Electronically Filed I AM Page questions Mr Scarola rm more than happy to sit here and answer them Would you like to continue BY MR SCAROLA Yes fd like to know what the answer to that question is Did anyone ever sift through your garbage looking for damaging evidence MR PIKE Form THE WITNESS I dont know a BY MR SCAROLA Did you ever have damaging evidence in your garbage A Whats damaging evidence sir Evidence tending to implicate you In criminal conduct MR PIKE Fonn THE WITNESS At least today Mr Scarola with these with your questions and your claims and your defense of Mr Edwards and his finn the Rothstein finn while his partner sits injail today rm going to have to assert my Fifth Sixth and 14th Amendment Right sir BY MR SCAROLA Did you ever have any evidence in your garbage that would subject you to blackmail MR PIKE Form Same same objection Page THE WITNESS Again Ill respectfully answer the question by asserting my Fifth Sixth and 14th AmendmentRJghl BY MR SCAROLA YourComplamt in paragraph page says that Upon information and belie Rothstein David Boden Debbie Villegas Andrew Barnett Michael Fisten and Kenneth Jenne_ all employees of RR.A through brokers or middle men would stage regular meetin during which false statements were made about the number of cases/clients that existed or RRA bad against Epstein and the value thereof Do you have any knowledge that Mr Edwards ever knew ut such meetings being conducted MR PIKE Fonn To the extent you understand the question and ft will not violate any attorney/client or work product privilege infonnation you can answer that question MR SCAROLA Mr Pike it has become evident that that speaking instruction to your witness is an instruction for him to assert an attorney/client privilege regardless of whether it is or is not valid and I object to it MR PIKE Let me make the record clear Page Youve been interchanging knowledge with personal knowledge And many of the objections to which I am asserting an attorney/client and work product privilege are bued upon your malphrased question and use of personal knowledge and knowledge interchangeably with those questions So.if you want to rephrase your question to attempt to elicit a response Jet me finish then I have no objection to that However Im not going to sit here and allow my client to waive attorney/client and work product Now to the extent youre saying rm coaching the witness I object to that because I am certainly not The witness is here to answer your questions and I believe has been answering your questions today to the best of his ability MR SCAROLA I am saying youre coaching the witness BY MR SCAROLA Could you answer the question MR PIKE Same objection nm WITNESS Youll have to repeat it BY MR SCAROLA Do you have any infonnation indicating that Bradley Edwards ever had any knowledge of anyone Page associated with the Rothstein finn holding meetings during which quote false statements were made about the number of cases/clients that existed or RRA had against Epstein and the value thereo unquote MR PIKE Form Same objection THE WITNESS My best recollection is the U.S Attorney has accused the Rothstein firm of just those types of meetings where the partners got together schemed to defraud local investors of millions of dollars by fabricating cues of a sexually charged nature And whether Mr Edwards personally participated rm going to at least today sir have to assert the attorney/client privilege but look forward to one day disclosing it MR SCAROLA Move to strike all unresponsive portions of the answer BY MR SCAROLA Paragraph of your Complaint says that RR.A Rothstein and Edwards claiming the need for anonymity with regard to existing or fabricated clients they were able to effectively use initials et cetera Do you have any knowledge that Bradley Edwards fabricated a client to bring a claim against you MR PIKE Form Pages to PROSE COURT REPORTING AGENCY INC Page Page 1lffi WllNESS I believe Mr Schercrs MR PlKE then please C.Omplaint THE WITNESS Yes BY MR SCAR.OLA MR PIKE answer Mr Scarolas question rm not asking about Mr Sc::herers Complaint lHE WITNESS Separate from Im addng about any evidence that you have MR SCAROLA Objection Coaching the MR PIKE The witness is basically been five witness words into his sentence and youre not allowing him THE WITNESS Separate from the communication to finish once again Ive had with my attorneys I amt answer that So If you recaJI the question then please question respond MR PIKE Mr Scarola rm confused I 1HE WITNESS Please repeat it back please started objecting to form in the beginning ofthJs MR PIKE Madame C.Ourt Reporter if you deposition You then instructed me which is would against the rules Mr Pike I dont know whats Pending question was read wrong with the fonn I object to you objecting to MR PIKE Fonn form 1llE WnNESS The pleadings of Mr Scherer and Then I assert the attomey/cllent work his claim against the Rothstein fmn for a massive product and now youre telling me Im coaclrlng the fraud as well as Mr Sakowitts claims to at witness least in the de.5Cribed in the public press So tell me Mr Scarola what is the what because he went to the FBI for fabricating cases is the way that you would like me to object in this that included initials deposition and maybe I can confonn that way for With respect to anything specific with you which may or may not be consistent with the Mr Edwnrds rm goins to have to claim the Florida Rules of Civil Procedure attorney/client privilege today sir MR SCAROLA Mr Pike BY MR SCAROLA MR PIKE Yes sir Page Page Do you have any do you have knowledge of MR SCAROLA if you dont know the the existence of any evidence that Bradley Edwards knew difference between a form objection and a privilege that Rothstein was utilizing RRA as a front for a Ponzi objection scheme MR PIKE Right MR PIKE Fonn MR SCAROLA then this deposition is not 1llE WTINESS Thats attorney/client the proper context in which for you to learn the privilege difference between a form objection and a privilese BY MR SCAR.OLA action Do you have knowledge of any evidence that MR PIKE Im pretty clear on what a fonn would indlcate Bradley Edwards should have known that objection is and what a privilege objection is and Rothstein was utilizing RRA as a front for a Ponzi Im pretty knowledgeable on that The problem scheme MR SCAROLA Then we dont need to engage in MR PIKE Form any further discussion THE WITNESS At least today MR PIKE I want to Uy to make the record MR PIKE Wait clear because initially you didnt want me to TIIB WITNESS Sony object to form You wanted me to speak So rm MR PIKE Fonn Same objections Same thinking youre conceding to that point attorney/client work product as to the last What my question is is Whats wrong with my question Same objections here attorney/client objecting to attorney/client work product So-I work product guess rm asking you what you were asking me nm WITNESS And today Im going to have to earlier on Whats wrong with the fonn assert the attorney/client privilege We can just move forward MR PIKE To the extent you can answer that BY MR SCAROLA question In your Complaint you identify the RRA law THE WITNESS I understand finn Rothstein and Edwards as the quote 1itigation Pages to PROSE COURT REPORTING AGENCY INC Page Page team unquote Edwards individually and personally sold all to You then go on to say in paragraph of your be sold and/or assisted with the sale ofan Interest in Complaint at page that Rothstein and the non-settled personal injury lawsuits litigation team Mil PIKE Before you answer that question MR PIKE Wait a minute Put that down for a Madame Court Reporter will you please read that second Hold on question back lo me nm WITNESS You can read it Pending question was read BY MR SCAROLA MR PIKE To the extent you can answer that Individually and in a concerted effort may _question without diwlging attorney/client or work have unethically and illegally engaged in certain product infonnation you may answer that question specified conduct MR SCAROLA Objection Coaching May we correctly conclude from that statement TiiE WITNESS You said allowed to be sold that you dont have any knowledge as to whether the rm going to assert attorney/client privilege to quote litigation team including Mr Edwards engaged the answer Im afraid but rd like to answer that in any unethical and illegal conduct question MR PIKE For now while rm reviewing the BY MR SCAR.OLA document itself