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UF UFAGA UA UA UAL UL UL UL UL UL UL U7 U7 U7 U7 U7 U7 U7 2EH GTU U/U OUoU UV G1 CTX TUV 1G 7A UA UAL X7 U7 U7 U77XL UL UL ULLYX KTX 8Y GJ A UMAT UD 7M GVW GF10 MWA LL MPM M?M 4M XY qr qr qr NEeD 10Cy qYY E2 GH l1 Pd h3V g?KIq V5kL O65S d_xKKU vV 5H p1 Z6 CTX U0 U1 CTX U0 U1 A0 1D qr qr 10Cy YY K??Kl 1B AMwv 1K F1 KV yW Gd T?H CTX CTX I CK M?qr K?SK?PQZ I IRZX 8YCX 10Cy qr CX kv zg S5kB??a iG wA CTX U2 6Y CTX U2 6Y I K,,j j,s 6Y P!p qr 10Cy qr YY G?O 9K mSd X0 9r?yal 1d bY0 XNf??qN D?J CTX P!Z b!o C,C qrM 10Cy qr8 I fX2 9R lO KV CTX Oo CTX A qr r?qr rq YY Lsy7H4 C,6E IL CTX U3 CTX J,O3_3xx qrM?r q?CX Y9/C 9CX CTX Y10Cy CX CX CX YC YY FV uTl bEWa ȓjJ-8 Gc G??Q9E 9Wq CTX CTX Up i I A 9_ qr qr YY D.X 7s F??Y bc3_c iH CTX CTX A qr 10Cy YY EMq 7H AY mK9Z BY A2 P6L N7 CTX CTX a I I i qr rC CTX CTX 7O I FMM qr qr i I I3 CTX Z6 I L(K4 P:u Z6P CTX y8 Epstein Rothstein et al WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via electronic service through the e-file portal to all parties on the attached service list this October Isl Tonja Haddad Coleman Tonja Haddad Coleman Esq Florida Bar No Tonja Haddad PA SE th Street Suite Fort Lauderdale Florida facsimile Attorneys for Epstein SERVICE LIST CASE NO Jack Scarola Esq jsx searcylaw.com mep searcylaw.com Searcy Denney Scarola et al Palm Beach Lakes Blvd West Palm Beach FL Jack Goldberger Esq jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss PA Australian Ave South Suite West Palm Beach FL Marc Nurik Esq I East Broward Blvd Suite Fort Lauderdale FL Bradley Edwards Esq brad pathtojustice.com Fanner Jaffe Weissing Edwards Fistos Lehrman Andrews Avenue Suite Fort Lauderdale Florida Fred Haddad Esq Dee FredHaddadLaw.com Financial Plaza Suite Fort Lauderdale FL Chester Brewer Jr Esq wcblawra;aol com wcbcg aol.com Chester Brewer Jr P.A One Clearlake Centre Suite Australian Avenue South West Palm Beach FL cont Epstein Rothstein et al Tonja Haddad Coleman Esquire Tonja tonjahaddad.com efiling tonjahaddad.com Law Offices of Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Attorneys for Jeffrey Epstein Epstein Rothstein et al EPSTEIN ROTHSTEIN Plea Agreement between United States of America and Scott Rothstein Privilege Log of Framer Jaffe Weissing Edwards Fistos Lehrman Dated February I Privilege Log Filed by Bradley Edwards as to Communications between Edwards and Conchita Sarnoff Electronic Communications between Edwards and Various Members of the Press LM Jeffrey Epstein Marra/Johnson Order in Jane Doe No Epstein Dated November Electronic Communications from Cara Holmes to Bradley Edwards dated July Deposition Transcript of Scott Rothstein dated December Affidavit of Jeffrey Epstein in Support of his Motion for Summary Judgment JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendant IN THE CIRCUIT COURT OF TIIB FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO AG FOURTH AMENDED COUNTERCLAIM Bradley Edwards EDWARDS sues Jeffrey Epstein EPSTEIN and alleges COUNT I-ABUSE OF PROCESS This is an action for damages in an amount in excess of the miniml jurisdictional limits of this Court Counter/plaintiff EDWARDS is sui juris resides in Broward County Florida and is an attorney licensed to practice in the State of Florida at all times material hereto Counter/defendant EPSTEIN is suijuris and is a resident of Palm Beach County Florida EPSTEIN is a convicted felon having entered into a plea agreement pursuant to which he effectively conceded his having engaged in illicit sexual activity with a large number of female children over an extended period of time in violation of both State and Federal criminal laws EXHIBIT A Edwards adv Epstein Case No Fourth Amended Counterclaim Page ofl3 EPSTEIN was sued civilly by a large nwnber of his victims Many of the cases against him have been settled and upon information and belief federal law enforcement agencies continue to investigate additional allegations of EPSTEINS serial abuse and molestation of children others remain pending As a consequence EPSTEIN continues to face the potential of further criminal prosecution and huge civil judgments for both compensatory and punitive damages in favor of many victims of his depraved criminal exploitation of children including victims represented by EDWARDS In the face of overwhelming evidence of his guilt EPSTEIN repeatedly asserted his Fifth Amendment Right against self incrimination and refused to answer any substantive questions regarding his sexual exploitation of his minor victims Lacking any substantive defense to the claims against him EPSTEIN sought to avoid his compensatory and punitive liability and to deter cooperation in the ongoing criminal investigation by employing the extr ordinary financial resources at his disposal to intimidate his victims and their legal counsel into abandoning their legitimate claims or resolving those claims for substantially less than their just value In some circumstances EPSTEINs tactics have proven successful while other victims have thus far withstood this continued assault upon them and persisted in the prosecution of their claims EDWARDS clients are among those who continued the prosecution of their claims and the assertion of federal statutory rights afforded to them pursuant to the Federal Crime Victims Rights Act CVRA Edwards adv Epstein Case No Fourth Amended Counterclaim Page of While prosecuting the legitimate claims on behalf of his clients EDWARDS has not engaged in any unethical illegal or improper conduct nor has EDWARDS taken any action inconsistent with the duty he has to vigorously represent the interests of bis clients EPSTEIN has no reasonable basis to believe otherwise and has never had any reasonable basis to believe otherwise Nevertheless EPSTEIN filed civil claims against EDWARDS and EDWARDS client L.M for the sole purpose of further attempting to intimidate EDWARDS L.M and others into abandoning or settling their legitimate claims for less than their just and reasonable value His sole purpose in both filing and prosecuting claims against EDWARDS was never the stated purpose of collecting money damages from EDWARDS since EPSIBIN knew that he had never suffered any damage as a consequence of any wrongdoing by EDWARDS Nevertheless EPSTEIN filed knowingly baseless and unsupportable claims against EDWARDS and proceeded to prosecute those baseless and unsupportable claims in order to divert EDWARDS from the prosecution of EDWARDS legitimate claims against EPSTEIN to require EDWARDS to expend time energy and resources on his own defense to embarrass EDWARDS and impugn his integrity and deter others with legitimate claims against EPSTEIN from pursuing those claims at the risk of having to fend off similar assaults EPSTEIN real purpose was to put pressure on EDWARDS L.M and other victims by publishing what amounts to nothing more than a highly defamatory press release issued under the cloak of protection of the litigation privilege EPSTEIN acted purely out of malice toward EDWARDS and others and he had ulterior motives and purposes in filing his unsupported and unsupportable claims EPSTEIN Edwards adv Epstein Case No Fourth Amended Counterclaim Page of13 primary purpose in both filing and continuing to prosecute each of the claims against EDWARDS was to inflict a maximum economic burden on EDWARDS in having to defend against the spurious claims to distract EDWARDS from the prosecution of claims against EPSTEIN arising out of EPSTEINS serial abuse of minors and ultimately to extort EDWARDS into abandoning the claims he was prosecuting against EDWARDS The claims filed by EPSTEIN against EDWARDS included the following a violation ofF.S et seq Florida Civil Remedies for Criminal Practices Act Florida RICO-"Racketeer Influenced and Corrupt Organization Act pursuant to F.S et seq abuse of process fraud conspiracy to commit fraud EPSTEIN in his Complaint directly alleged that EDWARDS was a knowing participant in a civil theft and criminal enterprise when EPSTEIN was well aware that there was and is absolutely no evidence whatsoever to support such false assertions Indeed his Complaint was replete with speculation conjecture and innuendo and was entirely devoid of factual support for his spurious allegations Indicative of his total disregard for the lack of any predicate for his claims EPSTEIN ignored the statutory requirement for written notice prior to the initiation of a civil theft claim Edwards adv Epstein Case No Fourth Amended Counterclaim Page of EPSTEIN knew at the time of the filing of the specified claims and throughout his failed prosecution of those claims that he could not prosecute the claims to a successful conclusion because a they were both false and unsupported by any reasonable belief or suspicion that they were true he had suffered no legally cognizable injury proximately caused by the falsely alleged wrongdoing on the part ofEDW ARDS he had no intention of waiving his Fifth Amendment privilege against self incrimination in order to provide the relevant and material discovery that would be necessary in the course of prosecuting the claims even if they had any reasonable basis and he knew that his prosecution would consequently be barred by the sword-shield doctrine EDWARDS conduct in the prosecution of claims against EPSTEIN could not support the prosecution of a separate civil lawsuit against EDWARDS because of the absolute protection of the litigation privilege EPSTEIN acted purely out of malice toward EDWARDS and others and he had ulterior motives and purposes in filing his unsupported and unsupportable claims as previously detailed in Paragraph EPSTEINS filing and prosecution of claims against EDWARDS recklessly and purposely disregarded the lack of justification for each of the claims and EPSTEIN never had as Edwards adv Epstein Case No Fourth Amended Counterclaim Page of13 his primary purpose to establish what he did consider or reasonably could have considered to be meritorious claims Each and every pleading filed by and on behalf of EPSTEW in his prosecution of every claim against EDWARDS every motion every request for production every subpoena issued and every deposition taken as detailed on the docket sheet was intended with respect to EDWARDS solely and exclusively to advance EPSTEINS efforts at extortion as previously detailed and constituted a perversion of process after its initial service As a result of EPSTEIN wrongful conduct as alleged EDWARDS has suffered and will continue to suffer the following special damages a injury to his reputation mental anguish embarrassment and anxiety fear of physical injury to himself and members of his family the loss of the value of his time required to be diverted from his professional responsibilities the cost of defending against EPSTEINs spurious and baseless claims WHEREFORE EDWARDS demands judgment against EPSTEIN for compensatory damages costs and such other and further relief as the Court may deem appropriate under the circumstances Counter/plaintiff EDWARDS having satisfied the statutory prerequisites for the assertion of a claim for punitive damages and having been granted leave of Court to assert such a claim does hereby also assert a claim for punitive damages Counter/plaintiff EDWARDS further demands trial by jury Edwards adv Epstein Case No Fourth Amended Counterclaim Page of COUNT II-MALICIOUS PROSECUTION This is an action for damages in an amount in excess of the minimum jurisdictional limits of this Court Counter/plaintiff EDWARDS is sui juris resides in Broward County Florida and is an attorney licensed to practice in the State of Florida at all times material hereto Counter/defendant EPSTEIN is sui juris and is a resident of Palm Beach County Florida EPSTEIN is a convicted felon having entered into a plea agreement pursuant to which he effectively conceded his having engaged in illicit sexual activity with a large number of female children over an extended period of time in violation of both State and Federal criminal laws EPSTEIN was sued civilly by a large number of his victims Many of the cases against him have been settled and upon information and belief federal law enforcement agencies continue to investigate additional allegations of EPSTEINS serial abuse and molestation of children others remain pending As a consequence EPSTEIN continues to face the potential of further criminal prosecution and huge civil judgments for both compensatory and punitive damages in favor of many victims of his depraved criminal exploitation of children including victims represented by EDWARDS In the face of overwhelming evidence of his guilt EPSTEIN repeatedly asserted his Fifth Amendment Right against self-incrimination and refused to answer any substantive Edwards adv Epstein Case No Fourth Amended Counterclaim Page of questions regarding his sexual exploitation of his minor victims Lacl lng any substantive defense to the claims against him EPSTEIN sought to avoid his compensatory and punitive liability and to deter cooperation in the ongoing criminal investigation by employing the extraordinary financial resources at his disposal to intimidate his victims and their legal counsel into abandoning their legitimate claims or resolving those claims for substantially less than their just value While prosecuting the legitimate claims on behalf of his clients EDWARDS has not engaged in any unethical illegal or improper conduct nor has EDWARDS taken any action inconsistent with the duty he has to vigorously represent the interests of bis clients EPSTEIN has no reasonable basis to believe otherwise and has never had any reasonable basis to believe otherwise Nevertheless EPSTEIN filed civil claims against EDWARDS and EDWARDS client L.M for the sole purpose of further attempting to intimidate EDWARDS L.M and others into abandoning or settling their legitimate claims for less than their just and reasonable value His sole purpose in filing claims against EDWARDS was never the stated purpose of collecting money damages from EDWARDS since EPSTEIN knew that he had never suffered any damage as a consequence of any wrongdoing by EDWARDS Nevertheless EPSTEIN filed knowingly baseless and unsupportable claims against EDWARDS and proceeded to prosecute those baseless and unsupportable claims in order to divert EDWARDS from the prosecution of EDWARDS legitimate claims against EPSTEIN to require EDWARDS to expend time energy and resources on his own defense to embarrass EDWARDS and impugn his integrity and deter Edwards adv Epstein Case No Fourth Amended Counterclaim Page of others with legitimate claims against EPSTEIN from pursuing those claims at the risk of having to fend off similar assaults EPSTEINs real purpose was to put pressure on EDWARDS L.M and other victims by publishing what amounts to nothing more than a highly defamatory press release issued under the cloak of protection of the litigation privilege EPSTEIN acted purely out of malice toward EDWARDS and others and he had ulterior motives and purposes in filing his unsupported and unsupportable claims EPSTEINS primary purpose in filing each of the claims against EDWARDS was to inflict a maximwn economic burden on EDWARDS in having to defend against the spurious claims to distract EDWARDS from the prosecution of claims against EPSTEIN arising out of EPSTEINS serial abuse of minors and ultimately to extort EDWARDS into abandoning the claims he was prosecuting against EDWARDS The claims filed by EPSTEIN against EDWARDS were the following a violation ofF.S et seq Florida Civil Remedies for Criminal Practices Act Florida RJCO-"Racketeer Influenced and Corrupt Organization Act pursuant to F.S et seq abuse of process fraud conspiracy to commit fraud EPSIBIN in his Complaint directly alleged that EDWARDS was a knowing participant in a civil theft and criminal enterprise and that he had conspired to and did engage in Edwards adv Epstein Case No Fowth Amended Counterclaim Page of a fraud against EPSTEIN when EPSTEIN was well aware that there was and is absolutely no evidence whatsoever to support such false assertions Indeed his Complaint was replete with speculation conjecture and innuendo and was entirely devoid of factual support for his spurious allegations Indicative of his total disregard for the lack of any predicate for his claims EPSTEIN ignored the statutory requirement for written notice prior to the initiation of a civil theft claim EPSTEIN knew at the time of the filing of the specified claims and throughout his failed prosecution of those claims that he could not prosecute the claims to a successful conclusion because a they were both false and unsupported by any reasonable belief or suspicion that they were true he had suffered no legally cognizable injury proximately caused by the falsely alleged wrongdoing on the part of EDWARDS he had no intention of waiving his Fifth Amendment privilege against self incrimination in order to provide the relevant and material discovery that would be necessary in the course of prosecuting the claims even if they had any reasonable basis and he knew that his prosecution would consequently be barred by the sword-shield doctrine EDWARDS conduct in the prosecution of claims against EPSTEIN could not support the prosecution of a separate civil lawsuit against EDWARDS because of the absolute protection of the litigation privilege Edwards adv Epstein Case No Fourth Amended Counterclaim Page ofl3 EPSTEIN acted purely out of malice toward EDWARDS and others and he had ulterior motives and purposes in filing his unsupported and unsupportable claims