matters that are matters of public record that is if a response has been filed with the court or provided to you in the form of a pleading you may respond TI-IE WI1NESS I cannot respond to that question MR CRITTON All right Were going to quit at I dont want to go on MR SCAROLA You already you already missed that MR CRlITON All right Well lets ru adjourn the deposition today and I will arrange with you for a time to finish MR SCAROLA Well so that the record is clear it is our position that you have had more than adequate time to conduct an appropriate examination ofMr Edwards and we will resist any further effort to depose him MR CRITTON I understand your position Disagree with it but understand it MR SCAROLA Thank you THE VIDEOGRAPHER This concludes todays Pages to PROSE COURT REPORTING AGENCY INC EhlctronicaUy signed by cynthia hopkins Electronically signed by cynthla hopkins Electronically signed by cynthla hopkins Page videotape deposition of Scott Rothstein The time is THE WITNESS Whoa whoa THE COURT REPORTER Yes Bradley Edwards THE WITNESS Please dont lump me in with that guy man MR SCAROLA This concludes the deposition of Mr Bradley Edwards THE VIDEOGRAPHER Oh rm sorry This concludes the deposition of Mr Bradley Edwards The time is p.m A discussion was held off the record THE COURT REPORTER Did you want to order this MR CRITTON Ask me tomorrow MR SCAROLA I will take a copy ofit Lets stay on the record We dont need to be on the video record but I want to make the statement that we would consider it entirely inappropriate for any portion of this deposition to be used for any reason whatsoever that is not directly connected with the prosecution of the pending claim against Mr Edwards or the defense of the counterclaims Thank you M:R CRlTTON Bye MR SCAROLA Bye Witness excused Deposition was concluded Page lJ CERTIFCATE OF OATH IBE STA TE OP FLORIDA COUNTY OF PALM BEACH I the undersigned authority certify that Page BRADLEY EDWARDS ESQUIRE personally appeared before me and was duly sworn on the 23rd day of March Dated this 5th day of April Cynthia Hopkins RPR FPR Notary Public State of Florida My Commission Expires February I My Commission No DD CERTIFICATE THE ST ATE OF FLORIDA COUNTY OF PALM BEACH I Cynthia Hopkins Registered Professional Reporter Florida Professional Reporter and NO!ary Public in and for the Statr of Florida at large do hereby certify that I was authorized to and did rt said deposition in stenotype and that the foregoing pages are a 1rue and correct transcription of my shorthand notes of said deposition I lunher cenify 1ha1 said deposhion was taken al the lime and place hcreinabove set forth and that the taking of said deposition was commenced and completed as hereinabove set out I further certify thal I am not anomey or counsel of any of the partios nOI am I a relative or employee of any auomey or counsel of party conm:cn:d with the action nor am I financially in ted in the action The foregoing cer1ifica1io11 oithis transcript does not apply to any reproduction of the same by any means unless umler the direct control and/or direction oflhe certifying reporter Dated 1llis Slh day or April thia Hopkins RPFPR Page Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthta hopJdns Electronk:ally signed by Cynthia hopkins EJectronk:ally signed by cynthla hopklns ff76c2ea lQ ll LS DATE April Stli,lOIO TO l!RADLEY BDWAII.DS ESQUJRI c/o Jad s-do qui SEAJI.CY DENNEY SCAROLA llARNRAR.T SHIPI..SY P.A hlm80 Ch Lal W,st P.im llealt 1lorida IN RE Bp,;tein ltoll,slri CASE NO AG lake nockc tl1l OIi Tl OISday lhc 23rd of March yoogavc OUrdcpcilition in lhc refemd mw.r Auhat lime did no1 wal,.:sw,atu ltilnow oeccal lhal II your deposida lu prc iwslyagn,c,:110 1hc will be fumished IO yoo thrrush u,,r lffl Pl rad tho futi wing mstrudions cotdllily Al he end of the lrS!i liJ I you will llnd cmwuheet As JU rue yoor any cma,:s orcorrecuav lol you with mould be not 253loo 5hr iq pege and tiilc no-ofnidclloop DON0Twri1toolhc tr.weriJ I ii.elf Onoc you have rad lhc 1ra1 fipl and MlCd Ill bcswe1ooign andd.i.:lhe.-.ta shectandro!""-P"P mo If you do oot Nad ond sign tl depositiO withio a liMe lhc Ciriginll which boo afmdy been 253warded tho attorney may be fi1 wilh tho Cl,rlc of!ho Court lf II wish I woi-.cY""f 225igm usc in tho bin DI tl bonom of this leltor lQ ii Very Indy OUR 4,hAS mnio Ull ici It.PR fl do hcnoby waive rny signaiu BRADLEY EDWAADS ESQUIRE CERTIFICATE THE STA TE OF FLORIDA COUNTY OF PALM BEACH Page Page I hereby certify that I have read the foregoing deposition by me given and that the statements contained herein are true and correct to the best of my knowledge and belief with the exception of any corrections or notations made on the errata sheet if one was executed Dated this __ day of BRADLEY EDWARDS ESQUIRE Job Page ERRATA by cynthia hopklns Electronically signed by cynthia hopldns