Im just going to just tell you to Do you have knowledge of any evidence hold off indicating that Bradley Edwards ever reached ag,eements THE WITNESS Sure to share attorneys fees with non-lawyers MR PIKE on answering that question MR PIKE rm sorry Mr Scarola can you You may want to go offthe record so we dont telJ me what page of the Complaint youre referring have a Jag in to if you are MR SCAROLA No Id like it on the record MR SCAROLA rm not referring to any page of Thankyou tho Complaint although I will tell you that that MR PIKE Mr Scarola did you bring an extra precise aJlegation is made in the Complaint Page Page copy of the Complaint that youre questioning TIIB WITNESS In fact Mr Scarola we have Mr Epstein on for Mr Epstein lo look at subpoenaed Mr Edwards documents and documents MR SCAROLA No from his finn that I believe will in fact give me MR PIKE Okay rm going to have to go get more specificity with the answers to that question him a copy so be can the paragraphs oftbis rm looking fOIWllJd to getting the that Complmnt are very long end the Complaint itself is specific evidence With respect to what we ln excess of It was approximately 3S pagee currently know sitting hero today rm so unfortunately going to have to claim my MR SCAROLA Ill withdraw the question attorney/client privilege BY MR SCAROLA BY MR SCAROLA Do you have any evidence that Brad Edwards Do you today have any evidence to support an sold allowed to be sold and/or assisted with the sale assertion that Bradley Edwards ever used investor money of an interest in non-settled personal injury lawsuits to pay L.M E.W and/or lane Doe up-front money such MR PIKE Fonn that they would refuse to settle civil actions THE WITNESS The newspapers have widely MR PIKE Same instnJction reported that the Rothstein firm engaged in illegal nm WITNESS Youll have to get I need to structured settlements of cases of a sexual nature hear the first part of the question Do I have any including specifical me We have subpoenaed the evidence Do I have knowledge of evidence rm documents from Mr Edwards and hls finn and we have SOJJ Whatwasthe not been able to get them as of yet BY MR SCAROLA I am confident that once we do I will be able Do you have knowledge of any evidence to to answer your questions with more specificity support that assertion BY MR SCAROLA MR PIKE fo the extent you can answer that As you sit here today do you have any question without violating attorney/client worlc evidence whatsoever to support an assertion that Bradley product please do so Pages to PROSE COURT REPORTING.AGENCY INC Page MR SCAROLA Objection Coaching THE WITNESS rm going to have to assert the attorney/client privilege Im afraid though Id like t_o answer that question as well sir BY MR SCAR.OLA Do you have any evidence to support the assertion that Bradley Edwards conducted searches wire taps or intercepted conversations in violation of State or Federal laws and Bar rules A Your question once again asked did Mr was Mr Edwards personally involved in the eavesdropping Did he walk to someones house and sort of put a bug in their house Did he personally stand outside The question is did Mr Edwards finn engage in this behavior in an attempt to defraud local investors out of millions of dollars The U.S attorney bas filed a Complaint saying that they did The Complaints filed by Scherer saying that his finn did The Scherer Complaint says my name and the boxes offiles that weve subpoenaed used my name sir We have requested infonnation but up until today have not received any To give you a more specific answer Im afraid I cannot Page Do you have knowledge of any evidence that Bradley Edwards ever conducted searches wire taps or intercepted conversations in violation of State or Federal laws and Bar rules MR PIKE Same instruction 1HE WITNESS The newspapers and the U.S Attorneys Complaint widely reported that Mr Edwards finn and people hired by bis finn investigators hired by his finn fraudulently representing themselves as FBI agents engaged In just those activities sir BY MR SCAROLA Do you have any knowledge of any evidence that Bradley Edwards was ever aware of any such activities A rm going to have to MR PIKE Same objection nm WITNESS assert the attorney/client privilege to that sir BY MR SCAR.OLA Do you have any knowledge that Bradley Edwards ever participated in or was aware of actions that utilized the judicial including but not limJted to unreasonable and unnecessaJY discovery for the sole purpose of furthering a Ponzi scheme MR PIKE Same objection Page To the extent you can answer the question without disclosing attorney/client or work product infonnation do so THE WITNESS The pleadings of Mr Scherer with respect to the largest Ponzi scheme in South Floridas history engaged in by Mr Edwards fmn and Scott Rothstein who currently sits injall probably for the rest of his life for engaging in not only illegal wire taps and eavesdropping but an abuse of the entire legal system I believe speaks for itself Unfortunately with respect to Mr Edwards today Im going to have to assert the attorney/client work privilege sir BY MR SCAROLA Is it your contention that Mr Scherels Complaint even contains the name Bradley F.dwards A I dont recall sir Did sexual assaults ever take place on a private airplane on which you were a passenger MR PIKE Fonn Relevance THE WITNESS At least I would lilce to answer each and every one of your questions here today Mr Scarola But at least today Im going do have to assert my Fifth Sixth and 14th Page Amendment Rights as provided by the U.S Constitution BY MR SCAROLA Does a flight log kept for a private jet used by you contain the names of celebrities dignitaries or International figures A At least today sir Im going to have to respectfully decline to answer based on my Fifth Sixth and 14th Amendment Right though Id like to answer that question Have you ever had a personal relationship with Donald Trump A What do you mean by personal relationship sir Have you socialized with him A Yes sir Yes A Yes sir Have you ever socialized with Donald Trump in the presence of females under the age of A Though Id like to answer that question at least today Im going to have to assert my Fifth Sixth and 14th Amendment Right sir Have you socialized with Alan Dershowitz A Yes sir Hes my attorney as well as a PROSE COURT REPORTING AGENCY INC Pages to Page Page friend this just this type o_fbehavior the answer is Have you ever socialized with Alan Dershowitz today at least I must wert my Fifth Sixth and in the presence of females under the age of 14th Amendment Right though rd like to answer MR PIKE Fonn each and every one of your questions Mr Scarola nm WITNESS Sir at least here today rm BY MR SCAROLA goir13 to have to as.,m my Fifth Amendment Sixth Have you had a social relationship with David Amendment and 14th Amendment Rights Copperfield BY MR SCAROLA A As a reaction to once again the abusive Have you ever socialized with Tommy Mottola discovery process of bringing in names of people that A This is the type of questions where people who have absolutely nothing to do with any of Mr Edwards have nothing to do with this case whatsoever have been Mr Rothsteins or their clients claims by bringing in brought into the case by Mr Edwards in an attempt to the names of friends of mine strictly in an attempt to simply imperil my relationships with social friends and stress my relationships imperil my business serves as an example of why this case has been brought relationships rm going to say yes I do know against Mr Edwards and his firm sir Mr Copperfield MR PIKE Fonn as well JJave you ever socializ.ed with David BY MR SCAROLA Copperfield Well do you know who brought those persons A Again as names into this lawsuit MR PIKE Fonn MR PIKE Fonn 11IE WITNESS Sony And just to be clear what Mr Scarola I Its II typical Edwards/Rothstein strategy of believe talking about this la-wsuit Epstein versus trying to involve well-known people in maliciously RRA fabricated cases in order to fleece Investors out BY MR SCAROLA of millions of dollars They brought up names in 2S Yes sir thats the lawsuit Im talking attempts at abuse of discovery process to try and Page Page about The one in which your deposition is being taken take discovery of people who have nothing to do today with this case Do you know who brought those persons names Did I socialize with David Copperfield The into this lawsuit answer is yes