as previously detailed in Paragraph EPSTEINS filing and prosecution of claims against EDWARDS recklessly and pmposely disregarded the lack of justification for each of the claims and EPSTEIN never had as his primary purpose to establish what he did consider or reasonably could have considered to be meritorious claims After unsuccessful efforts to defend and amend his maliciously filed and prosecuted claims over a period of almost two years EPSTEIN abandoned each of the claims described in Paragraph except for an ongoing effort to salvage his abuse of process claim That abandonment brings to successful conclusion EDWARDS defense against each of the other abandoned claims and constitutes a specific bona fide termination in EDWARDS favor of the prior prosecution of each abandoned claim As a result of EPSTEINs wrongful conduct as alleged EDWARDS has suffered and will continue to suffer the following special damages a injury to his reputation mental anguish embarrassment and anxiety fear of physical injury to himself and members of his family the loss of the value of his time required to be diverted from his professional responsibilities the cost of defending against EPSTEINs spurious and baseless claims Edwards adv Epstein Case No Fourth Amended Counterclaim Page of WHEREFORE EDWARDS demands judgment against EPSTEIN for compensatory damages costs and such other and further relief as the Court may deem appropriate under the circumstances Counter/plaintiff EDWARDS having satisfied the statutory prerequisites for the assertion of a claim for punitive damages and having been granted leave of Court to assert such a claim does hereby also assert a claim for punitive damages Counter/plaintiff EDWARDS further demands trial by jury I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached Jis this qf day of rZ:LJ JACK-SC OLA Flortcla ar No E-mail jsx searcylaw.com ondary E-mail mep searcylaw.com earcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorney for Bradley Edwards Edwards adv Epstein Case No Fourth Amended Counterclaim Page of COUNSEL LIST Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian A venue South Suite West Pahn Beach FL Phone Fax Attorneys for Jeffrey Epstein Bradley Edwards Esquire bj e.efile pathtojustice.com staff.efile pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehhnan FL North Andrews A venue Suite Fort Lauderdale FL Phone Fax Fred Haddad Esquire Dee FredHaddadLaw.com haddadfm aol.com Fred Haddad P.A One Financial Plaza Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com Law Offices of Marc Nurik One Broward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein Lilly Ann Sanchez Esquire lsanchez thelsfinn.com The L-S Law Finn Brickell Avenue 15th Floor Miami FL Phone Fax Attorneys for Jeffrey Epstein Tonja Haddad Coleman Esquire tonja tonjahaddad.com Debbie Tonjahaddad.com Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein JEFFREY EPSTEIN Plaintiff SCOTT ROTHSTEIN individually and BRADLEY I EDWARDS indiYidually Dcf i:ndants IN THE CIRCUIT COURT OF THE flFTEENTII JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEINS ANSWER AND AFFIRMATIVE DEFENSES TO DEFENDANT/COUNTER-PLAlNTIFF BRADLEY EDWARDS COUNTERCLAIM PlaintiftJCountcr-Dcfondant Jeffrey Epstein Epstein hy and through his undersigned counsel and pursuant to Rule or the Florida Rule Ciril Procedure hereby files his nsvvcr und Aftirmati Defenses to Dcfcndant!Countt.:r-Plaintiff Bradky Edwards Edwards Counterclaim and states Epstein admits ilmt the Counterclaim alleges an ainout within the jurisdictional purYicw of the Court bul denies that Edwards is entitled to said amount Epstein is without knowkdge as to Edwards residential status but ndmits that he is an attorney licensed to practice law in the State of Florida Epstein Denies that he is a resident of Palm Beach County but admits the remaining allegations in Paragraph Epstein admits that he entered into a plea agreement that resulted in a frlony conviction Epstein further admits that the tcnns and conditions of the agreement speak for themselves To the extent that Edwards has inaccurately summarized or interpreted any provision thereof in Paragraph of his Counterclaim Epstein denies the allegations EXHIBITB Epstein admits that he Vas a party to civil actions brought forth by purported 267ictims and that civil actions to which Epstein was a party settled but is without knowle lge as to any further investigation by federal law enforcement any pending civil cases against Epstein by any purported victims and Edvlards relationship with any other purported victims and therefore denies these allegations and demands strict proof thereof Epstein admits that at certain times in the litigation he asserted his rights against self-incrimination as afforded to him by the Fifth Amendment to the United States Constitution Epstein denies the remaining allegations contained in Paragraph and demands strict proof thereof Epstein denies Paragraph except for the allegation therein stating that Edwards 1s involved in pending litigalion in federal Court under the federal Crime Victims Righls Act Epstein denies each and every allegation contained in Paragrapgh and demands strict proof thereof Epstein denies each and every allegation contained in Paragrapgh and demands strict proof thereof Epstein denies each and every allegation contained in Paragrapgh and demands strict proof thereof Epstein admits that the causes of action asserted by him against Edwards in Epsteins initial Complaint arc listed in Paragraph and its subparts However Edwards fails to either attach the Complaint to which he is referring or otherwise identify the Complaint from which he derives his assertion To the extent that Edwards has inaccurately summarized or interpreted any provision thereof in Paragraph of his Counterclaim Epstein denies the allegations Epstein admits that in his initial Complaint he asserted causes of m:tion against Ethvards as specifically stated in Paragraph and its subparts but denies that he has ever asserted a cause of action for Civil Theft against Edwards as alleged in Paragraph To the extent that Edwards has inaccurately summarized or interpreted any provision of Epstein Complaint in Paragraph of his Counterclaim Epstein denies the allegations Epstein further denies the remaining allegations contained in Paragraph and demands strict proor Lhereof Fpstcin denies each and every allegation contained in Paragrnpgh including its subparts and demands strict proof thereof Epstein denies each am.I every allegation contained in arngrnpgh and demands strict proof thcrcor Epstein denies each and every allegation contained in Paragrapgh and demands strict proof thereof Epstein denies each and every allegation contained in Paragrapgh and demands strict proof thereof Epstein denies each and every allegation and claim for damages lhat is contained in Paragraph including its subparts and demands strict proof thereof Epstein admits that the Counterclaim alleges an amout within the jurisdictional purview of the Court but denies that Edwards is entitled to said amount Edwards fails to attach a copy of Epsteins Complaint or even reference the version of the Complaint to which he reters in this allegation Epstein is without knowledge as to Edwards residential status but admits that he is an attorney licensed to practice law in the State of Florida Epstein Denies that he is a resident of Palm Beach County but admits the remaining allegations in Paragraph Epstein admits that he entered into a plea agreement that resulted in a felony co1ffiction Epstein further admits that the terms and conditions of the agreement speak for thcmsdvcs To the extent that Edwunls has inaccurately summarized or interpreted any provision thereof in Paragraph of his Counterclaim Epstein denies the allegations Epstein admits that he was a party to civil actions brought forth by purported victims and that civil actions to which Epstein was a party selcd but is without knowledge as to any further investigation by federal law enforcement any pending civil cases against Epstein hy any purported victims and Ed,vards relationship with any other purported victim and therefore denies these alkgations and demands slrict proof thereof Epstein admits that at certain times in the litigation he asserted his rights against sdf 267incrimination as afforded to him by the Fifth Amendment to the United States Constitution Epstein denies the remaining allegations contained in Paragraph and demands strict proof thereof Epstein denies each and every allegation contained in Paragrapgh and demands strict proof thereof Epstein denies each and every allegation contained in Paragrapgh and demands strict proof thereof Epestcin denies each and every allegation contained in Paragrapgh and demands strict proof thereof Epstein admits that the causes of action asserted by him against Edwards in Epsteins initial Complaint are listed in Paragraph and its subparts However Edwards fails to either attach the Complaint to which he is referring or otherwise identify the Complaint from which he derives his assertion To the extent that Ethvards has inaccurately summarized or interpreted any provision thereof in Paragraph of his Counterclairn Epstein denies the allegations Epstein admits that in his initial Complaint he asserted causes of action against Edv,,ards as specifically stated in Paragraph and its subparts but denies that Epstein has ever asserted a cause of action for Civil Thell against Edwards as alleged in Paragraph To the extent that Edwards has inaccurately summarized or interpreted any provision of Epsteins Complaint in Paragraph of his Countcrclai1n Epstein 1.knics the allegations Epstein denies the remaining allegations contained therein and demands strict proof thereof Epstein denies each and every allegation contained in Paragraph including its subparts and demands strict proof thereof Epstein denies each and every allegation contained in Paragraph and demands strict proof thereof Epstein denies each and every allegation contained in Paragraph and demands strict proof thereof Epstein admits that he has Amended his Complaint over the course of this litigation and submits that while some counts were dismissed by the Court without prejudice this constitutes neither abandonment of Epsteins claims nor a bona fide Edwards fails to either attach the Complaint to his Counterclaim or reference the specific Complaint which he is referring in Paragraph tennination thereof As such Epstein denies the remaining allegations contained in Paragraph and demands strict proof thereof Epstein denies each and every allegation and claim for damages that is contained in Paragrapgh including its subparts and demands strict proof thereof AFFIRMATIVE DEFENSES FIRST AFFIRMATIVE DEFENSE For his First Affirmative Defense Epstein states that Edwards Abuse of Process claim fails to state claim upon which relief can be granted as is required under Rule IO of the Florida Rule Civil Procedure Edwards did not nor will he ever be able to assert the three requisites required to properly plead same lo wit an ilkgaL improper or perverted use of process qfier it issues i.e improper willful acts during the course of a prior ac!ion or tf/ier the filing of lhe Complaint an ulterior motive or purpose in exercising the illegal improper or perverted process and damages resulting therefrom I Inv Payless Flea Mkt Inc So 3d Fla 4th DCJ emphasis added Della-Don11a Nova Univ Inc So 2d Fla 4th DCA SECOND AFFIRMATIVE DEFENSE For his Secon Affirmative Defense Epstein states that Edwards Malicious Prosecution claim fails to state a claim upon which rellcf can be granted as is required under Rule I of the Florida Rules Ci il Procedure Spccilically the requisite of a bone-fide termination of the original proceeding in favor of the present plaintiff as ddineatcd by the Florida Supreme Court as one of the legally-mandated clements to bring forth a Malicious Prosecution claim has not been nor can it be smisfied See Alamo rem-A-Car Mancusi So 2d Fla The original proceeding to which Edwards refers in his Counterclaim is in fact the current litigation that is pending against him to which there has not been an ending in a manner indicating lEdwards innocence of the charges or allegations contained in the first suit See Doss Bank of America NA So 2d Fla 5th DCA See also oder Adrialico So 2d Fla 5th DCA stating that the tort of malicious prosecution requires as an element the prior ter1ination of that claim and therefore malicious prosecution may not be brought as a counterclaim Indeed it is well-settled law that an action for Malicious Prosecution cannot be lilcd until the original action is concluded and that counts of a Complaint that are dismissed witlumt prejudice arc not deemed a bona fide termination in that party favor where dismissal is on technical grounds for procedural reasons or any other reason not consistent with the guilt of the accused it docs not constitute a favorable determination Union Oil of California John Walson So 2d 3d DCA Accordingly Edwards fails to state a claim upon which relief may be granted THIRD AFFIRMATIVE DEFENSE For his Third Affirmative Defense Epstein states that Edwards Counterclaim fails to properly plead his damages as required as required under the Florida Rules of Cili Procedure See Miami atimwl Bank Nunez So 2d Fla 3d DCA stating that a litigant cannot recover as damages his own time for participating in a litigation when counsel is engaged to represent him Edwards further pleads damages for injury to his reputation mental anguish anxiety and embarassmcnt which are impermissible and improperly plead Most importantly however Epstein submits that Edwards has not nor will he suffer any damages as a result of any actions allegedly taken by Epstein In fact Edwards still utilizes his litigious association with Mr Epstein at his new finn Farmer Jaffe Weissing Edwards Fistos Lehrman to disparage Epstein to seek new clients on whose behalf ht can sue Epstein to attract additional plaintit1s for whom he can tile suit and to achieve notoriety with the press Composite Exhibit A attached hereto FOURTH AFFIRMATIVE DEFENSE For his Fourth Affirmative Defense Epstein asserts that he is afforded absolute immunity pursuunl to the 225Litigation Privilege because at all times his actions were tonnccteu with rclcvanl lo and matl!rial to his cause of action against Edward The Litigation Privilege protects actions taken that arc runclionully tied to the judicial procc1 ling and 267arises immediately upon th1 doing of any act rcquirtd nr permitted hy law in the dm 1.:oursc of the judieial proceedings or is necessarily pn.:liminary thereto Fridoridt Fridovic/1 So 2d Fla Epstein has not taken nny action outside the 1.:onlex1 of the judicial proceeding su as actions ri nsic lo the liligatio11 Suchile Klepph1 WL S.D Fla citing to lm1:rinm Nat Tille Escrow Florida Inc Guarantee Title Tmst Co So 2d Fla 4th DCA See also Montejo Martin Memorial Medical Cemer Inc So 2d Fla 4th DCA Defendant specifically reserves the right herein to amend these defcnst:s and plead other affirmative defenses that may become known during his continuing investigation of this action and during discovery in this case WE HEREBY CERTIFY that a true and correct copy of the foregoing was served dl:!ctronic and US Mail to all panics on the attached service list this July I Tonja Haddad Coleman Esq Florida Bar No Tonja Haddad Pi South Andrews Avenue Suite Fort Lai1dc.rdalc Florida facsimile Attomcys for Plaintiff SERVICE LIST CASE NO Jack Scarola Esq Searcy Denney Scarola et al Palm Beach Lakes Blvd West Palm Beach FL Jack Goldberger Esq tterbury Goldberger Weiss PA Australian Ave South Suite West Palm Ilcach Marc Nurik Esq I Easr Broward Blvd Suite Fort Lauderdale f-L Bradley Edwards Esq Fanner Jaffe Wcissing Edwards Fistos Lehrman Andrews A venue Suite Fort Lauderdale Florida Lilly Ann Sanchez Esq LS Law Firm Four seasons Tower I 5th Floor Brickell A venue Miami Florida l3 Page IN THE CIRCUIT COURT Of THE FIFTEENTH JUDICIAL GIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO AG Complex Litigation FlaRCiv.Pro JfFFREY EPSTEIN Pl11intiff vs VOLUME II OF II SCOTT ROTHSTEIN individl.W.lly BRADLEY EDWARDS individuany and L.M individually Defendllnts VIDSOTAPED OEPOSITION OF BRADLEY EDWARDS F.SQUIRE l3 Tue lday March I p.m Palm Beach Lakes Boulevard West Palm Beach 1-lorida ReportwB Cynthia Hopkins RPR FPR Notary Public Stale of Florida Prose Court Reporting Job No APPEARANCES On behalf of the Plaintiff ROBERT CRITTON JR ESQUlRE BURMAN CRITTON LVITIER COLEMAN LU Banyan Boulevard Suite400 West Palm Beath orida Phone afld JACK ALAN GOLDBERGER ESQUIRE A TIERBURY GOLDBERGl!R WEISS P.A 260IAlliun v,;r,ue Sulh Sui1e West Palm ch Aorida Phone and On behalf of the Plaintiff ALAN DERSHOWITZ ESQUIRE HARV ARD LAW SCHOOL Ha.w,-er Cambridge M-husetts Phone On bel1 lf of the Defendant ACK SCAROLA ESQUIRE SEARCY DENNEY SCAROU BAANHART SHIPLEY PA Palm Beacli Lakes Boulevard West Palm Florida Phone ALSO PRESENT Jefftcy f.pstein Joseph Kauk Videognipher Prose Reporting Sei-vicc Page lB 2S INDEX START INDEX Page EXAMINATION DIRECT CROSS REDIRECT CONTINUED EXAMINATION OF BRADLEY EDWARDS ESQUIRE BY MR CRITTON EXHlBITS EXHIBlT DESCRIPTION PAGE PLAINTIFFS EX I ALFREDO RODRIGUEZ CRIMINAL COMPLAINT PLAINTIFFS EX COMPLAINT PLAINTIFFS EX JULY FACSMILE Page PROCEEDINGS THE VIDEOGRAPHER Were now on the record at I p.m Volume CONTINUED DIRECT EXAMINATION BY MR CRJTION Mr Edwards when we broke we were talking a little bit about we were talking about George Rush and different many people that you had spoken with and you said you had spoken with Mr Rush approximately five times correct A Correct With regard to Mr Rush did you ever provide him with any documents A dont believe so Did you tell Mr Rush did you EVER advise or did Mr Rush ever ask you who your clients were I mean not by name but as to how your clients factored into any of the conversations that you were having A I dont remember that Do you recall discussing with Mr Rush Ghislaine Maxwell Or in fact let me ask it this way Did you talk with Mr Rush about Ghislaine Maxwell in any way Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopklns Electronically signed by cynthla hopk:lns Electronically signed by cynthla hopklns EXHIBITC a Vϝ vKД3 nZ M?h M?A K??tT??N dm?LU x??KcA?n VLz A6 eД G?t YǢÜ N?q?r?J?U?s gL Dr_ TZ?m?