A As a reaction and only a reaction to total BY MR SCAROLA misbehavior on Mr Edwards part and the Complaint was Did you ever socialize with David Copperfield obviously written by my attorneys sir In the presence of females under the age of So you know that those names are in your A Im sure again this question is a typical Complaint right question of Mr Edwards/Rothstein scheme to defraud A Yes sir investors asking questions knowing it serves no purpose Okay So because those names arc in yow or relationship relevance to their case whatsoever Complaint rm asking you about the people you named At least today though Id like to answer that Have you had a social relationship with Tommy question on advice ofmy Counsel and only on advice of Mottola my Counsel Im going to have to assert my Fifth Sixth A The names in my Complaint are strictly as a and 14th Amendment Right reaction to the abusive discovery process by MR PIKE Form as well Mr Edwards his partnm Scott Rothstein who sits in BY MR SCAROLA jail in an attempt to imperil my friendships Have you ever had a social relationship with But yes I have socialized with Mr Mottola Bill Richardson Governor of New Mexico and fonnerly Have you ever socialized with Mr Mottola in U.S Representative and Ambassador to the United the presence of females wider the age of Nations MR PIKE Form MR PIKE Fonn nm WITNESS At least today the typical to nm WllNESS As is typical of the Edwards the Edwards contention of bringing cases of a scheme along with his partner Scott Rothstein malicious nature where his par1ner sits in jail for who sits in jail what they attempted to do was Pages to PROSE COURT REPORTING AGENCY INC Page Page bring in any celebrity I might have known question Im told by my Cowisel that ifl choose well-known people in an attempt to strictly to do so which is my preference I risk losing imperil my relationships with these people where their re on these people have no bearing whatsoever on any of BY MR SCAROLA their claims or cases How many children have you sexually abused Yes I do have a social relationship MR PIKE Fonn BY MR SCAROLA And I just want to be clear on the record Have you ever socialized with Mr Richardson These types of questions are argwnentative and in the presence of females under the age of harassing And moreover its my contention that MR PIKE Fonn these types of questions are not related to thls THE Wl1NESS Again typical of the lawsuit by any stretch of the imagination In this Edwards/Rothstein scheme of bringing in well-known deposition while Ive been liberal in allowing people asking them ridiculous questions these questiom are being utilized in an attempt ridiculous questions in an attempt strictly to to provoke a waiver of the Fifth Amendment Right imperil my relationships with these people where There has been an Order entered by I believe they have absolutely nothing to do with anything to Judge Hafele regarding these types of questions do with Edwards Rothstein or any of their alleged So with that caution Mr Scarola I would ask victims the answer to your question is yes I you that you refrain from asking abusive and have socialized harassing questions that are not relevant to this BY MR SCAROLA case Yes but that wasnt my question MR SCAROLA Well its very interesting that My question was Have you ever socialized you claim theyre not relevant when they are with Mr Richards in the presence of females under the directly taken from the allegations in your age of18 Complaint MR PIKE Fonn And I agree with you that they are not Page Page THE WITNESS In re.,ponse to your question relevant because there is no basis whatsoever for again my full answer was typical of the this claim against Mr Edwards But since youve Edwards/Rothstein scheme to ask questions of a made these baseless allegations am obliged to sexual charged nature crafted cases the U.S pWSUe the allegations by asking these questions Attorney has called his firm the largest fraud In So well move on from there And whenever you U.S bistoJ fleecing investors out of millions of think its appropriate to tenninate this deposition dollars by engaging in just these types of because you believe that Ive acted questions Though I would like to answer each and inappropriately be my guest leJ question about every one of these people on MR PIKE I appreciate your invitation advice of my Counsel today I must take Emert Mr Scarola 1l my Fifth Amendment Sixth Amendment and 14th rm going to move to strike Amendment Rigbt Though Id prefer to answer the The fact is Mr Scarola is that these types question I was told that lfl choose to do so I of questions have already been ruled upon as being risk losing their representation sir argumentative and harassing BY MR SCAROLA If you want to direct some questions relevant Have you ever sexually abused children to your lawsuit I invite you to do so But MR PIKE Fonn attempting to use this deposition process as a mE WllNESS On advice of Counsel and only mechanism to provoke a waiver of the Fifth upon advice of Counsel though Id like to answer Amendment and to obtain information that is more or that questlon as well as every other one of your potentially more relevant to Mr Edwards cases in claims brought by Mr Edwards and his partner who which he is lead Counsel on I think is improper currently sits In jail sir I would lilce to answer BY MR SCAROLA those questions But today at least I haw to Did you have staff members that assisted you assert my Sixth Amendment 14th Amendment and Fifth in scheduling appointments with underage females that Amendment RJgbl Though Id prefer to answer the is females under the age of PROSE COURT REPORTING AGENCY INC Pages to Page A So along with many of the other claims that the Rothstein firm crafted with malicious claims against people like me and others of a sexually charged nature in order to simply fleece investors out of millions of dollars in South Florida these typeS of questions though Id like to answer today at least this specific question Im going to have to assert unfortunately my Fifth Sixth and 14th Amendment Right though Id prefer to answer the question BY Mlt SCAROLA Who are the others referred to in that response A Again sir You said you and others Who are the others that you were referring to A Youll have to read my answer baclc MR PIKE Im sony Madame Court Reporter would you please read the witness answer back nm WITNESS ouJJ have to I have to take a bathroom break MR PIKE Actualty I dont one second For the record were going on now Is there do you have a time frame as to when you MR SCAROLA About a half hour MR PIKE You have a half hour left age MR SCAROLA Uh-huh MR PIKE Okay Do you have an objection to us taking a quick bathroom break and 1llE WITNESS Ill Just walk out and back in MR SCAROLA If Mr Epstein needs to go to the bathroom Mr Epstein needs to go to the bathroom THE WI1NESS Thank you sir MR PIKE Then were off the record VJDEOORAPHER Were offthe reoord Brief recess VIDEOGRAPHER We are back on video record at BY MR SCAROLA I think when we went off the record you had requested that the last answer that you gave and the question asked of you based on that answer be read back so well start there MR PIKE Madame Court Reporter Previous question and answer were read nm WITNESS Sounds like a complete answer to me BY MR SCAROLA No sir My question to you following that answer was Who are the others to whom you made Page reference in that response You said me and others Who are the others A Can you repeat where it says me and others rm sorry MR SCAROLA Read it back again please Sandy Answer was read TIIE WITNESS The others are people reported in the press to be many people in South Florida who were the victims of the Rothstein scam rm glad Im happy to answer the others rd Uke to know the others In fact weve subpoenaed documents from the bankruptcy trustee of Brad Edwards firm in an attempt to find out more details of the others that youve just asked about People I believe the Attomey Scherer has filed a Complaint for some of the others who have been defrauded as well as some of the investors who were told about many others sir BY MR SCAROLA So you dont know any names is that correct MR PIKE Fonn Move to strike Mischaracterizes the witness testimony THE WITNESS Im sure thats an its an easy way of saying that as a response to the Page questions and subpoenas weve asked Mr Edwards to produce so we can find out the specific names of the others who have been the U.S Attorney has claimed have been blackmailed and victims of the Rothstein finn rd be happy and hopefully at the end of this trial evmyono will Im.ow somo of the names ofthc others sir BY MR SCAROLA Do you know the names of any of the others A No sir I do not However the U.S Attorney we believe is going to file more charges against Mr Roth Mr Edwards partners And Mr Scherer and us have subpoenaed the bankruptcy trustee for the names of the others So sitting here today I do not Hopefully sometime before trial we will have names of the others sir Have you ever pied guilty to any criminal wrongdoing A Yes.sir What crinunal wrongdoing did you plead guilty to A A solicitation of prostitution and procuring a minor for prostitution sir Pages to PROSE COURT REPORTING AGENCY INC Page On bow many occasions did you solicit prostitution A Under excuse me Again On how many occasions did you solicit prostitution A At least sitting here today Im going to have to on advice of Counsel assert my Fifth Amendment 16th Amendment sic and Fourth sic Amendment Right On how many occasions did you plead guilty to soliciting prostitution A Once sir How many acts of solicitation of prostitution did you plead guilty to A Three What are-the names of the individuals who you pied guilty to soliciting as prostitutes A I do not know When did those acts OC UJ A I do not know How many prostitutes have you solicited MR PIKE Fonn nm WITNESS On advice of Counsel at least sitting here today sir Id like to answer each one of those questions However today Im going to have to assert my Fifth Sixth and 14th Page Amendment Right BY MR SCAROLA Who are the minors who you solicited far prostitution MR PIKE Form THE WITNESS Who are the pied guilty to soliciting prostitution There was no soliciting minors charge sir MR SCAROLA Could you read back the response to the question about what Mr Epstein pied guilty to pleue MR PIKE About four questions back Previous question and answer were read MR Pl.KE And his answer MR SCAROLA That was his answer BY MR SCAROLA Who are the minors who you procured for prostitution MR PIKE Form THE WITNESS believe if you my answer was procuring a minor sir not minors BY MR SCAROLA Who is the minor that you procured for prostitution A I do not know Page MR PIKE Form And relevance BY MR SCAROLA How many minors have you procured for prostitution MR PIKE Fonn THE WITNESS On advice of Counsel sir rm going to have to assert my Fifth Sixth and 14th Amendment Righ1 though I pied guilty to procuring a single minor BY MR SCAROLA Yes but my question wasnt about what you pied guilty to I just want to know how many minors you have procured for prostitution MR PIKE Asked and answered THE WITNESS Again at least with respect to what Ive pied guilty to I pied guilty to procuring a single minor With respect to the rest of your question Im going to have to assert my Fifth Sixth and 14th Amendment Rights as provided by my Counsel BY MR SCAROLA When did you procure the minor for prostitution as to which procurement you pied guilty MR PIKE Form TIIE WITNESS I dont Jmow Page BY MR SCAROLA Was there a time before you entered your guilty plea when you knew the identity of the prostitutes that you solicited MR PIKE Form THE WITNESS A BY MR SCAROLA Was there a time before the entry of your guilty plea when you knew the identity of the prostitutes you solicited MR PIKE Form nm WITNESS I dont recall BY MR SCAROLA Was there a time befote the entry of your guilty plea when you knew the.identity of the minor that you pied guilty to procuring for prostitution MR PIKE Fonn THE WITNESS I dont Jmow BY MR SCAROLA Did you plead guilty because you were in fact guilty MR PIKE Fonn Thats attorney/client work product Attorney/client MR SCAROLA havent asked anything about Pages to PROSE COURT REPORTING AGENCY INC Page Page any communication crafting of a sexual nature against people in MR PIKE It definitely could get into a South Florida me and others the others yet to be comrmmication with Mr Epsteins lawyers at the determined However today though Id like to time oftbe criminal proceeding answer every one of his questions on advice of MR SCAROLA No sir it cant CoW1Sel at least today Im 267going to have to BY MR SCAROLA assert my Fifth Sixth and 14th Amendment Right I want to know whether you pied guilty because BY MR SCAROLA you were in fact guilty How many times have you engaged in fondling A rm going to have to assert my Fifth Sixth underage fema1es and 14th Amendment sir MR PIKE Fonn Do you understand the term John to be a slang nm WITNESS This is relewnce here at some reference to the customer of a prostitute point MR PIKE Fonn MR PIKE To the extent you can answer the THE WITNESS Yes sir question BY MR SCAROLA THE WITNESS Again a another one of the How many times were you one ofL.M.s irrelevant questions a.,ked of this lawsuit with customers respect as a client how I was abused by the MR PIKE Fonn Rothstein flnn for his the practices the abuse nm WITNESS L.Ms customers of the legal system the-hopefully the ladies Youll have to rephrase the question sir and gentlemen of jury will be able to see BY MR SCAROLA through some of these ridiculous questions with Your Complaint says respect to questions that today at least I must MR PIKE What page wm-e you reading from take the Fifth Sixth and 14th Amendment but I MR SCAROLA Page believe are obvious to the ladies and gentlemen of MR PIKE Thank you the JUIY what youre trying to do here Page Page BY MR SCAROLA Mr Scarola Paragraph a last_ sentence Under the MR SCAROLA Move to strike Unresponsive circumstances her claim for damages against Epstein MR PIKE No Thats fmo one ofL.M.s many Jolms during that same period et BY MR SCAROLA cetera How many times have you engaged in illegal You have identified yourself in this Complaint sexual touching of minors as one ofL.M.s many Johns which you acknowledge to be MR PIKE FOJm Relevance a reference to a customer of a prostitute 1HE WITNESS Again an iJTelevant question to How many times were you one ofL.M.s this lawsuit strictly a continued attempt to customers for purposes of prostitution bring In irrelevant facts to tho fact of what the A Well now that youve now put on the record Rothstein finn has done to both me and others in that L.M I believe in her deposition is an admitted South Florida defrauding investors of millions of prostitute I would like to answer that question but on dollars Jmowing that at least today Im going to advice of Counsel sir Im going to have to have to with respect to that particular question respectfully decline But I am happy to bear you assert my Fourth excuse me Fifth Sixth and finally admit it in your own questions that your L.M is 14th Amendment Rights an admitted prostitute MR SCAROLA Move to strike as unresponsive MR SCAROLA Move to stn1re Unresponsive MR PIKE Mr Scarola hes answering your BY MR SCAROLA question Youre asking abusive and harassing Have you ever coerced induced or enticed any questions that are unrelated to this lawsuit minor to engage in any sexual act with you lfyou can direct me to anywhere in the MR PIKE Fonn Complaint that even remotely addresses your two THE WITNESS A typical question from questions that youve just posed to Mr Epstein Mr Scarola representing Mr Edwards and the flnn rd be happy to look at the section in the of Rothstein who Scott Rothstein sits in jail for Complaint But moving to strike the witness Pages to PROSE COURT REPORTING AGENCY INC Page answer when hes IIJl!lwering your abusive and harassing questions is improper 8Y MR SCAROLA How many times have you engaged in oral sex with females under the age of MR PIKE Objection Relevance Alnwve and harassing Not reasonably calculated to lead to discovery of admissible evidence in this case nm WITNESS A typical question posed by Mr Scarola in an attempt to divert the attention away from the wrongdoing of Bradley Edwards his partner Scott Rothstein who sits injail for defrauding investors of South Florida of millions of dollars by crafting maliciom of a sexual nature just in order to fleece investors called by the U.S Attorney one of the largest frauds in South Floridas history Mr Scarola as I would like to respond to the questions regarding of your Wlderage girls the fondling or the other questions youve asked me here today w,fortunately I cannot on advice of Counsel answer those questions so I must assert my Fifth Sixth and I 4th