/d?d??E?r v?e a ME??Y I?c Y?/H קTQ M??J GcBd 9q gQ bq ѓ?u?eT q?U Q?Si 4ór j?t z?Z??dЈԚ x?a I?V i?S H?i1K K?V b?Ԣ3 p??s?D 훞N uk K?hj 9W?jHs?9Pr ϔ??HÍe 0Y K7 S?LB?lT k?h?d:/W-VS Iz HIQ DP T??T?h mPŀ??Λ pT?I 6?Nf w?ܪd?G??T vQ Rvx b?J e?h?q?Z NNaw-f aT jU??h Nk?r fp6E v??꺒 X?Yp9 z?i?s V6 H?T?2i y??C Bk _ʿ?t i 2i A C?VR w?,H??XH0tMgHloz?Jh Ji mjK pε u9?f J?T?梇?b鉐?I X?o?N?QSK47?_n 3o K??s Gx kn6??Y xXe 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g?Fγ?Rg?Xl ۯ?OU m??C?L?I H??P L?n n?b b3 NХQ?V M8 r??PN I Page A rm not sure Why would you did any of your clients claim or have any of yQur clients claimed to have any contact with Ghislaine Maxwell at all A That is something that certainly calls for attomey--01ient privilege and not something that I am going to be answering today With regard to at least you have attended the deposition of both Jane Doe and of L.M correct Si A Yes Okay And have you heard them reference Ghislaine Maxwell during the course of those depositions A No Would it be a correct statement that none of the three of your clients lets take a look at the two that have testified Both of the two that have testified Jane Doe and L.M have testified that they did not ever take travel with or were transported in any way by Mr Epstein correct A No that is incorrect Okay Did who which A I believe I am sorry A I guess the transcript will speak for itself Page I dont remember their specific Is it your belief that Jane Doe ever traveled with Mr Epstein on his plane MR SCAROLA Excuse me is the question limited to the testimony MR CRITTON Correct MR SCAROLA that has been iven MR CRITION Correct THE WITNESS No I do not believe she testified that she traveled with Mr Epstein on his plane BY MR CRITTON All right And same would be true with L.M she did not testify that she traveled wifu Mr Epstein on his plane true A I believe thats true as well Okay Are you aware of any other infonnation from any other source that either Jane Doe or L.M traveled on Mr Epsteins plane A No Did you did you indicate to well let me strike that Did you tell Mr Rush that none of your clients had ever traveled with Mr Epstein on his plane or any on his plane or with him in any fashion in any other manner Page A I dont remember that subject coming up in the conversations with Mr Rush Had he asked I I dont remember that conversation Youre not denying it You are just saying you dont remember it or are you A Correct saying it didnt happen A No I am saying I just dont remember Did you did you tell Mr Rush that Mr Epstein had transported females on his plane for the purposes of having sex with other individuals A I dont know Well why A I just dont remember lfMr Rush would testify that you told him that other females had traveled on Mr Epsteins plane and had had sex during the time they were on the planes why would you have had that discussion with him A Youre asking a hypothetical if I said that why would have I have said that Well let me rephrase it this way With Mr Rush if I asked you to assume that he would testify that you you told him about the transportation that Mr Epstein transported other Page women on the plane to have sex with them what infonnation did you have that was the basis for that claim at that time MR SCAR.OLA I am going to object to the fonn of the question It assumes facts not in evidence It has no proper predicate BY MR CRJTTON Mr Edwards did you have Ghislaine Maxwell served in this case with a subpoena A Yes For what purpose I mean obviously to talce her deposition A Exactly to take her deposition AU right Do you is she neither would you agree that neither Jane Doe nor L.M have testified to any that they had any connection whatsoever with Ghislaine Maxwell A Yes would agree And what what was what is the purpose that is with regard to your three clients and onJy your three clients is they what connection if any did Ghislaine Maxwell have to those individuals MR SCAROLA Objection work-product Instruct vou to not answer Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthia hopkins Electronically signed by cynthla hopklns Electronically signed by cynthia hopkins ff76c2ea CcK A L?s w?.v v??ƪ W?W STN 3lz U?勁Z W??Cc j?!I?Ѓʵ 3T B?Q?E xR Ió I j?I??H 2T/gw S??S O??Y YA?G w3_Y p??b amX TUO v3?C?i QN S??r 1ݟ?za aC Q?ɏyq i?pk Ix30 yM??pQ(Q?"?w H?ɧ?R J?ē qGJe Page BY MR CRITTON When you originally started working with the Rothstein firm did you have any discussions with Mr Rothstein regarding how your cases would be funded that is your personal your personal inj w:y cases and specifically the cases relating to Mr Epstein A No Okay With regard to prior to taking your cases to prior to starting at RRA you were responsible for the funding of your personaJ injury cases or any contingency fee case correct A Right And I assume you had either your own personal funds or you had a line of credit or both A Right And when you came to RRA and you brought the cases with you that is the personal injury cases and as well the Epstein cases were you reimbursed for the costs that you had already expended thus fat on those cases A No Did you request that you be reimbursed A Yes And with to whom was the request made Page A Directly to Scott Rothstein Was that at the ten minute meeting that you had A Yes AtBOVA A Yes And what did he say A No proo1em He said he would reimburse you A Correct And did that in fact take place A No And how did you attempt to get reimbursed for the CO ts that you had thus far incurred on your personal injury cases including Ivlr Epsteins case when you went when you started at RRA A What do you mean Well you said that Ivlr Rothstein agreed in the ten minute conversation that RRA would reimburse those costs A Correct You go to RRA in April of09 and I assume you had to ask someone and say look I had a conversation with Scott Rothstein He said he would reint,urse mv costs Page A I didnt do that You didnt Did you choose not to do that A No I I the statement was made to me by Scott Rothstein that the costs would be reimbursed And I anticipated that the costs would be reimbursed I was thi:re for a fairly short period of time and I didnt know Scott Rothstein personally So I didnt go to him additionally to tell him something that we already had a meeting of the minds about Well how much in costs did you have outstanding at the time from your cases including the Epstein cases when you went to the firm RRA in April of09 A I dont know the total Was it Was it Was it A More than And did you have that both from was it the debt was that comprised of both your own money and as well as LOC line of credit money through a bank A Correct Was it more than I SO A Im not sure Page Was it someplace between and your best estimate A That is my best estimate Did you find that to be a significant amount of money A Of course Okay And you said you were at RRA for only a short period of time In fact you were there April May June July August September October You were there seven months true A Yes Okay And at no time even though Mr Rothstein said he would reimburse those funds or the finn would reimburse those funds to you at no time during those seven months which you have described as a short period of time did you ever make a request that you be reimbursed is that correct A I never made a well I dont know the process for getting reimbursed but I never made a fonnal request I said it to at least to Russe11 Adler on several occasions And it was always told to me dont worry about it the firm is growing there is a lot of things to deal with right now he operates 1mder the svstem of fairness you will get reimbursed Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopklns Electronically signed by cynthla hOpklns Electronically signed by cynthla hopkins a Page And obviously nobody expected the ending to the law firm that ultimately occurred With regard to case I assume you settled a couple of personal injuzy cases during the seven months you were there yes A Yes you assume that Thats correct Let me ask thi ti.on Did you settle any contingertcy fee cases during the sevens months that you were at the RRA finn A Yes And when you settled those cases did you and they closed they were settled through did you have any control of the trust accoWlt A No Okay Settlement monies come in on a personal injury case What did you do with the money once the once the client had endorsed the check A I didnt personally do anything with the money It was not handled by me Okay Were you there A Thats why rm confused Did I settle the case I mean Rothstein Rosenfeldt Adler firm settled personal injury cases while I was there There were no cases that were solely my cases They were finn cases Page Let me rephrase the question You brought you brought cases to the 243inn correct A That is correct Of any of the cases that you brought did you settle those cases A No Okay So you never had an instance so there never eir l-UWiiVliiWO rYh"-r you would have been reimbursed for costs as a result of a settlement ll A Thats correct All right And and so during the seven months that you were there you were never reimbursed a nickel of the one to that you had outstanding in costs A That is correct All right With regard to the costs that were to be incurred for prosecuting the cases specifically the Epstein cases what was your understanding was that ever discussed with Mr Rothstein at the ten-minute meeting A Repeat that Im sorry Sure How were how were costs investigation costs deposition costs travel exnenses to be reimbursed Page A Well youve thrown a lot of things in there Travel expen come back with your receipts hand them ver to I would hand them over to rey secretary And she would get them to the apPropriate place in the machine known as Rothstein Rosenfeldt Adler And in my next and I would get a ch believe All right How a.bout depositiQll I ro during the time that we we took depositions frQTT the time you were at RRA transcripts were ordered of depositions They were expedited of various hearings You took trips You took a trip to New York to lake the deposition of Mark Epstein correct all those things occurred A Yes all of those things occurred So when you would get a bill in for the trip for to go up and see Mark Epstein or to take Mark Epsteins deposition you had travel costs associated with that and you had plane fare taxicab hotel whatever else you had correct A I had costs associated with that All right And when you met with Mr Rothstein initially what was your understanding or did you have an understanding as to how costs would be handled that is how they would be paid on cases that you brought to th1 firm Page A It was unspoken but I had some understanding just based on logic Separate and apart from logic did anybody tell you that you had that is that RRA would pay all of the costs associated with prosecution of the Epstein cases A Did anybody tell me No oKay were you ever required to draw against either your personal funds or your personal LOC after you started with RRA to fund the Epstein cases A I dont know how to answer your question Mr Critton because ifl were to go out of town and purchase a plane ticket yeah I would purchase that personally and then I would be reimbursed If I ordered a deposition transcript which is a totally different category that gets billed to the firm I never see the bin or anything else So youre just throwing a bunch of things together that dont necessarily go together I am trying my best for you No thats fine Commonly in a personal injury closing you would see the recover you would see a list of the costs The costs would include court reporters investigation fees subpoenas things of that nature correct Pages to PROSE COURT REPORTING AGENCY INC Electronfcally signed by cyntnla hopldns Electronically signed by cynthia hopklns Electronically signed by cynthia hopkins Page A I have seen them before yes sir Okay And as well there would be reimbursable expenses such as when you went to New York and took Mark Epsteins deposition You you paid for the expense up front but in fact it was then reimbursed by the firm correct A Now were specifically specifically talking about Mark Epsteins deposition yes that what you just said is correct Okay Not only was the and ifI lo understand your testimony is the deposition was paid for directly by the finn With regard to your travel any hotel other expenses that you had you put in a request for reimbursement and the firm would reimburse you A Correct All right And with regard to those costs you said you and Mr Rothstein never had a discussion about that is that correct A Correct All right But you did speak with Mr Adler about how costs would be handled on your cases including Mr Epsteins case after you started withRRA A Correct Page Okay And is he the only one who explained what the procedure was A Yes And what did he tell you Well let me ask you thls Did he tell you what that is that the firm would pay for all of the reimbursements either costs and/or reimbursements for costs that were incurred in prosecuting the Epstein files and any other files that you had A Can you split this question up so that were not talking about reimbursement and costs and things like that Sure With regard to costs such as depositions A Okay court reporters court reporter fees video depositions transcripts ofhearing whether they were expedited or whether they were asked on a routine basis A Right Where would the who was responsible for paying those bills A The bills would to my to the best of my knowledge would be billed to the law firm of Rothstein Rosenfeldt Adler and it would be their financial Page responsibility to pay those bills And is that what Russell Adler told you A Yes Did you ever discuss that with anyone else in the firm or just Russell Adler A Just Russell Adler So if the bill came in for one of those types of costs you would give to your secretary or would she handle it automatically A I never would see the bill Why would it come into my name It just didnt do that never happened It was billed to Rothstein Rosenfeldt Adler So you would never see the bill that came in A Correct even if it was a RRA attention Brad Edwards you wouldnt see that A Preswning that happened attention Brad Edwards I still never saw it No I never saw a bill to my recollection right now the whole time I was at Rothstein Rosenfeldt Adler Did Mr Rothstein ever discuss with you whether there would be a budget associated with how much money you could spend on a particular case A No Page Okay Did anyone at the firm ever talk to you about whether or not there would be a budget associated with how much you could spend on an Epstein case or any personal injury case A No In temis of authorization if you wanted to order a deposition expedited or if you wanted to pay for a specific expense whether it was an outside investigator or to send an investigator to a location whose decision was that ls that you and you alone to incur that cost A Which question do you want me to you asked a bunch of things there that some of them may have been my decision Other parts of that would obviously be somebody elses But youre throwing five or six items in there and you want me to give you an answer Let me break it them do-.vn With regard to any costs that you wanted to incur incur relating to a Jeffrey Epstein matter was there an authorization process that is did you have to get someones okay before you could spend amount of dollars A No Okay It was and who told you that you never had to get an approval for any expense Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopk:ins Electronlcally signed by cynthia hopklns Electronlcalty signed by cynthia hopkins f6c2ea Page associated with the Jeffrey Epstein case A I didnt say that anybody did So no nobody,nobody You could just spend whatever money you wanted to in prosecuting your cases is that correct A No I didnt say that either What was the procedure then A That if I was at a deposition and there was a need in my judgment for the transcript to be expedited then I would order it expedited and nobody ever told me that they had a problem with my judgment as to those things And not as to those things As to that thing which we were talking about which right now is expediting deposition transcripts With regard to so any how about an expense associated with hiring with either directing well let me strike that With regard to Epstein did were you ever required or did you ever hire outside investigators to do work associated with the Epstein case By outside I mean someone who was not an employee of RRA and now I mean dealing with the time that you were at RRA A Right And your question is did I ever hire Page an outside investigator to perform work on Jeffrey Epsteins case Correct A The answer is no Were were all the investigations that were done during the time