Amendment Rights though these questions are totally irrelevant to this lawsuit Page MR SCAROLA Move to strike as unresponsive BY MR SCAROLA Do you have a personal sexual preference for children MR PIKE Fonn Relevance Abusive Harassing Not reasonably calculated to lead to the discovery of admissible evidence in this case nm WITNESS Another totally hrelevant question to this lawsuit Mr Edwards behavior in an attempt to strictly divert attention from the wrongdoing of the Rothstein firm in this matter by asking sexually charged questions in a case where the Rothstein finn has been charged by the U.S Attorney of fabricating claims of a malicious nature hiding behind attorney/client privilege forging documents excuse me but as with respect to these questions designed for nothing more than to harass me Mr Scarola Im going to have to Wlfortunately take the Fifth Sixth and 14th Amendment MR SCAROLA Move to strike as unresponsive BY MR SCAROLA Have you ever acted on a sexual preference for children MR PIKE Form Irrelevant Abusive Page Harassing And not reasonably calculated to lead to admissible evidence in this case nm WITNESS One more of Mr Scarolas irrelevant questions designed nothing more to try to harass me to divert attention from the fact that Mr Edwards and bis firm pezpeba one of the largest fraud in South Floridas history by using people like me and others in an attempt to fleece South Florida investors out of millions of dollars where the U.S Attorney bas accused his finn of being the largest criminal enterprise in South Floridas histOt where Mr Edwards parbler sits in prison potentially for the rest of his life rd like to answer all of your questions here today Mr Scarola even though theyre irrelevant however on advice of Counsel at least today Im going to have to assert my Fifth Sixth and 14th Amendment Right MR SCAROLA Move to strike as unresponsive BY MR SCAROLA Your Complaint at page paragraph says that RRA and the litigation team took an emotionally driven set of facts involving aUeged innocent unsuspecting underage females and a Palm Beach Page billionaire and sought to tum it into a gold mine end of quote Who is the Palm Beach billionaire referred to in that sentence A On advice of Counsel today Mr Scarola though I would like to answer each one of your questions Im going to have to assert my Fifth Sixth and 14th Amendment RighL What is the emotionaJly driven set of facts to which you make reference In that sentence A Its the same set of facts that were used by the Rothstein finn to fleece unsuspecting investors out of millions of dollars crafting fabricating malicious cases of a sexually charged nature with no fundamemal basis whatsoever reported wildly by the press The U.S Attorney has accused Mr Edwards partner of not excuse me Mr Edwards partner sits currently in jail pied guilty to some of these charges There are other members of his firm under investigation for just these types of questions and fabrications But however today though rd like to answer every one of your questions with specificity on advice of Counsel Im not going to be able to Mr Scarola and respectfully decline based on my Fifth Sixth and 14th Amendment RigbL Pages to PROSE COURT REPORTING AGENCY INC Page What day are you prepared to answer all these questions MR PIKE Form Attorney/client and work prod TIIE WITNESS Thats attorney I wish I could answer that question as well but its attomey/client privilege sir BY MR SCAROLA Your Complaint says that Rather than evaluating and resolving the cases based on the merits open parens i.e facts close parens which Included knowledgeable voluntary and consensual actions by each of the claimants et cetera Who are the claimants that are referenced there A Its Im sorry You have to repeat the question Yes,sir YourComplaintsays MR PIKE Page rather than evaluating MR PIKE Can you give me a page sir MR SCAROLA Page paragraph second sentence BY MR SCAROLA Quote rather than evaluating and resolving Page the cases based on the merits that is facts which included knowledgeable voluntary and consensual actions by each of the claimants A Yes Who are the claimants that youre referencing ilim A Theyre the prostitutes you referred to In the past sir What are their names A think the prostitutes names were the prostitute that you described before was L.M With respect to the others Im going to have to claim the Fifth Sixth and I 4th Amendment sir So one of the individuaJs that youre referencing there is L.M is that correct A Ifs the Individual Ive referenced is a person who filed a claim against me lsitL.M A It Is L.M as far as know from the claim Okay Sooneofthepeopletbatyoure referring to is L.M who yolive identified as L.M Is that correct A With respect to that question sir on advice of Counsel Im going to have to assert my Fifth Sixth Page and 14th Amendment What are the voluntary and consensual actions by L.M that you are referencing there A Sir though rd like to answer each one of your questions here today rm going to have to respectfully decllne based on advice ofmy Counsel and have to assert my Fifth Sixth and 14th Amendment Right What are the damages that you claim to have suffered as a consequence of any wrongdoing on the part of Bradley Edwards MR PIKE Fonn THE WITNESS The cost of ridiculous litigation of having my attorneys prepare responses to wildly irrelevant discovery in various locations at a minimum sir BY MR SCAROLA Which lawyers A Bunnan Critton Jack Goldberger and a bunch of the others sir Which ones Name them for me please A Specifically have so inany lawyers defending me here against Mr Edwards I cant sit here at the moment cant recall it with specificity You dont remember any of your lawyers names Page A Oh,Ido Besides Mr be.,ide the Burman Critton firm and Mr Goldberger A Are you asking me for the firm sir or are you asking me for the names I want as much information as you can give me about this element of damage which you claim and that is the cost of legal services that you claim to be damages in this case A Okay MR PIKE Fonn And move to stn"ke TIIE WITNBSS Mr Roy Black BY MR SCAROLA Okay Who else A Mr Marty Weinberger Mr Alan Dershowitz Mr.1ay Lefkowitz The firm ofBunnan Critton Luttier Thats it for the moment How much have you paid the law finn ofBunnan Critton and Luttier which you claim is damages A Hundreds ofthousands of dollars sir Howmucb A I dont have that figure offhand Can you give us any better figure than hundreds of thousands of dollars A No not sitting here today Pages to PROSE COURT REPORTING AGENCY INC Page Are you paying them on an hourly basis A Yes sir What is the howiy rate at which you are compen.,ating members of the law finn A Theyre ordinary rates What are they A I dont know How much have you paid Mr Goldberger A Im not aware total amount sir What is the hourly rate at which youre paying Mt Ooldbergel A His nonnal hourly rate How much is that A I dont know How much have you paid Mr Black which you claim as damages in this case A Hundreds of thousands of dollars Are you paying him on an hourly basis A I believe so What is the hourly rate A Im not do not know sir How much have you paid Marty Weinberger A I dont know the exact amowrt sir Whats your best estimate A More than a hwtdred thousand dollars Page Are you paying him on an hourly basis A I believe so Whats the howiy rate A I dont know sir How much have you paid Alan Dershowitz A Hundreds of thousands of dollars Are you paying him on an hom basis A I believe so At what hourly rate A I dont know sir How much are you paying Jay how much have you paid Jay Lefkowitz A Im not sure sir Do you have any idea at all A More than a hundred thousand dollars Are you paying him on an hourly basis A Yes sir Whats the hourly rate A I dont know What ls the form of payment to your lawyers How do you transfer money to them A I dont know sir MR PIKE Form BY MR SCAROLA Pardon me Page A I dont know Does someone do that on your behalf A I would guess so Who A I dont know MR PIKE Fonn BY MR SCAROLA Who are the people who are authom.ed to malce payment on your behalf7 A With respect to that question rm going to have to assert the Fifth Sixth and 14th Amendment sir Are there any other elements of damage apart from the money paid to lawyers A Yes,sir What A The stress and emotional damage of imperiling my fiiendships and business relationships with no relevance whatsoever to these cases brought by a finn that whose partner sits in a Federal prison who engaged in discovery to harass my mends and social contacts with no consideration or relevance to this case whatsoever in an attempt to simply fleece partly fleece investors in South Florida out ofmilons of dollars sir What is the value of those losses Page MR PIKE Fonn THE WITNESS rm not sure yet sir BY MR SCAROLA Do you have any idea at all A Not sitting here today More or less than MR PIKE Fonn nm WITNESS I would guess its more than sir BY MR SCAROLA More or Jess than a hundred A I would guess its quite an amoum of money Is it more or less than a hundred A Yes sir More or less than a thousand A I would say ifs more than More or less than a million A I dont know sir So somewhere between and a million A No sir Its not MR PIKE Form Mischaracterizes the witness testimony nm WlINESS No sir Thats not what I said I said I did not know BY MR SCAROLA Pages to PROSE COURT REPORTING AGENCY INC Page Maybe more than a mJllion I A Maybe More or less than a billion MR PIKE Form nm WITNESS I dont know BY MR SCAROLA Maybe more than a biUion A Maybe more How are you going to go about fmding out what the value of that loss is MR PIKE Attorney/client work product To the extent you can answer without disclosing our conversations or the conversations with your other attorneys that youve delineated you can do so BY MR SCAR.OLA Or you can just take the signal and say I refuse to answer because its attorney/client privilege A I re3ellt that MR PIKE Move to strike THE WITNESS But its okay You can continue to try to harass me sir It doesnt work The ladies and gentlemen of the jury hopefully when they see the deposition will recognize and see these pile of tricks The answer MR SCAROLA Hopefully they will THE WITNESS Yes MR PIKE Move to strike Page THE WITNESS I will respectfully decline to angwer that BY MR SCAROLA On what basis A Attorney/client privilege MR PIKE And work product BY MR SCAROLA Any other elements of damage A Not there might be but sitting here today I cant think of them Do you have written contracts with any of your lawyers A Idontknow Whodoes A I dont know MR SCAROLA Lets take a short break We may be finished VlDEOORAPHER We are now off the record at Brief recess VJDEOGRAPHER We are bacJc on video record at p.m Page BY MR SCAROLA Do you attribute alJ of the damages that you have described to Mr Edwards conduct MR PIKE Fonn lHE WI1NESS As a participant I dont lmow how to proportion the conduct as op to Mr Edwards and his partner who sits in jail I guess the U.S Attorney will also make a decision to how much the conduct and proportion is relevant to both damages and anything else hes done in this case sir BY MR SCAROLA But rm not asking you about what the U.S Attorneys opinion is I want to know whether you bold Mr E.dwards responsible for all of those elements of damage that YOU have described to us A Its a difficult question to answer Mr Scarola No Its easy Yes no or I dont know MR PIKE Mr Scarola you know as well as I do the witness is attempting to answer your question MR SCAROLA I dont think so I think hes attempting to evade all of my questions Page MR PIKE And I understand your contention However If you would allow Mr Epstein to finish his response nm WITNESS Could you repeat your question BY MR SCAROLA Do you hold Mr Edwards responsible for all of the damages that you have descnbed MR PIKE Fonn THE WITNESS Ifs difficult for me to proportion the damages that I have descnoed between Mr Edwards his partner who is currently in jBJl bis the other people named in the Complaint Hopefully a jury will do thal BY MR SCAROLA Do you hold L.M responsible for all of the damages you have described MR PIKE Form nm WITNESS Again these questions these ambiguous questions as opposed to who participated I would let Mr Edwards and his clients and his pastners decide whose proportionate responsibility it is sir BY MR SCAROLA So you defer to them MR PIKE Fonn Pages to PROSE COURT REPORTING AGENCY INC Page Page THE Wl As proportionate to the 8Dl0Wlt contention on the record of damages I think Mr Edwards played a vital Okay role I believe his partners potentially played a CROSS EXAMINATION role rve only had any contact with Mr Edwards BY MR.EDWARDS sir Mr Epstein ls your sole basts for your claim BY MR SCAROLA against L.M that she changed her testimony from the Which partners time she testified to the FBI in A Beg your pardon MR PIKE Fonn To the extent you can answer Which partners besides Mr Edwards and that question without invading attorney/client Mr Rothstein do you claim engaged in conduct that work product you can do so rende,s them liable to you 1llE WITNESS Unfortunately rd Hice to A I believe its in the Complaint sir And I answer that question but I cant do so without believe its Mr Adler Mr Berger Theres Mr Jenne invading attorney/client privilege Mr Fisten but those are not partneJs BY MR EDWARDS So Mr Berger Mr Adler and I forgot the Is there anything in L.M.s Complaint that was names of the others at the moment sir but its in the filed against you in September which you contend Complaint to be false Why didnt you sue them MR PIKE Asked and answered MR PIKE Fonn THE WilNESS I recognize Mr Edwards again TIIB WITNESS Attorney/client privilege sir the concept of attempting me to get to waive my MR PIKE Work product Fifth Amendment privilege however in this lawsuit MR SCAROLA I have no further questions Ive answered quewons with respect to your MR EDWARDS I have three or four questions lawsuit And with regard to the question you just Thats it asked Im going to have to unfortunately wert MR PIKE Okay ljust want to be clear for my Fifth Amendment Sixth Amendment and 14th Page Page the record Mr Scarola represents Mr Edwards in Amendment Right thJs case is that coJTeCt Mr Scarola But Im willing to listen to any other MR EDWARDS Thats eotrect questions you may have MR SCAROLA Yes MR EDWARDS Finished Mil PIKE And in this particular case MR PIKE I have a couple questions Epstein versus Rothstein et al Mr Edwards who CROSS BXAMINATION do you specifically represent BYMR.PIKE MR EDWARDS L.M Mr Epstein earlier in the deposition MR PJKE Okay I believe that if you follow Mr Scarola was reading from page of the Complaint through with questioning you have an filed in the Epstein versus Rothstein Rosenfeldt and irreconcilable conflict with regard to the other Adler et al Do you recall that case in which you represent L.M and L.M A Yes sir I cannot stop you from asking any questions And then I showed you page of a Complaint however If you do move f01W8rd with asking that I had my notes on COJTect questions I will take the appropriate action A Yes MR SCAROLA And on behalf on behalfofmy Did you read the black type or did you read client the handwritten notes in the comers of the Complaint MR PIKE Yes sir that particular page that I showed you MR SCAROLA we do not accept your A Unfortunately my eyesight is not good enough assessment of Mr Edwards ethical to read the notes I only read the black letter responsibilities And it was that one sentence correct MR PIKE That is absolutely fine for you to A It was two sentences I believe but yes do that I just wanted to put it on the record MR PIKE Thank you that I am by no means going to prevent you from Well read questioning today However wanted to put my REDIRECT EXAMINATION Pages to PROSE COORT REPORTING AGENCY INC Page BY MR SCAROLA What is your eyesight A Sorry What is your eyesight A My eyesight Yes sir You said that your eyesight was not good enough to be able to read the handwritten notations What is your eyesight A Are we on the record or off Were on the record MR PIKE Were on the record THE WllNESS I need glasses BY MR SCAROLA And you had those on when you were reading the Complaint didnt you A But these arent my sir What are they A I dont know Lets hand them over if you would Lets take a look at them A Sure Do you see anything No Is it your contention that those glasses were inadequate to enable you to read the handwritten Page notations on the Complaint MR PIKE Form Mischaracterizes testimony THE WITNESS My testimony was I only read the black letter and partially because I cannot see thoroughly through these glasses sir BY MR SCAROLA Is It your contention that those glasses did not sufficiently correct your vision to be able to read the handwritten notations on the papers that were handed to you MR PIKE Fonn TI-IE WITNESS Again we can play this game back and