that you were employed by RRA were they done by in-house investigators A I dont know Well if you wanted investigation done on Mr Epstein how would you go about authorizing that or directing that that be done A I would ask one of the investigators to do it So you would direct the specific investigator A Yeah There were plenty of times where I directed the specific investigator I want you to talk to this witness or so-and-so yes just like you would in any case In this particular instance associated with Mr Epstein what investigators worked on Mr Epsteins case during the time you were at RRA A If you want an exclusive list I dont know I want to know A I can teJI you Michael Fisten did because I communicated with him directly Page Did you meet did you know Mr Fisten before you started working at RRA A Same answer no No All right And Mr Fisten did you direct Mr Fisten to do investigations in Marthas Vineyard A No Did you direct Mr Fisten to do investigations in California A I directed Mr Fis ten to interview people and ultimately it was leamed that they lived in California And did Mr Fisten go to California to interview those individuals A To the best of my knowledge he did Okay And who did he go and interview MR SCAROLA That is work-product and I instruct you not to answer BY MR CRITTON Did Mr Fisten interview a person by the name of Michael Sanka phonetic MR SCAROLA That is work-product and I instruct you not to answer MR CRITTON Did Mr Fisten interview a individual by the name of Michael Friedman phonetic Page MR SCAROLA That is work-product and I instruct you not to answer MR CRJTTON 1r Fisten MR SCAROLA except to the extent as may have already been disclosed to the defense in any of the three cases that are currently pending Any and all questions about investigative work will meet with the same objection and same instruction BY MR CRITTON Did you direct Mr Fisten that he could represent that he was an agent of the FBI in interviewing individuals in California A Of course not Did you and if in fact Mr Fisten represented he was an agent of the FBI you would find that reprehensible true A This is some hypothetical question that I do not believe exists Im asking you to assume that Mr Fisten represented that he was an agent of the FBI You would find that type of conduct by the investigator to be inappropriate correct A Im not going to render an opinion on a hypothetical that doesnt exist Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopkins Electronically signed by cynthla hopklns Electronically signed by cynthia hopklns Page So youre refusing to answer that question A Youre asking me about my definition of reprehensible as it pertains to a specific hypothetical that youve just created Let me ask you A Now you want me to try to analyze that particular hypothetical and tell you whether it meets the definition of reprehensible I will let you if Mr Fisten if I ask you to assume that Mr Fisten represented to a witness out in California that he was an agent or working for the FBI would you find that conduct appropriate by Mr Fisten MR SCAROLA And I will tell you that you are not obliged to answer hypothetical questions TIIE WITNESS And therefore I am not going to answer that question BY MR CRITTON lfMr Fisten represented that he was associated with the Miami-Dade Police Department Miami-Dade County Police Department would you find that conduct inappropriate MR SCAROLA Same instruction and I would Page also observe with regard to each of the hypothetical questions that you are asked that they are incomplete And without knowing all of the surrounding circumstances it would be impossible for any witness to pass judgment upon what may have occurred BY MR CRITTON So Mr would it be a correct statement at least as you understood it Mr Edwards that Mr Fisten was not an agent was not an FBI agent during the time that he worked for RRA A Youre asking me was he an FBI agent or did he work for RRA He worked for RRA Correct He was not an FBI agent true to the best of your Imowledge during the time he worked for RRA A Okay I am not talking about any other time period right now A Okay Then the answer is be was not an FBI agent at the time he was working for RRA During the time he worked for RRA he as well was not associated with Miami-Dade Police Department correct A Oh I dont know that Page Could he is it your A How would I know associate he may have been Let me ask you this was he employed by the Miami-Dade Police Department in addition to RRA during the time he worked there A To the best ofmy knowledge no Did with regard to Mr Epsteins cases was there any type of cost account set up for for them A I dont know Could you access any of the financial files within the RRA firm A No Could you access any files that were associated with your specific excuse me clients or your specific case such as if you wanted to know how much in costs had been incurred by Mr Epstein on Jane Does case while at the RRA firm could you request that could you access that information A I dont know Did you ever tty to access that information A At any time did you request that anybody provide you copies of what the costs were associated Page with Mr Epsteins cases A No Since you left the firm have you requested any type of detailed billing or cost analysis such as to the cost of any of the costs that were incurred on any of Mr Epsteins cases A Of course Okay And did you receive those costs Did you receive that information A Yes And what costs have been incurred in the cases in the Epstein cases associated up let me strike that What costs what is the total amount of costs that were incurred in the Epstein cases during the time that those files existed in the RRA film MR SCAROLA If youre able to answer that question with regard only as to amount without specifying any of the specific cost expenditures then I think we can answer that question only as to amount THE WITNESS And the question as to the aggregate in the three cases MR CRITTON Correct THE WITNESS Because I cant delineate Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopklns Electronlcally signed by cynthla hopldns Electronically signed by cynthia hopklns Page for you MR CRITION Your best estimate 11IE WITNESS Okay I believe more than BY MR CRITTON With regard to if investigation was done on on a Epstein case was the investigator charged that is for his time as an example Mr Fisten if he did work in California would his time Im not talking about his expenses would that be billed as a cost to the file A I dont know On the cost that you received well let me strike that lfl understood it up to approximately thats been spent on the Epstein file were you able to look A It would be more than that I am just saying its at least Something between three and could it A Something that I would say is definitely between and but rm not sure It could be It could be I really dont know When was the last time that you looked at that ledger or the printout associated with the Page A I have never looked at the printout Okay How how do you know what is amount is then That is how do you have the estimate of it being between Im sorry between and the cost associated with Epstein A I asked a paralegal within my current finn for the total amount of costs on these three cases that is being claimed by Rothstein Rosenfeldt Adler And I remember the cost number in the aggregate being given to me reflecting an amount what I just told you Have you requested a copy of the Jet me strike that Did she say she had that is did she did you actually receive a document that reflects the breakdown of the costs from the trustee A I personally have not seen that Okay Has your firm received it A I dont know assume would it be a correct statement that the three to is includes only the time between April of and October of when you were with the firm A Its a good question I I believe so And approximately prior to joining the Page finn had you you had spent some of your OWll money and/or LLC money on the files is that correct A Thats correct Approximately how much is that amount A Im Im not sure I think as youre aware most of the depositions and costly work that was done on the files happened to have been done during that time period for all of the respective cases or claims against Mr Epstein during that time period oflast summer of All right But in tenns of your costs prior to coming to RRA whats your best estimate of the costs that you have paid either out of pocket or are responsible to a bank to repay A I dont know More than less than A Im not sure More than I A No More than A I dont know Thats a record obviously you could pull up correct A Correct AU right Now with regard to prior to Page your coming to RRA had there been any investigation work that you had done on the Epstein files and let me strike that Had you hired or retained an investigator to do any work for you on the Epstein files prior to coming to RRA A I dont think so All right A It would have been around that time I dont remember whether the initial investigator was hired by me from my previous from my solo firm or was hired by Rothstein Rosenfeldt Adler I cant say Who was the first investigator that you believe was involved in investigating the Epstein cases Just a name not topic MR SCAROLA Work-product instruct you not to answer BY MR CRITTON Was the first person that was retained as an investigator someone who ultimately became employed by RRA MR SCAROLA You can answer that THE WITNESS No BY MR CRITTON The the person who you hired to and by investigation I mean something other than looking up Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthia hopklns ElectronJcally signed by cynthia hopklns Electronlcally signed by cynthia hopkins ff76c2ea Page an address to setve a subpoena or or doing some minimal background A I am glad you clarified because I am using that same definition All right So its its your best recollection that you did or did not hire an investigator to do real investigative work with associated with Mr Epstein prior to joining RRA A I believe I did but it was after a time when I had I was contemplating or at least to myself had conitted to going to RRA So it was within that time period I believe that I hired that person prior to RRA When you then went to now you had committed to go to RRA or at least mentally committed to go to RRA As soon as you started with RRA did you tenninate the services of that investigator A No Did that investigator continue to do work A Yes Okay Has does he or she or it continue to do work today for you A No On Mr Epsteins case youre asking right Yes sir Page A No Okay For how long a time period did that person continue to do the work before it got transferred to Mr Fisten or other investigators A Question doesnt make sense Okay How long did the investigator that you may have hired prior to joining RRA work on the Epstein files before you ceased that work after you started working for Epstein in April of Im sorry for RRA in A The person was hired in either March or April of which is why I cant say with absolute certainty whether I was at RRA or not And that person continued to do investigative work in some capacity probably throughout the entire time that I was at RRA Were all of the bills for that investigator paid by RRA A Yes With regard to the payments for the investigators well let me strike that Who other than Mr Fisten from an investigator from an internal investigator at RRA employee worked on doing investigation on I.he Epstein files MR SCAROLA Same objection same instruction Page MR CRITTON You are claiming work-product MR SCAROLA Yes BY MR CRITTON The investigators did you m1derstand them to be salaried employees of RRA A really have no idea Did you ever ask them A No Do you Imow whether the do you have any knowledge as to whether the investigators kept time records A I do not have that knowledge In tenrlS of when an investigator would come back well do you know how the investigators were paid A Withmoney FromRRA A I would preswne Totally speculation Would the RRA were the investigators for RRA bonused A have no idea Did you ever discuss with Mr Fisten what his fmancial compensation was associated with RRA A No Page Did did you ever promise either Mr Fisten or any other investigator that when the case settled they would get a bonus from an Epstein case A No Okay Did Mr Fisten ever inquire of you as to whether he would get a bonus if in fact the cases on which he worked including the Epstein cases settled for a favorable verdict or result came in A No Did you have any understanding from either your conversations from Mr Rothstein whether investigators were bonused based upon the work that they did A Excuse me Did you ever have an m1derstanding from Mr Rothstein that that investigators would be bonused from cases on which they worked based upon their work product or their contribution A No I had no understanding Did you from I assume youve read a number of the news reports associated with Mr Rothstein and the implosion of the firm A Okay I assume you have seen a number of them Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthia hopldns Electronically signed by cynthia hopkins Electronically signed by cynthla hopkins Page A What do you mean by a number More than one A Yes I have seen more than one Have you seen articles were its alleged that investigators that were employed by Rothstein by RRA would go through the garbage of prospective Defendants to search for incriminating or favorable incriminating evidence against the Defendant or favorable evidence for a Plaintiff who might be working or who might be a client of the firm lo A I have not seen an article saying that I think I have heard your client say that before Separate and apart A Right You dont have to rely on anything my client has said before the testimony MR SCAROLA I am sure we wont MR CRITTON I am confident of that BY MR CRITTON In terms of were you aware from the articles did you see in the article let me strike that Did you ever direct your investigators to go through Mr Epsteins trash MR SCAROLA I am going to object work-product attorney-client privilege Page BY MR CRITTON Have you directed did you ever direct this is the investigators during the time you were at RRA and thats the question youre claiming the privilege over correct MR SCAROLA I am claiming the privilege with respect to any action that was taken by Mr Edwards or at Mr Edwards direction in MR CRITTON Tell you what I will withdraw the last question MR SCAROLA in connection with the investigation in prosecution of the claims against Mr Epstein BY MR CRITTON Let me make my question clear Mr Edwards With regard to your investigators you gave direction with regarding the Epstein cases during the time you were with RRA did you ever tell them or direct them to go through Mr Epsteins trash MR SCAROLA Same objection same instruction BY MR CRITTON Did you ever direct the investigators to go throurui the trash of the lawyers who were Page representing Mr Epstein including myself MR SCAROLA Same objection same instruction BY MR CRITTON Did you ever MR SCAROLA Mr Edwards will not answer any questions regarding what he did or didnt do MR CRITfON I understand I just want to make it certain its for the court on some of these issues MR SCAROLA Well for the court I am telling you he is not going to answer any of those questions And continuing to ask them in light of the fact that we have told you and made it clear the scope of our assertion of privilege serves no useful purpose BY MR CRITTON Mr Edwards at any time did you well let me strike that Did you ever direct the investigators to during the time you were at RRA to conduct a surveillance on Mr Epsteins property MR SCAROLA Same objection same instruction Page BY MR CRlITON Since the time you have left RRA in your current finn have you conducted surveillance on Mr Epsteins property MR SCAROLA Same objection same instruction BY MR CRJTION Have you instructed anyone either of the in house investigators to conduct surveillance of Mr Epsteins property MR SCAROLA Same objection same instruction BY MR CRITTON Have you authorized investigators employed by RRA either employees of the firm or an outside investigation finn to walk around the perimeter of Mr Epsteins home on or about March 17th of MR SCAROLA Same objection same instruction THE WITNESS Whats the date MR CRITTON March 17th MR SCAROLA St Patricks Day Did you employ any leprechauns TIJE WITNESS Actually Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopkins Electronically signed by cynthia hopklns Elecb-onlcally signed by cynthla hopkins ff76c2ea Page BY MR CRITTON With regard to the with regard to the investigators wid1 regard to the investigation bills that would come in from outside investigators specifically the one that you well let me strike that The investigator that you hired before you went to RR.A I think you testified that bill was paid by RRA correct A Yes All right And in terms of the investigators who were employed by RRA for whatever investigation you directed them to do those individuals were also paid from funds from RRA correct A Dwing the time period when I was at RRA youre asking about specifically correct I Correct A Then the answer is yes Was there any specific cost account that was set up for Mr Epsteins cases A I dont know Did you ever speak with the A Again were talking about the time period at RRA Page AtRRA A Okay Duling the time you were at RRA did you ever speak with the accounting department or the accounting department ever call you to talk about the amount of costs asswning they were something between and that were being expended on Mr Epstein files A No Did did anyone at the finn ever call you to discuss the issue of the amount of costs between and that were being incurred to prosecute Mr Epsteins cases A No l4 Okay Who had checked did you have any check-signing authority at RRA A No Who did sign the checks A Idontknow lwas In terms of the the work that was being done or the the work that was iliat is the costs that were being incmred including reimbursable costs did you understand that you had a basically an unlimited budget to prosecute those cases A No Page Okay Well if you could authorize any expenditure that you wanted and nobody ever told you not to that you couldnt spend the particular money what controls if any existed with regard to monies spent on the Epstein cases A The presupposition that you just created is incorrect so I cannot answer that question You began with I have no limit to how I can spend money and that there is no regulation I mean thats just not true so I dont understand what to tell you What limits if any did you have in spending money in prosecuting Mr Epsteins case A We went through expediting transcripts and I used my own judgment I understand that A Ifwe have another specific example I will address it and I will tell you whether I had that authority or somebody else may have had that authority But specifically related to expediting transcripts and things involving depositions ordering depositions I used my judgment and it was never questioned Separate and apart from transcripts if if youve testified that the expenditures for costs that the finn or the trustee is seeking back at RRA is seeking back is seeldng relating to any Page recovery in any Epstein cases is between three and correct A Correct All right So separate and apart from expedited transcripts or video depositions or serving subpoenas that there has to be you know hundreds of thousands of dollars in additional expenses that were associated with prosecuting Mr Epsteins cases correct A Correct And with regard to those types of expenditures that are in the hundreds of thousands of dollars who authorized those types of expenditures A I dont know Well you said that you used judgment certainly with regard to transclipts So who if if spending an extra two three separate and apart from transcripts serving subpoenas is not a limitless budget how would you describe it that is what controls if any did you have in prosecuting the Epstein cases A First I havent seen the delineation of that amount and I dont lmow that we agree with Rothstein Rosenfeldt Adler as to their costs but that is what Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopkins Electronically signed by cynthla hopldns Electronically signed by cynthia hopklns Page theyre c1aiming 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 caUs 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 infonnants did you authorize your investigators to hire informant informants 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 correct A Yes document documents do reflect that title of course yeah And ifI had asked for a card during the time that you started at RRA up until the time of the implosion of the finn in late October of would your card have also reflected that you were a partner of the firm A I think you did request a card I think I gave it to you and 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 1s public Youcalledyourselfapartner Youdidnt say Im an employee rm not a partner correct You held yourself out to the public as being a partner MR SCAROLA Im going to object to the form of the Question to the ex.tent that it Page suggests that those terms are mutually exclusive TI-IE WI1NESS That was a pait of my answer is that I dont know MR CRITTON I am shocked to hear that THE WI1NESS 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 Thats just the way it was BY MR CRITION 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 care 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 Dilling 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 recall significant settlements Correct A coming into the firm that were publicized Correct A I believe I cant gay 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 widerstand 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 firm or within the newspapers is that a fair statement A Fair statement Where did you tlrink 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 Seventv Pages to PROSE COURT REPORTING AGENCY INC Electronlcally signed by cynthia hopklns El lcally signed by cynthia hopkins Electronlc:alty signed by cynthia hopkins ff76c:2ea 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 nwnber 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 MR 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 Ivrr Edwards MR CRITTON Is that form 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 MR SCAROLA Objection MR CRITTON Just of yours and yours alone lv1R SCAROLA Objection form and compoWld THE WITNESS The law finn 1l Page BY MR CRITTON Where did you think the law finn let roe 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 rvtr property sic Mr Epsteins property on March 17th IO 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 wen as attorney-client privilege and instntct 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 IvlR 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 was a lawyer at Rothstein Rosenfeldt Adler Did you have any dealings with her on any of your cases A None What did you 1.mderstand her area of practice A Never knew Pages to PROSE COURT REPORTING AGENCY INC EJectronlcally signed by cynthla hopkins Electronically signed by cynthla hopkins Electronically signed by cynthla hopkins l3 Page Did you know an individual by the name of Patrick Roberts A Yes Okay And who is Mr Roberts during that is what did Mr Roberts do for RRA A He was an investigator Did he ever perfonn investigation worlc on any of the Epstein files MR SCAROLA Same objection same instruction BY MR CRITTON Did you ever authorize Mr Roberts to perform investigation on the Epstein files MR SCAROLA Same objection and instruction BY MR CRITTON All right I asked you earlier about Richard Fandrey F-a-n l-r-e-y I think you said you dont know who that you knew someone named Rick is that correct A I know an investigator named Rick Did Rick did Rick perform any investigation on the Epstein did you authorize Rick to perfonn any investigation on the Epstein files MR SCAROLA Same objection and Page instruction BY MR CRITTON And I believe we talked a little bit about we certainly talked about Mr Jenne did you ever authorize or direct Mr Jenne to perf onn any investigation on the Epstein files MR SCAROLA Same objection and instruction a BY MR CRITTON Are you familiar with the company called Blue Line Research and Development ll A No Are you are you aware at the current time that there is an entity called Blue Line Research and Development which is composed of Mr Roberts Mr Richard Fandrey Mr Michael Fisten and Ken Jenne A No If youre unaware of the existence of the entity called Blue Line Research and Development LLC would it be a correct statement that you have never authorized anyone from Blue Line Research and Development LLC to conduct any investigation of Jeffrey Epstein MR SCAROLA Same obiection same Page instruction MR CRITTON Says he doesnt know them How can that be an instruction MR SCAROLA Well because I am not going to ten you were not going to permit Mr Edwards to answer any questions about either what he did or what he didnt do that are part of the work product involved in his representation of the Plaintiffs with claims against Mr Epstein whom Mr Edwards is representing MR CRITTON Did you ever MR SCAROLA So in light of that and what I have attempted to make very clear with regard to the scope of our objections if you continue to ask questions which it is clear fall within the scope of my instructions to Mr Edwards and my announced intention with regard to the scope of those instructions then we will terminate this deposition so that I can seek a protective order My suggestion is that you move onto other areas that are outside the scope of that instruction if you have any other questions outside the scope Page MR CRITTON Oh I have a lot of other questions MR SCAROLA Okay MR CRITTON Let me be clear with you with regard to any for purposes of following asking any fol1ow-up questions should the court determine that am entitled to this information you would agree that should the court detennine I am entitled to ask the name of these individuals and possibly other questions is is that by not asking questions I am in no way waiving my right to ask as many questions as the court ultimately determines as appropriate proper and as the court allows correct MR SCAROLA I absolutely agree MR CRITTON All right BY MR CRIITON Mr Edwards are you familiar with a person named Alfredo Rodriguez A Yes And how do you know Mr Rodriguez A Who do I know him to be How do I know him I met him the same well I met him after you did after you and your investigators pre-depoed him on three Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopklns Electronically signed by cynthia hopkifl5 Electronically signed by cynthla hopkins ff76c2ea Page age various occasions for a total of about hours before July 29th and August 7th we took this deposition met him for the first time A And ifl did or ifl didnt either way thats during that deposition going to be protected by the work-product privilege and MR CRIITON Let me move to strike as Im not going to give you that information because nonresponsive youre not entitled to it BY MR CRITTON I disagree even in a simple My question to you is when did you first attorney-client privilege you also you identify the meet Mr Rodriguez date you dont identify the subject but you MR SCAROLA And you have an answer to identify the date who may have been present that question MR SCAROLA We understand your position THE WI1NESS Its a very complete answer and its not necessary to articulate it on the I the day of his deposition record BY MR CRITTON MR CRITTON I just want to be clear Had you ever spoken with Mr Rodriguez And your position is the same is youre not before that time talking A No lvlR SCAROLA Work-product Okay Had anyone on your behalf spoken MR CRITTON Work 225product correct with Mr Rodriguez 1B lvlR SCAROLA Thats correct A No BY MR CRITTON Mr Rodriguezs deposition occurred over a Mr Rodriguez was requested to bring 2l two.day period is that correct Two separate days documents to his second deposition that he had A I believe thats right referenced that he might have Do you recall that And you were present for both of those from the first deposition Mr Edwards depositions is that correct A Ido A Yes And in fact when he came to the second Page Page And the first one I believe at least in deposition he didnt bring any documents with him looking at the transcript the first one occurred on did he January 29th of A I dont remember A Im assuming Well do you remember him producing any And the second the follow-up was on documents at the second at his completion of his August 7th correct deposition A When was the first January you said A I dont remember Excuse me Im orry July 29th Do you recall him saying that he might A Okay have some sort ofbook or some sort oflist of names With the follow-up July rm sorry and addresses and/or names excuse me of females August 7th who may have come to Mr Epsteins house along with A Jfyou say so Im not quarreling with that phone numbers And I will just represent that is what I A I dont remember ifhe said that or it says read off the transcripts Between those two dates that in the police report but I remember that that is July 29th and August 7th of09 did you information at some point in time speak with Mr Rodriguez at all All right And subsequent at the 1R SCAROLA Same objection same conclusion well let me strike that instruction to the extent that any such Do you recall receiving any documents from conversation may have occurred in connection Mr Rodriguez that were produced at his deposition with your representation of the Plaintiffs and that had the names and addresses and/or phone claims against Mr Epstein numbers of any other females BY lY1R CRITTON A I dont know Do you We were there together All I am asking right now not the I dont remember specifically I think the answer is substance but just so the record is clear I am just no askin1:t did you sneak with Mr Rodril!UeZ between And I think youre right Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthia hopklns Electronically signed by cynthia hopkins 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 Welt 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 CRJTTON 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 workwproduct privileges 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 a 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 fr Rodriguez between his first and second MR SCAROLA Same obiection same Page instruction BY MR CRITTON Did Mr Rodriguez ever make a request of you at any time for any type of monies for testimony documents or any other infonnation associated with any existing or potential claimants directed to Mr Epstein MR SCAROLA Same objection and instruction BY MR CRlTION 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 CRITION Did you after Mr Rodriguezs completion of his deposition on August 7th did you have an occasion to speak with any representative a professional attomey professional slash attorney for the U.S Attorneys Office MR SCAROLA Same objection and instruction Page BY MR CRlTION 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 CRITTON Yes MR SCAROLA Im not sure what are you familiar with it means BY MR CRJTION 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 cynthia hopklns Electl"onlcally signed by cynthla hopklns 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 FBI or the U.S Attorneys Office in support of aJthough not attached to this to Exhibit I 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 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 tvfr Edwards you lrnew or you first Marie Vi11afana through the complaint you filed on behalf of Jane Doe and Jane Doe in July of 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 Ms 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 dont know What what was your first association or what contact was what was your fast contact with Marie Villafana ever A I dont remember But ifl 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 with 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 thia earlie1 so I apologize did you c:vi::r speak witl1 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 cynthla hopkins ff76c2ea Page had conversations with Mrs Villafana from time to 267time A Okay Is that true A Is your asswnption true Correct A I have spoken with Ms Vil1afana And when you spoke with Ms Villafana let me strike that Have the only conversations that you have had with Mr Marie Villafana or VHiafana 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 objectioIL 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 MR CRITTON Has Ms have you spoken have you had an occasion to speak with Ms Villafana with regard to the criminal complaint Exhibit No involving Alfredo Rodriguez Mr Rodriguez 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 Iv:lR SCAROLA Any of the three clients who have claims against Mr Epstein a MR CRITTON Correct MR SCAROLA Same objection same instruction BY MR CRITTON 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 That fine MR CRITTON Nesbitt Kirkendahl TIIB WI1NESS I don know her last name but I do know 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 CRlITON 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 Vil1afana Okay What 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 Jong 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 cJients 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 sw1mwv Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopklns Electronically signed by cynthla hopkins Electronically signed by Cynthia hopldns 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 rerord in the case will speak for itself I really I dont remember right now Have you had any other conversations with Nesbitt Kirkendahl 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 K.irkendahl since July July or August during that short conference as physically 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 Attorney Office FBI or other agency 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 doesnt 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 workwproduct 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 Epstein MR SCAROLA Same objection same instruction BY MR CRITTON Did you have did you engage in weekly or monthly meetings among the Plaintiffs lawver to Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthia hopklns Electronically signed by cynthla hopklns Electronically signed by cynthla hopkins ff76c2ea Page share investigative material regarding that you had obtained regarding Mr Epstein MR SCAROLA Same objections and instructions BY IvlR CR1ITON 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 BYMR CRITION 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 lv1R SCAROLA Sarne objection same instruction to the ex.tent 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 answer to that extent TIIB WlINESS Privileged BY MR CRITfON And I just want to be clear is is there any