forth What I just said and I think I was very clear that I did not read the notes I said BY MR SCAROLA What you said was you couldnt read the notes MR PIKE Allow the witness to finish nm WITNESS Let me finish And what I said was with these glasses it would be aJmost impossible for me to read the notes on the page BY MR SCAROLA Yes sir So your contention is that those glasses do not adequately correct your vision to be able Page to read the handwritten notations is that correct MR PIKE Fonn nIE In this particular instance sir these glasses did not rm not saying they cannot but did not allow me to read the notes thats correct MR SCAROLA I would like those glasses marked as an Exhibit to this deposition MR PIKE I dont think so MR SCAROLA Youre refusing to allow that to happen MR PIKE I dont see how you can mark a set of glasses as an Exhibit to a deposition The witness has already said that he did not read the handwritten notes in the comer or the comers of page of the Complaint MR SCAROLA The witness is a liar The witness testimony is totally incredible The witness made up a response and I want to be able to demonstrate to the Court and jury that the witness lied when he said that those glasses did not correct his vision sufficiently to be able to read the handwritten notes I want the glasses marked as an Exhibit If you refuse to mark them I am placing you Page on notice that they are relevant and material to issues involved in this lawsuit and need to be preserved MR PIKE All right Well mark the glasses Well mark the glasses as an Exhibit Okay And I will keep them here in my office MR SCAROLA Thank you MR PIKE Thats fine VIDEOGRAPHER This concludes todays videotaped deposition of Jeffrey Epstein The time is Exhibit nwnber was marked for identification purposes and retained by Cowisel for Plaintiff Witness excused Deposition was concluded Pages to PROSE COURT REPORTING AGENCY INC __ __ __ aftft 1l Z3 2S CERTIFICATE OF OATH STA TE OF FLORIDA COUN"IY OF PALM BEACH Page I the undersigned authority certify that JEFFREY EPSTEIN personally appeared before me and was duly sworn on the 17th day of March Dated this 26th day of March Sandra TOWMend Court Notaiy Public State of Florida My Commission Expires My Commission No DD Job CBRTIFICATB STATE OP fl.ORIDA COUNTY OF PALM BBAOt I Sandra TOWIISCDd Court Reporta and Notary Public ill and for the Slalo of Plorida al Large do bcnby certify that the aforemcnticml wimea WU by me fitst duly testify be Mole IJutli that I WU autborizcd to and dJd report said dq,osilion In llaiotype and bat tho foregaina pages numbered lo inclusive IR a NO and comet tnnac:rip!ion of rey lonhand notes of said dq,osilion filnber c:enily bat saiddq,osldon laba I the lintD mid place bcreinabow el fo,tl and Iba lbe taking of said dq,osition was COIClloed 1d compled bt.reinabove sei oar I llu1her conify Iha I am DOI sttomey or CXJISd of any of the parties ll0f I a rdalive or CIP1oYee of any a11on1ey or coumd of pmty ocmneded v.ith the ldioa nor I finmlially intamed in the 1:rion The foresomB on of this lnDSl:ripl does not apply to anyrcprodoctioo oflbeume by fl6TI las ander the direct COlltrol ldloT clireclioo of the eo1ifying reporter Daled this 26th day of Marth Sandra Tawnsend Court Reporter loUtl,8 Page ll DATB Mardi TO Jl!FFRSYEPSTEIN t:lo Midiad Pilce Eaquire Sllito West Palm Bca:fi Aurida RE P.pleln VI l!dwards el al CASENO OCXMBAO Please lake notice an Wednesday the of Mardi OIi pw your deposition ia the alxmH-efen-ed maaer At tut time you did IIOI WIMl ignal!e ltisnowllfllCSSllylbat yoasia,J your deposition Please call our office al the bel JWUled number to 5llhcdulc appointment between Ille hours of a.m and p.m Manda tluvuah Friday at the office localed nemeCI you If you do nol read and sisn the deposition within a RISOlblo lime lhc oripal fflch has already been famarded IO tho ordaing enomey may be filed wifb the lerk ofthD Qnat If yoo wish to waivo your ID8ftll!Ule slgp your name in lbc blank Ill thD bollom of his letter and lCI IID it IO us Very lnlly Un Sandn TOMltelld,FPR PROSE COURT REPORTING AGENCY AullralianA SUito ISOO West Palm Beach Florida Phone I do ba-eby W8iw 1DY slg,181Ure JEPFJUjyEPSffiN I do llrnby l4iw my signature cc Via llaoscript All Oxmsd of Record Ille copy Page Page CER TI Fl CATE nIE STATE OF FLORIDA COUNlY OF PALM BEACH 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 JEFFREY EPSTEIN Job Pages to PROSE COURT REPORTING AGENCY INC Page ERRATA I RAZORBACK FUNDING LLC D3 CAPITAL CLUB LLC BFMC INVESTMENT LLC LINDA VON ALLMEN as Trustee of the VON ALLMEN DYNASTY TRUST PARTNERS LP DAVID VON ALLMEN as Trustee of the DA YID VON ALLMEN LIVING TRUST ANN VON ALLMEN as Tnistee of the ANN VON ALLMEN LIVING TRUST and DEAN Case No Amended Complaint hereby sue the Defendants SCOTI ROTHSTEIN DAVID BODEN DEBRA VILLEGAS ANDREW Case No Amended Complaint any such further relief this court deems etlttaN-t tltl-just under the circumstances Overview This action arises out of a fraudulent scheme orchestrated by Scott Rothstein who bilked investors out of hundreds of millions of dollars Mr Rothstein through the use of his law firm Rothstein Rosenfeldt Adler P.A collectively referred to herein as the Principal Conspirators and more fully described infra devised an elaborate plan to assign putative plaintiffs confidential settlements with structured payments to investors at a lump sum discounted rate In reality while some of the cases used to induce investor funding were real all of the confidential settlements were purely fabricated Indeed returns to earlier investors were not made via structured payments but instead were made with the principal obtained from later investors--a classic Ponzi scheme However the Principal Conspirators did not act alone Defendant TD BANK N.A hereinafter TD Bank a subsidiary of Toronto Dominion Bank was complicit in this scheme serving as a critical lynchpin legitimizing the Principal Conspirators plot and facilitating crucial inducements to investor action Specifically investors were duped by TD Bank employees conspiring with the Principal Conspirators to manipulate TD Banks trust account statements and deceiving investors with false senses of security predicated on written assurances that settlement funds existed and would only be released directly to them It is these bank A Ponzi scheme is generally recognized as a fraudulent investment operation that pays returns to separate investors from their own money or from monies paid by subsequent investors rather than from any actual profit earned The scheme is named after Charles Ponzi who became notorious for using the technique in early Case No Amended Complaint declarations tantamount to a guaranty which gravely impacted investor risk-evaluation analysis and unduly influenced investors to close their deals Moreover demonstrative of TD Banks participation or alternatively evidence of their gross negHgence and wanton disregard is the banks reckless disregard of numerous red flags Irrefutably TD Bank knew that Rothstein Rosendfeldt Adler P.A hereinafter RRA was moving hundreds of miUions of dollars through its TD Bank trust accounts In fact in October alone almost a half of a bilJion dollars moved in and out of RRA Fon Lauderdale based ttust accounts--more money than most bank branches would Jikely see in a decade Yet despite the massive amount of funds being moved by one client TD Bank never sought independent verification of the source of monies choosing instead to stand idly by The Ponzi scheme simply could not have gained traction without TD Banks involvement in sanctioning or otherwise willfully failing to authenticate the origin of the enonnous amounts of money coming through its doors Unfonunately this is not the only pending case which alleges a TD Bank affiliate as a complicit actor involved in a Ponzi scheme On August TD Banks parent Toronto Dominion Bank was sued for knowing assistance and/or dishonest assistance in a Ponzi scheme based upon inter alia holding over in fraudulent proceeds and transferring hundreds of miHions of dollars through the alleged perpetrators accounts See a copy of the Dynasty Furniture Manufacturing Ltd et al Toronto Dominion Bank Statement of Claim attached hereto for reference as Exhibit A Based on the allegations set forth herein Plaintiffs aver that at all materials times ro Banlc had actual knowledge of its complicit involvement in a highly-organized Ponzi scheme