Mitten 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 There are a number of claims that are outstanding against Mr Epstein brought by a number of different lawyers IvtR SCAROLA The objection extends to both written agreements and oral agreements THE WI1NESS Yes We both know that there are a lot of claims 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 of infonnation MR SCAROIA um objection 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 sony 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 CRITTON Okay And Im looking for is ayes/no MR SCAROIA Correct Same objection same instruction BY MR CRJTION Mr Edwards during the time that you were with RR.A did you your e-mail was your only e-mail address bedwards rra-law.com A I only had one e-mail address All right Did you ever receive any Page information regarding your cases at your home e-mail A I dont remember Okay What is your home e-mail address please THE WITNESS Do give this MR SCAROLA lvlr Scarola nods his head Tiffi WITNESS hotmail.com BY MR CR11TON 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 fonn 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 Electronically signed by cynthla hopkins Electronically signed by cynthia hopkirn ElectronlcaHy signed by cynthla hopkins 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 1HE WITNESS Answer MR SCAROLA Yeah THE WITNESS The reports were yes I did BY MR CRITTON 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 do not remember there being any in the form of an e-mai I Does not mean that there was not I did corranunicate by e-mail with other members of the firm and other members of the investigative team on all cases as has been my practice all 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 Ali 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 A 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 WlINESS No BY MR CRITTON 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 Epstein 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 Im 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 I may remember I dont remember right now Did other lawyers in the finn at RRA perf onn 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 Eledronically signed by cynthla hopklns Electronically signed by cynthla hopldns Electronically signed by cynthla hopklns 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 Wl1NESS Other lawyers contributed to some extent to the prosecution of those cases BY MR CRITTON Who Names Im not asking for tasks MR SCAROLA You can answer MR CRITTON I am asking for names THE WilNESS Bill Berger Judge Stone Russell Adler Rob Buschel BYMR CRITTON A I dont know how to spell it B-u I dont know how B-u I 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 lt was Page another lawyer Thats thats those are the ones that I can remember right now Were there ever meetings that occurred wen 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 Buschel and yourself that would have commented 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 lawyers 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 TilE WllNESS 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 CRITTON Okay And what did what did what information did Mr Rothstein send you that involved Mr Epstein MR SCAROLA Same objection same instruction BY MR CRITTON ls the infonnation that you received or the communication you received from Mr Rothstein regarding that involved Mr Epstein was that bv Pages to PROSE COURT REPORTING AGENCY INC Electronically sfgned by cynthla hopkins Electronically signed by cynthla hopklns Electronically signed by cynthla hopkins ff76c2ea l1 Page way of e-mail A Tu 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 that occurred where these various lawyers Berger Adler Stone Rob Busche were present and Epstein was discussed was the discovery that discovery and/or investigation regarding Mr Epstein was that ever discussed MR SCAR.OLA Same objection same instruction BY MR CRITTON Mr Edwards are you aware as a former state prosecutor that there are laws against conducting certain financial transactions in money thats derived from a crime A I dont understand your question Okay Well you were a fonner state prosecutor is that correct A Right Yes Right Are you aware that there are Page certain laws both state and federal that that are that preclude conducting certain fmancial 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 I help you Do you want to ask him whether he was aware of the existence ofa state RICO statute MK CRITTON No MR SCAROLA Okay MR CRITTON 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 RJCO claims But you certain have brought RICO claims against Mr Epstein A 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 ours through attempted murders and everything in between No we11 not no very few economic crimes some insurance fraud cases but very few otheiwise 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 What 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 what 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 CRITTON 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 have never read in the entirety Exhibit Are you familiar do you know what an infonnation is A Yes Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopkins Electronically signed by cynthia hopklns Electronlcally signed by cynthla hopklns Page And thats Exhibit attached to the complaint correct A Correct And youre aware that and this the information that was brought by the United States of America S.A versus Scott Rothstein correct 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 lo information 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 infonnation brought by is U.S.A against Mr Rothstein I assume you have read the allegations associated with the racketeering conspiracy the pattern of racketeering activity a correct A 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 wtder under RICO but with regard to mail fraud wire fraud Page laundering of monetary instruments engaging in monetary transactions and conspiracy to launder monetary instruments 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 infonnation Exhibit to the complaint in Paragraph where it speaks in temlS of the Defendant and his co-conspirators 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 former 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 finn was a racketeering enterprise correct A Not necessarily no Well if you look in Paragraph see where the finn is identified as the enterprise of the racketeering conspiracy A Law firm Paragraph of the infonnation says Rothstein Rosenfeldt Adler P.A was a law finn with offices located at East Las Olas Boulevard Fort Lauderdale Florida and elsewhere The law finn employed approximately 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 my error A Okay See where the law fom is identified as the racketeering enterprise A Im sorry Your question is am I do recognize that the Jaw finn 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 Jv.lr Rothstein A No in the criminal complaint A No Since the implosion at the firm have you had an occasion to talk about or speak or discuss any fitm 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 Pm sorry Have you had an occasion to discuss with Mr Adler since you left the firm 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 hopkins Ekldronically signed by cynthla hopkins Electronically signed by cynthla hopkins tm Q??F?Ԭ 4U U?m 2Y hK tC7 y?x Jk??L r?fY?NN oɃ1?PW?S O??Ǯt A æ7 Qfn fxF?v 0_ A Q?ED z!FE A i U?W U9 V?c??b?ckRR O1a_ jT s?HQDi?o Z??D?Y s?r V?Y ZHEx Zb?Z?u?ҁj MA I uwi6?ZA?HA??J UL0?m JD C?TA?w YL s?I?8)SJ L?m F?tG?m??j TZ H?oQ?OsT?Q 켼??J?Q Ke f?j b?ɪê?jQ c?e T??j?Z yLz??п?uTc yTH bY?e Z?g?V ɲ?yX?j45 ʀ2W 1TBI ˆ?C 7H P?M zA sN?J?L??cl Ԡ?l MxŮ?0??J jo?w CN ˬڐo Q"a?v j?ڒ f?R?Ԁr CW ߕ??ޡ D?W y?L Iu?S J?m??Q jv z?C j?m p0?W 1LR?wJ 右VY 6W m?t 4DE T?b?OQf 1r LU HQ??V n?T ȕa a 7Wk ΐƎ?p?V CV MoZ?iЕ u?2vW BW Ь?䘁??7?RLD?ʯd ls??Wrr?c OKD??l F?gO cS U?b?gV?u 5M?I a FU?k?ن3 f?u?RL?M FN q0??Cmx h?;o UZ VK Ė??R f?A Mܐī k?g A b7?w O?y 夔鎄0 aKE?3 K??n DnQ7J?wE0 h?q??k i y?jq JŴ h?x Ȥd?-c?m Bk Px?6 uw?nw?c?Y E??W?B?ǥ 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 finn RRA business A Right no How about with Mr Rosenfeldt have you had any discussions with him a A None since the implosion of the finn in late October ofl09 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 fonner partners of the finn regarding the implosion well let me strike that regarding the ponzi scheme that was being run 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 Rothstein had been well let me strike that How long did you think RRA had been in existence prior to your joining the finn What were you told A I dont know what I was ever told I think that I learned that infonnation when the implosion as you call it occurred And were you in tenm of what the revenues of the finn were were you ever advised what the revenues of the firm were A Nn Okay Were you were you familiar with what the expenses were associated with operating the RRAfinn A No Were you in anyway weU let me strike that With regard to let me talce a five minute break and Jet me collect my thoughts Page THE VIDEOGRAPHER We are now off video record MR SCAROLA That will be a refreshing change nm VIDEOGRAPHER We are now off video record at p.m A brief recess was held MR CRITTON Mr Edwards THE VIDEOGRAPHER Were back on video record It is p.m BY MR CRITTON Mr Edwards whenyoujoinedRRA 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 terms of how to prosecute the case The 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 fl 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 signed by cynthla hopkins Electronk:aly signed by cynthla hopklns Elec.tronlcatly signed by cynthla hopklns ff76c2ea Page obviously knew what whether hiring an investigator or what a particular cost was because you had to pay it correct A Yes 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 well 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 conjunction 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 des ribed the compound I think is the word that you used that Mr Rothstein kept himself in when he was Page at the finn correct i 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 paitly a separate floor TI-IE 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 finn 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 firm where bless you Had you ever been in a firm where there well let me strike that The guards were what Broward County Sheriffs Officers A I dont remember the agency but they were armed 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 ai.med 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 anned guards patrolling the floors did you ever have a convernation 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 guarcw Page A When I first started I believe that the people patrolling Jm 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 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 wh hey 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 anned unifonned police officm 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 security he is going to do that for all of our safety Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthia hopldns Electronically signed by cynthia hopldns Electronically signed by cynthla hopkins Page Did you understand as well that he had that the firm was paying for aI1ed guards to guard his 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 SU 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 I 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 lawyer to be wearing yes And in tenns of the in temJS 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 it as 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 Wall 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 irrunediately 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 dont know if I could have walked around the house but I 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 during 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 cynthia hopkins Electronically signed by cynthia hc,pklns Electronically signed by cynthla hopklns Page at that time A I 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 Through rumors And rumor was he had ms fingers in many 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 I 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 Corvettes 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 I was to say it was approximately an to 90-foot yacht or in fact an 87-foot yacht A I wouldnt quarrel with that Did it also appear that he had a substantial sport fisherman that was parked out there as well A I didnt see that Were you aware that he had 33-foot Aqua AQuaviva Page A No Were you aware that he had multiple jet skis A No Were you aware that he had a 55-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 BOY A 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 purchased various patents I understood I didnt know what the patents were I understood that he owned other restaurants I understood that he owned or was partial owner of cafe Iguana Page At some point in time I learned that he was owner or partial owner of the Versace mansion And I think in general it was always explained to me or I overheard he had he has his hands in of these this assortment of businesses and those business ventures have done very well and that is the source of his apparent extreme amount 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 documents that reflected or documents or read any infonnation about Mr Rothstein that preexisted which was kind of the start of the RRA finn A I dont understand Okay Well I think we established earlier that your understanding was that RRA kind of started as a firm 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 re23.td to Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthia hopkins Electronlcally signed by cynthla hopkins Electronically signed by cynthla hopkins ff76c2ea Page Mr Rothstein prior to going to the filTil and by research I mean people Google Did you Google him A No Did you did the firm 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 was founded background of the finn et cetera A No Was it on your web site A Was what on my web site The history or the background of the finn Let me strike that RRA had a website A RRA had a website Thats no longer in existence true A True And A Tomylmowledge 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 pe of business that it appeared to you that the firm was doing A I have no understanding whatsoever No thats not something that ever crossed my mind Well under these circumstances is is When you went to the finn you had the ability to your discretion to spend whatever monies you wanted in prosecuting your personal injury and Epstein cases You llO 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 WlINESS I dont understand the question BYMR 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 these cases MR CRITTON Fonn Page MR SCAROLA No no Its a its a speaking inquiry BY MR CRITTON Mr Edwards did you ever have any dealings with Deborah Villegas A No Am I saying it right A I dont lrnow A Ive seen the name Did you know who she was A In vthat 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 firm 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 I 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 vehic1es his boats his 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 know 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 firings 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 he had with regard to the yacht that you knew he had with regard to the vehicles that you knew he had with regard to the business interests at least BOY A and Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopklns ElectronlcaUy signed by cynthla hopklns Eledronlcally signed by cynthia hopklns 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 firm A I believe 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 his hands in of which only a fraction I was aware WeU 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 firm 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 M:r 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 firm who also had cases A I 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 firm was Page funding your cases MR SCAROLA Objection argumentative TIIE 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 film at that level operate and right I didnt BY MR CRIITON 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 A Never heard the name until right now A.J Discala A Again same answer Clockwork Capital Advisers A No never heard of them RazorbackFunding A Nerve heard of it Michael Sz.afranski S-z-a-f-r-a-n-s-k-i A Heard that name And A only after imnlosion and throullh 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 of Benozon phonetic Varon 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 P-r-e v-e A No Okav Mr Preve is purportedly was Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopkina Electronically signed by cynthia hopklns Eltctronlcally signed by cynthia hopklns ff76C2ea 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 I 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 firm A Something with money Did he have an office at the firm A I think the trustees are still trying to figure out what he exactly 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 Page 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 K-r-e-t-c-h-m-a-r 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 Sochet A No Mark Melvin A No Jack Samoney phonetic A No Lawrence King 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 asl;ng me what I know now or what I 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 I 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 firm 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 hopklns Electronically signed by cynthla hopkins Electronically signed by cynthla hopklns Page as the director of Corporate Development for RRA A dont know even know what that means Have you ever heard of the Centurion Credit Fund or the Platinum Management Fund A No AJan Sakowitz A No Wait Alan Sakowitz I have heard that name recently I dont know why believe I actually heard that name in a response Never mind In some nonresponsive answer that your client gave I heard that lo 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 ceUphone today the same as it was back then A Yes And whats that number please MR SCAROLA Cellphone nwnber THE WITNESS Page BY MR CRJTION Did you ever have a finn cellphone or just your own personal cellphone A No Just my omt personal cellphone During the time that you were at the finn were you ever involved in making any type of a presentation to anyone regarding the Epstein cases A Including other lawyers within the firm 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 yot.ttself you said there was an individual on the phone A Right It was another lawyer with the finn 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 lawyer who represents Scott Rothstein now I dont know which it was but it was one of the two Okay Were you ever present at a meeting where someone who you didnt know was present 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 confinn 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 finn 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 conferenced 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 summary of any of your Epstein cases that you in tum 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 Jet 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 l1R 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 atthefmn Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopkins Electronically signed by cynthia hopkins Electronically signed 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 was the guy on the billboards and at the Triple A arena and everything else marketing the finn 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 we11 although I am not shoMl as a recipient I received e-mail THE WITNESS Are you talking about the fax MR CRJTfON I am sorry the fax MR SCAROLA Exhibit Exhibit lvIR CRITTON Exhibit Let me start again Exhibit is a fax THE WI1NESS 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 signatle and under that it says Bradley Edwards Esquire partner fort sic the firm 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 welI BJE is you Who is the MGL A Who is the MGL Lets see On Page There are your initials Bradley Edwards BIB 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 know With regard to the individuals who were listed in Exhibit specifically Donald Tnp 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 All right Prior to your joining RRA you had never requested either that the deposition of lvfr Trump be taken Mr Wexner nor Bil1 Clinton correct Page A I never requested a deposition to be taken including any deposition of those three individuals I understand but all right A The answer to your question is yes All rigllt 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 Sterns at some p-::,int in time You also requested dates and in fact served a subpoena on Alan Dershowitz the Harvard Jaw professor correct A Correct And Mr Dershowitz you 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 was a former rm 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 cynthia hopkln Electronically igned by cynthla hopklns FԆ??Bm y?i?Qp H?ZȋЫ A??BP 3o?o?E Qŧu x?k YGa?S U?rSV cP6W 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vCR S?uj.0 G/?y U??p??I?AC YW?b A a 5?gT i G?i P/k Page Jeff Epstein Well you also understood Mr Epstein has had ongoing criminal law issues even during the time of the civi1 case 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 aware of the existence of a nonprosecution agreement Well and in fact you came into possession of the nonprosecution agreement sometime 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 1s So you had possessionoftheN.P.A as of sometime in the year correct A Right All 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 agreenxmt 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 Mr Dershowitz had represented Mr Epstein with regard to negotiating his plea that ultimately was reached in negotiations with the federal government true A 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 W.s and E.W.s updated interrogatory answers which were provided durine the vear an individual named Page Tony Mottola was listed Do you know who Mr Mottola is A Generally I think I know who that is Who did you understand Mr Mottola was A Something to do with he music industry All right And the name David Copperfield was also referenced as a potential witness in the case correct A That is correct Alt 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 MR CRITION Let me rephrase it With regard to the lawyers in the case including myself you attempted to coordinate a time for completing or taking the deposition of Mr Copperfield Mr Mottola who I will represent is the former president of Sony Records fomier president Bill Clinton Alan Detshowitz Donald Trump and Leslie Wexner 1rue Page A False Which of those as to which one of those is that false A Torrnny Mottola So but you did attempt to coordinate the depositions of Donald Trump Mr Dershowitz former president Clinton David Copperfield and Leslie Wexner correct A I 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 firm as to the benefits that would exist in your case your three cases against Mr Epstein by raking these individuals depositions MR SCA.ROLA 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 Mr Trump that is in discussions with any other lawyers in your firm includitu Scott Rothstein Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cyntt,la hopklns Electronically signed by cynthla hopklns Electronically signed by cynttila hopkins Page MR SCAROLA Same objection same instruction BY MR CRITTON Same question with regard to Mr Dershowitz fonner president Clinton Torrnny Mottola David Copperfield and Leslie Wexner TI-IE WllNESS No MR SCAROLA Same objection same instruction THE WITNESS And with respect to Tommy Mottola I that was not my firm that was a separate law finn that intended to take his deposition BY MR CRITTON Vho was it that you understood was taking Mr Mottolas deposition A Searcy Denney Did you ever discuss with Mr Rothstein or anyone on his behalf the value of taJring the depositions of Trump Dershowitz former president Clinton David Copperfield and Leslie Wexner as an inducement to get Mr Epstein to settle his lawsuits MR SCAROLA You have already inquired of Mr Edwards about the communications that he Page had with Mr Epstein He has responded to those questions previously So any further questioning along those lines is entirely repetitious BY MR CRITTON Can you answer that question sir Would you like it read back MR SCAROLA Beyond what he has already responded we would object on the basis of work-product and attomey client privilege and I instruct you not to answer THE WITNESS Okay BY MR CRITTON Were you involved in any of the decision to pursue obtaining flight data from Mr Epstein Well let me strike that Were you involved in the decision to pursue flight data associated with any planes that were purportedly owned by Mr Epstein MR SCAROLA I will allow Mr Edwards to acknowledge whether he did or did not communicate about such matters with opposing counsel But beyond that would assert attorney-client and work-product privileges and instruct you not to answer Page BY MR CRITTON First my question in the broad sense Were you involved in the decision to pursue flight data associated with any planes puiportedly own by Mr Epstein MR SCAROLA My objection MR CRITTON In tenns of the discussions within your finn MR SCAROLA My objection and my instruction stands BY MR CR11TON Did you have discussions within your finn with regard to taJdng the depositions of celebrities or fa1nous people who were on purportedly on Mr Epsteins planes so that they could be deposed such that that would be an inducement to Mr Epstein to settle his lawsuit MR SCAROLA Same objection same instruction BY MR CRITTON Isnt it true Mr Edwards that in taking the deposition or in attempting to take the deposition of Donald Trump you had no information that Mr Trump had any knowledge of any female having that is underage female ever having been on Page Mr Epsteins plane and been and having been assaulted by him MR SCAROLA What Mr Edwards mew or didnt know in connection with this prosecution of pending claims is protected by a privilege I instruct him not to answer BY MR CRITTON Mr Edwards did you know Officer Recarey I mean I know you have meet him now because you have seen him at his deposition correct A Correct Did you ever meet with did you ever meet Mr or Officer Recarey at any time prior to his deposition in person A No Have you ever spoken with Officer Recarey at any time prior to his deposition by phone or otherwise A Yes Okay And what context were you speaking with Officer Recarey THE WI1NESS Answer BY MR CRITTON Well first of all let me withdraw that Question Excuse me On how many occasions have Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthia hopklns Electronically signed by cynthia hopkins Electronlcally signed by cynthia hopkins Page you spoken with Officer Recarey prior to his deposition A One time And when was that A What was the pwpose of the let me strike that Did you initiate the conversation or did he a THE WITNESS Answer MR SCAROLA You can answer that THE W11NESS I did BY:MR CRITTON Okay What was the purpose of your conversation MR SCAROLA To the extent that the purpose of your conversation was unrelated to any pending legal matter including in particular the claims against Mr Epstein you may answer To the extent that it had anything at all to do with Mr Epstein you should not respond on the basis of privilege THE WITNESS Privilege BYfvlR CRITTON Did you ever speak with Chief Reiter at any time well let me strike that You were not Page at his deposition were you A No Okay Have you ever spoken with Chief Reiter at any time for any pui:pose as it relates to Mr Epstein THE WITNESS Answer MR SCAROLA Only to the extent that we11 you asked specifically whether the conversation related to Epstein TifE WITNESS Did the conversation occur is the question MR SCAROLA Relating to Epstein Read the question back if you would please MR CRITTON Let me rephrase it MR SCAROLA Okay BY MR CRlTION With regard to Chief Reiter have you ever spoken with Chief Reiter or now fonner Chief Reiter from the Palm Beach Police Department for any reason MR SCAROLA You can answer the for any reason part THE WITNESS No BY MR CRITTON Have y0u ever testified in a irrand iurv Page proceeding relating to any matter during the year or MR SCAROLA You may answer THE WITNESS No BY MR CRITTON Did Jane Doe ever come let me strike that Did Jane Doe ever come to your finn the RRA finn for any reason A Yes On how many occasions did she come to your firm to RRA A I believe one time In addition to I assume you met with her on that oceasion A Right Was anyone else present A I don believe so Did L.M ever come to your firm at RRA A No Did E.W ever come to your firm at RRA A Yes On how many occasions A One time Did anyone meet with her other than yourself Page A Yes Who was present A Bi11 Berger Did any RRA lawyer ever have an occasion to meet with Jane Doe at at a location other than your office that is did you ever request that some other lawyer meet with her Jane Doe for a specific reason Dont want to know the reason just whether another lavryer met with her A No Did any other RRA lawyer meet with L.M separate at any time A No Did any other lawyer ever met with E.W separate and apart from the one meeting that you had with Bill Berger and yourself in Im sorry did A Were talking always about the time period at RRA I understand that Correct Did any lawyer from RRA ever meet with E.W separate from the single occasion that you and Mr Berger met with her at RRAs office A No Did did you ever have any type of Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthia hopklns Electronically signed by cynthla hopktns Electronically signed by cynthla hopklns Page conunication and by that I mean either a conversation or any writing with Mr Scott Rothstein about the value of the ofthe Jeffrey Fpstein cases MR SCAROIA You can answer yes or no THE Wl1NESS No BY MR CRITTON Did you ever have a conversation or communication where Scott Rothstein was present and the value of the Epstein cases was discussed A No Did you ever have a conversation with other attorneys at RRA regarding the value of the of the Epstein cases that you had A Yes 1s Okay With whom A Russell Adler Bill Berger I believe thats From from your observations when you were at RRA did it appear that certain individuals had access to Mr Rothstein that is other lawyers in the firm had access to him A It appeared to me like nobody had access to him In the particular instance that you got Page called up to his office Mr Adler was present along with Mr Rothstein and either Mr Nurik or somebody else who was on the phone correct We already established that A Correct From your observations and or your conversations with Mr Adler did you get the impression that Mr Adler could have or would have access to Mr Rothstein MR SCAROLA By that I assume you mean wifettered access MR CRITTON No,just easy access Unfettered suggests someone can walk in and out of the office and you already told me it was a compound Let me reask my question BY MR CRITION From what Mr Adler told you if you had a conversation with Mr Adler about a particular whether it was an Epstein case or another case was it your understanding that Mr Adler had regular some form of regular communication with Mr Rothstein A No Okay Did you understand that he didnt have any communication with Mr Rothstein or did you Page not just did you just not have an W1derstanding A I had an understanding Okay What was your widerstanding and what was it based on A Based on numerous conversations with Russell Adler that even he had a very difficult time gaining access to Scott Rothstein for any reason Did Mr Adler did you ever ask Mr Adler to pass on infonnation to Mr Rothstein about the Epstein cases A No Other than Mr Jenne who would make I think you indicated earlier on eight to ten occasions ask you about the Rothstein I am sorry asked you about the Epstein cases did any other person inquire on a somewhat regular basis or even an irregular basis as to the status of the Epstein cases A Yes Who MR SCAROLA Again assume youre talking about persons within the firm MR CRITTON Correct Im back to only within RRA You understood that didnt you Mr Edwards Page THE WITNESS No I didnt I thought you meant anybody BY MR CRITTON Okay Then I am back within RRA because I had asked you about Mr Jenne A Gotit So I wouldnt go out I want to stay within the firm Did anyone ask you or inquire of you about the status of the RRA cases it was either a lawyer or an investigator within the firm A Maybe but but none that I can really picture as somebody who would do it regularly lfl was talking in some lawyers office about any case or any issue there were times where I remember generally how is this specific case going or that specific case and at times it was Jeffrey Epstein case With regard to Mr Jenne what did you understand with regard to what his position was in the firm A Something to do with the investigative department Okay What did you understand about Mr Jennes background Let me strike that Were you a State Attorneys when Mr Jenne was a Broward County Sheriff Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopkins Electronically signed by cynthla hopkins Electronically signed by cynthla hopklns Page A I believe so Were you still a State Attorney when Mr Jenne was indicted and then eventually ended up A No Were you in private practice at that fl A Correct But you lived then in Broward County so you followed the developments of Mr Jennes downfall in becoming a convicted felon A I was aware All right Was Mr Jenne would it be a correct statement that Mr Jenne and Mr Fisten and Mr Roberts were all at the RRA firm when you started in April of09 A I dont believe so Which one was there when you started When I say there was already employed by RRA when you started A I am not sure if any of the three were there but perhaps all of them were there All you know is at some point you came to be involved with them as investigators A Correct Page AIi right With regard to Mr Jenne was his office on the same floor as yours A No Where was his office in any way near Mr Rothsteins MR SCAROLA What does any way near Mr Rothsteins mean MR CRITTON Same floor a THE WITNESS No BY MR CRITTON Did it appear to you that well let me strike that You said that Mr Jenne had something to do with investigation correct A Correct Okay Did he ever describe for you what he did for the finn A No And I think you said did you say what his title was A I didnt know