Case No Amended Complaint and/or was recklessly or willfully blind to its role in materially supporting the scheme TD Banks acts and/or omissions in assisting facilitating and actively participating in the Ponzi scheme renders TD Bank as a direct and proximate cause of Plaintiffs losses and therefore is liable for the damages Plaintiffs incurred Furthennore as alleged in detail infra the Principal Conspirators inner-circle of facilitators Villegas Boden Barnett Stay and Berenfeld and promoters Levin Preve Banyon Szafranski and Onyx were essential to Lhe perpetration of this systemic fraud and their actions equally as culpable Indeed Rothstein in a November interview with the Sun-Sentinel slated that karma has caught up with him but it will catch up with others too Youre in a town full of thieves and at the end of the day everyone will see leave it at that The Plaintiffs LINDA VON ALLMEN is Trustee of the VON ALLMEN DYNASTY TRUST hereinafter Dynasty Trust an irrevocable trust with its principal place of administration in Broward County Florida In or around the summer of the Dynasty Trust invested J,O,O.OO into the Ponzi scheme through Banyon Income Fund Plaintiff PARTNERS LP hereinafter Partners is a Missouri limited partnership with its principal place of business in Broward County Aorida In or around the summer of Partners invested approximately into the Ponzi scheme through Banyon Income Fund Doug Von Allmen is the general partner of Partners DAVID VON ALLMEN is Trustee of the DAVID VON ALLMEN LIVING TRUST hereinafter OVA Trust a revocable tmst with its principal place of administration in Case No Amended Complaint Saint Louis County Missouri On or about August the DV A Tmsl invested into the Ponzi scheme through Banyon Income Fund ANN VONALLMEN is Trustee of the ANN VONALLMEN LIVING TRUST hereinafter AV A Trust a revocable l:lust with itc principal place of administration in Saint Louis County Missouri On or about August the AV A Trust invested into the Ponzi scheme through Banyon Income Fund Plaintiff DEAN The Defendants Principal Conspirators Case No Amended Complaint Scott Rothstein Esq hereinafter Rothstein is an individual residing in Broward County Florida and at all times relevant hereto was one of Rothstein Rosenfeldt Adler P.A.s founders its managing partner and CEO Rothstein is the principal organizer of the Ponzi scheme Non-party RRA is a Florida professional association with its principal place of business in Broward County Florida RRA was used as the front to this elaborate Ponzi scheme serving as the purported law firm representing putative plaintiffs in connection with their pre-suit confidential settlements RRAs trust accounts were allegedly used to receive the putative defendants settlement funds and used to receive investor payments._Rothstein and RRA are collectively referred to as the Principal Conspirators The Defendants Co-Conspirators TD Bank Defendants TD Bank is a foreign national banking association registered to do business in Florida TD Bank maintains substantial contact with Florida through its multiple branches throughout the state TD Bank was the financial epicenter of the Ponzi scheme Among other things TD Bank conspired induced and facilitated the Principal Conspirators deceptive practices allowing Principal Conspirators to divert hundreds of millions of investor dollars through TD Bank accounts FRANK SPINOSA hereinafter Spinosa is an individual residing in Broward County Florida and at all times relevant hereto was a senior vice-president of operations for TD Banlc Spinosa participated in the scheme by among other things meeting with investors verifying Case No Amended Complaint account statements and providing investors with purported irrevocable lock letters securing investor funds JENNIFER Ca-se No Amended Complaint furnishing false bank account statements and wire transfers to investors for the purpose of inducing investor funrung despite having actual or constructive knowledge that the investments were a Ponzi scheme ANDREW Case No Amended Complaint USVl LLC and Banyon Income Fund who maintained an office at RRA Preve a convicted bank fraud and embezzlement felon participated in the scheme by among other things recruiting inducing and securing investor funding despite having actual or constructive knowledge that the investments were a Ponzi scheme BANYON CNCOME FUND LP hereinafter BIFl is a Delaware limited partnership which Levin and Preve operated as a putative investment entity to purchase the Ponzi scheme settlements with investor funds BANYON USVI LLC hereinafter Banyon USVI is a Delaware limited liability company which Levin and Preve operated as a putative investment entity to purchase the Ponzi scheme settlements with investor funds Onyx Defendallts MICHAEL SZAFRANSKI hereinafter Szafranski is an individual residing in Miami-Dade County Florida and at all times relevant hereto was the president of Onyx Options Consultants Corporation and who maintained an office inside RRA Szafranski was hired as an independent third-party on behalf of BIF Banyon USVI Razorback and D3 tasked with verifying critical ao;pects of the purported investment deals Specifically Szafrdllski was the only person authorized to anaJyze unredacted senJement documents to confim1 the Principal Conspirators finances through TD Bank and to offer an opinion as to the authenticity of the settlement deals Szafranski participated in the scheme by among other things making material misrepresentations Frank Preve plead guilty to bank embezzlement charges in and received ten lO years probation and a fine for falsifying loan documents in connection with a scheme that resulted in losses exceeding Page Case No Amended Complaint false verifications and actively inducing investor funding despite having actual or constructive knowledge that the investment were a Ponzi scheme ONYX OPTIONS CONSULTANTS CORPORATION d/b/a ONYX CAPITAL MANAGEMENT hereinafter Onyx is a Florida limited liability company which Szafranski owns and operaLes as a third-party verifier and putative investment entity employed to facilitate and induce investor funding into the Ponzi scheme CPA Defelldant BERENFELD SPRITZER SHECHTER SHEER CPA LLP hereinafter Berenfeld is a Florida limited liability partnership who at all times relevant hereto served as the auditing firm for BIF and Banyon USVI and as the accounting finn for RRA Berenfeld participated in the scheme by among other things conspiring inducing and facilitating the Principal Conspirators deceptive practices by providing audited financial statements which purported to authenticate hundreds of millions of dollars of false receivables allowing Principal Conspirators to perpetrate a fraud Page The Ponzi Scheme The Rothstein Facade Case No Amended Complaint From humble beginnings in Rothstein built RRA into one of the fastest growing Aorida-based law firms Under Rothsteins stewardship RRA grew from seven attorneys to over seventy and amassed over two hundred and fifty in staff Along with its dramatic growth in size RRA rapidly emerged as a legal political and philanthropic powerhouse Not surprisingly Rothstein amassed an enonnous portfolio of assets including more than sixteen real estate properties twenty-five cars an eighty-seven foot yacht and various interests in a myriad of businesses ranging from watches to restaurants to vodka See a list of Rothsteins assets seized by the federal government along wilh estimates of their value attached hereto as Exhibit A-t Rothstein lived lavishly and spent prolifically--critical components necessary to set his scheme in motion With RRAs tireless marketing efforts and meteoric rise into prominence Rothstein quickly made forays into preeminent social circles rubbing elbows with high net worth individuals and political luminaries the perfect breeding grounds to lure wealthy investors His plot was up and running The Plan Rothstein seized upon his new found stature to entice investors into what would eventually become a Ponzi scheme using his budding employment and labor practice at RRA as his conduit Page A A 4A E0 A4 DE a qr?q rq qrCX HhL Kg lg d?a d6U a M3 flW y??S m/y t0 I F/Z V/j 1a qC KS u?v vZ O5 a qr rCX qC 0V I I dc rM?M rM 10Cy n??m?n k?o?h I A I w?!ac qr MCX 10Cy ITy qr M3 Ґ??1rA5R h?H?T3P K?z X?K I v"x i X5 EO5 5a r?q CX 9r Cy rq rqC M3 ş?:c p/p0 5H V)V 6T Y2 G5 qrM?r?qr?r9 q?10Cy 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