his title I dont know what his title is now Did you ever ask Mr Jenne why he was asking you questions about the Epstein case or engaging you in a dialogue regarding the Epstein cases Page A No Did you ever find it strange that Mr Jenne was asking you questions about the Epstein cases A No Did you ever ask Russell Adler as to why Mr Jenne would be asking you questions about the Epstein cases A No And I think you told me earlier but I may be MOng so I want to clear this up I dont want to be repetitious here Did Mr MR SCAROLA When did you change your mind about that lvlR CRITTON Earlier BY MR CRITTON Did Mr Jenne did you ever direct Mr Jenne to do any investigation on the Epstein cases MR SCAROLA Objection work-product BY 1R CRITTON Did Mr Jenne ever do any investigation on the Epstein files MR SCAROLA Objection work-product Page BY MR CRITTON Did Mr were you aware that Mr Jenne was attempting to shop the Epstein cases to investors during the time you were at the RRA finn MR SCAROLA Objection assumes facts TIIE WI1NESS No MR SCAROLA Thats all right BY MR CRITTON Do you know Bill Scherer Attorney Bill Scherer A No I lmow of rum You are aware that he has a pending lawsuit against various individuals including 1D Bank and other Defendants on behalf of various investors is that a fair statement A I remember when that first came out I have not followed it I dont lmow if its active if its still pending or what the status is at all But I do remember a lawsuit being filed on behalf of somebody against Scott Rothstein and others All right And do you remember its within Paragraph of the complaint its a A Of Of Im sorry of Exhibit No And it states Fort Lauderdale attorney William Scherer Pages to PROSE COURT REPORTING AGENCY INC Electronk:allY signed by GYf thla hopkins Electronically signed by cynthla hopklns Electronically signed by cynthla hopklns Page represents multiple Rothstein related investors He indicated in an article that RR.A slash Rothstein had used the Epstein ploy as a showpiece as a showpiece as bait Thats and the quote is Epstein ploy as a showpiece as bait 1bats the way he raised all the money He would use cases as bait for luring investors into fictional cases All the cases he allegedly structured were fictional I dont believe there was a real one there Okay Ifl asked you to assume that that quote is accurate from Mr Scherer would it be a correct would it be a correct statement well let me strike that Were you aware that Rothstein and other individuals were using the Epstein ploy that is the Epstein cases in order to as bait in order to raise money for for the firm and Mr Rothstein MR SCAROLA I am going to object to the form of the question but you can certainly answer it THE WITNESS Okay I am going to answer it to the extent that I understand it No I was not aware that the Epstein cases were being used as a showpiece as bait But you are also Page asked me to assume that the statement that you have injected as Paragraph of the complaint is true and it begins with or ends with I dont believe there was a real one in there taks speaking as to all the cases And you know and I know that that statement is absolutely false in that you know each and every one of the claims that have been asserted against lfr Epstein related to his molestation of children they are all true including the three that I have against lfr Epstein So if youre asking me to assume that this is it true no I did not know that they were being used for anything BY MR CRITTON Okay Well as to whether lfr Scherer was aware as to whether there were three pending cases or he assumed that they were all just made-up cases neither you nor I know what he was thinking correct A Yeah I dont know All right With regard to the Epstein ploy with regard to Epstein cases were you aware that Scott Rothstein was trying to market Epstein cases that is three three cases that existed Page A No Okay Were you aware that Scott Rothstein had represented to other individuals that he had multiple other cases multiple other Jane Does which he was trying to market to investors A No Were you aware that do you have any knowledge that Ken let me strike that Were you aware that Ken Jenne was attempting to market or shop non-existent Epstein cases to investors A I wasnt aware then nor am I aware of that now so no Do you have any knowledge that Mr Fisten and/or Mr Jenne would cart boxes of Epstein related materials that is existing Epstein related materials relating to Jane Doe and show those to other investors A Do I have knowledge that somebody carted Yeah are you aware that Mr Fisten or do you have any knowledge that Mr Fisten brought boxes of Epstein-related materials to show perspective investors A No MR SCAROLA Objection assumes Asswnes Page facts not in evidence no proper predicate BY MR CRITTON Do you have any knowledge that Mr Jenne either directly or directed someone else to bring boxes of Epstein-related materials to show investors MR SCAROLA Objection assumes facts not in evidence no proper predicate THE WITNESS No BY MR CRITTON If based on your earlier testimony if there were boxes of Epstein materials on existing cases Jane Doe L.M and E.W again ifl understood your testimony that information would have been available someplace in the firm and someone who had access to the room could have grabbed those files or taken those files and done whatever they wanted to them with them and then brought them back for storage correct and you wouldnt know A As is the case with every case in every law firm in America yes With regard to the three cases that you have now does any law finn other than your current firm which is Fanner Jaffe Pages to PROSE COURT REPORTING AGENCY INC Electronlca!Jy signed by cynthla hopklns Electronically signed by cynthia hopklns Electronically signed by cynthla hopkins 1l Page A Weissing Or RRA Mr Howell or Mr Cassel have any interest in those cases A No At any time let 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 a 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 WlTNESS No BY MR CRIITON 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 Rodriguez and that he apparently was trying to sell to the cooperating witness MR SCAROLA I am going to instruct you not to answer any question about anything that you may have done in connection with the fulfillment of your responsibilities as counsel for the Plaintiffs in the three pending cases BY MR CRITTON 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 court to obtain a coov of the of Page the information that is held by the FBI which would include the pamphlet and the yel1ow the pamphlet and the yel1ow 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 Im not sure If you show me my motion can tell you whether I drafted it or not HaveyouH 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 motion 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 ifa response has been filed with the court or provided to you in the form of a pleading you may respond IBE WITNESS 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 CRITTON All right Well lets l1l 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 of Mr 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 IBE VIDEOGRAPHER This concludes todays Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthia hopkins Electronlcally signed by cynthla hopkins Electronically signed by cynthla hopkins ff76c2ea 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 wil1 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 MR CRITTON Bye MR SCAROLA Bye Witness excused Deposition was concluded Page CERTIFlCATE OF OATH THE STATE OF FLORIDA COUNlY OF PALM BEACH the undersigned authority certify that Page BRADLEY EDWARDS ESQUIRE personally appeared before me and was duly sworn on the 23rd day of March IO Dated this 5th day of April Cynthia Hopkins RPR FPR Notary Public State of Florida My Commission Expires February My Commission No DD CERTIFICATE TI-IE STATE OF FLORIDA COUNTY OF PALM BEACH I Cynthia Hopkins Registered Professional Reporter Florida Professional Reporter and Notary Public in and for the State of Florida al large do hereby certify thal I was authorized lo and did report said deposition in stenotype and that the foregoing pages are a true and correot ITilnscrlpti-On ofrny shorthand notes of said deposition I funoo ce-nify tl,at aid depD1ition was 1aken at the time and place heteinabove set forth and that the taking of said deposition was commenced and completed as hereinabove set out I further cenify that I am not attorney or counsel of any of the parties nor am I a relative or employee of ny attorney or counsel of pany connected wilh the action nor am I financially inlere ted in action The foregoing cenifica1ion of this transcript does not apply to nny reproduction of the same by any means unless under the direct control and/or direi:tion of the certifying reporter Dated this Sth day of April I thia Hopkins RPFl Page Pages to PROSE COURT REPORTING AGENCY INC Electronically signed by cynthla hopkins Electronk:ally signed by cynthla hopkin Electronically signed by cynthla hopJ ins lt ll lB l9 DATE Apri TO BRADU;v EDWARDS J;SQO/Rll c/oJod ScarolA SEAJ!.CV DENNEY SCAJlOLA aARNlfARl SHJlLBY P.A Palm Loi.co Bwlcvml Palm Beach l10rida JJ IN RE llj ffl,in Rolhsleio CASBNQ SO XMB AG Pr..st l:e tl!M on Tuo ay Uie or Moreb iw g1ve OUrdq,a,ilion in Ille rolcrred 1cr AUhll time tl did no1 w1f,,-csi3Nrure rt now necmarydlillyou Uf dq,ooitian Ai preOOll i io the tmn riix will be fumiibedtoyouthrollghyoor.-..d Pl Gor lld the following 1n1c1iMs carefidl Al the end of tllc lnll1S0ipt you will ind emta sh cl A you rwl Oil dcpotilicn any chlni Offlfflicns that you wbh 10,nake riloold be llOled en lhotmilaibcet cioog JOiCN lute mtmberof aid ONng1 NOT wrilc he ln Oripl iuaelf you have read the lr an6 IIOled any ebonies be lo rign anddatethe01t i.t:ldre1um poec3to Ir JIOU do no1 _i and sign the depa,ilioo wilhii a muooabl timo.thc orltin,,I which hi already tioo ornl"docl me orocrmg onancy may be filed will 1hc Clcrl ofthc Cou lflOll wiih towai l0llf signatutO 225ign OOf name the blank bottom or this ltw lid morn us Cynthia Hoplcino JtPR fPR I do he,ebywaive my sig,,otutc BRADLEY EDWAADS ESQUIRB CER TI FICA TE THE STATE 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 In re UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION Case No Chapter ROTHSTEIN ROSENFELDT ADLER P.A Debtor RULE EXAMINATION OF SCOTT ROTHSTEIN Taken on behalf of the Chapter Trustee DATE TAKEN December TIME PLACE a.rn p.m James Lawrence King Federal Justice Building N.E Fourth Street Courtroom Miami Florida Examination of the witness taken before Michele Savoy Registered Professional Reporter united Reporting Irie S.E Third Avenue Fort Lauderdale Florida United Reporting Inc Page EXHIBIT the Ponzi scheme and then second so we can do this quicker if they knew of the Ponzi scheme even though they may not have known what was going on A Let me just you got to clarify I dont mean to be a pain in the butt on this but you have to clarify Ponzi scheme for me Because again you have multiple levels of criminal activity in the law firm that you may not think was related to the Ponzi scheme but which youll see on further investigation was related to the Ponzi scheme So you want to know what my belief is as to whether or not they were involved at any level Well how about if I change the question then and say that if they were involved in illegal activity at the firm A Fair enough Okay A Yes sir We will go back and well talk about whether or not that any of these people knew and then third what they would have done had they known A Okay So first question is this pertains to lawyers that participated United Reporting Inc Page Ii A A A A A A A A A A A A Lawrence Barksi No Bil.l Berger No Ri.1ey Ciru1nick No Jodi Cohen No Pedro Dijols No Ben Oishowitz No Brad Edwards No Gary Farmer No Mark Fiatos No Julio Gonzalez No Seth Lerhm.an No Arthur Neiwirth On the periphery I believe he had some Page It knowledge of illegal activity just because of things United Reporting inc he was working on but he was not directly involved A A A A Okay You mention Mr Nurik Barry Stone No Osvaldo Torres No Weissing Matthew Weissing No Richard Wolfe No So thats a fairly substantial number of lawyers that worked at the firm that didnt know a.bout the Ponzi scheme A I mean there was a whole section Of those involved did any of those names that I just mentioned to you excepting who you identified as being possibly Mr Neiwirth did they have any knowledge that you were involved in any illegal activity Forget the term Ponzi scheme A To my knowledge no Okay Did you believe those were honest lawyers A For the most part yes Okay Each of them had obligations with respect to trust account maintenance under the rules United Reporting Inc Page i I i of the F1orida Bar youre A Do you know that qen becau you were a F1orida 1awyer right Correct Did any of those lawyers know about the trust account defalcations that existed at the firm A Certain people had I believe had information to know but to my knowledge as I sit here today I dont know who knew out of these people that you just read to me on those When you say can you tell me what you mean when you say they had information to know A Well for example with Mr Neiwirth there were times when we would ask for trust checks and they were delayed for a significant period of time As a lawyer you know that there should be no delay in getting a trust check Irene Stay had a standing order which I believe was it would take up to days to get a trust check And that was to facilitate moving the money in and out of the trust account So youre saying that it was a red flag as an example for Mr Neiw rth A Thats my opinion yes Okay You never had conversations with United Reporting Inc Page him where you admitted to him that you were engaged in any illegal activity did you A No Okay Kith respect to the lawyers who were a1ready identified as not being complicit in any of the crimes or having knowledge of it do you have any understanding or belief as to for instance well take Mr Berger Had he learned of th illegal activity what do you believe he would have dcne A I believe he would have reported it And how about with respect to trust account defalcations it A A A A I believe Bill Berger would have reported Would Mr Barski have reported it Yes Illegal activity I believe so Trust account defalcations I believe so How about Cirulnick would he have reported illegal activity A I dont know if he would have reported it He would have gone to Lippman and then how Lippman United Reporting Inc Page ii would have reacted is your guess How about Jodi Cohen Do you believe she would have reported it A She probably would have gone to Lippman also They both meaning Cirulnick and Jodi worked for Lippman A A Yes Okay And understand that is just my judgment call knowing them as I knew them I dont know that for certain Youre asking me to speculate Pedro Oijols if he knew of the illegal activity A He would have reported it And if he had learned of the trust account defalcations he would have reported it A Yes How about Ben Dishowitz Would he have reported illegal activity A issues A Yes And same with respect to trust account Yes United Reporting Inc Page i Brad Edwards would he have reported illegal activity A I dont know Would he have reported trust account defalcations A I dont know How about Gary Fanner would he have reported it A A A A A A A Yes Yes as to both questions Yes Mark Fistos Yes to both questions Julio Gonzalaz Yes as to both Seth Lehrman Probably Mr Nurik Absolutely MR NURIK I would have shot you Probably BY MR LICHTMAN A Barry Stone Yes Absolutely Osvaldo Torres United Reporting Inc Page I I yield to Mr Lichtman at this time Thank you FURTHER EXAMINATION BY MR LICHTMAN I just have a few quick points A Okay Earlier in my discussion with you you mentioned some of the lawyers at RRA who knew about or were complicit in varying degrees in the commission of the Ponzi scheme A A A A In commission of illegal activity Illegal activity Yes Yes You mentioned Mr Adler Yes What was Mr Adler role Several Let me give you his key roles and see if they lead to other things Probably the most significant thing he did for us in helping perpetuate and really save the Ponzi from exploding was the New York hedge funds wanted to come down and do additional due diligence on our investment United Reporting Inc Page i There were back and forth between me and the hedge funds and me and the Banyan people trying to facilitate the due diligence they wanted to do What ended up happening was Brian Jedwab who was probably one of the more I guess observant people in that group decided it would be a good idea to give him and probably Gil Colter also also in the category of more observant people within Murray Huberfelds groups decided that this the deal flow that we were saying existed was suspicious highly unusual possibly impossible things of that nature is what we were hearing from up north and back to us And we needed to put on a dog and pony show for them if this thing were going to survive Because if we cant show the deal flow one of two things is going to happen Either they re just going to cut us off or theyre going to cut us off and the thing is going to explode Obviously we couldn allow that to happen So initially what happened was they just wanted to talk to some of our referring groups So I sent out an email to the entire firm I think it was the entire firm at least to the shareholders and partners But it may have been to the all the United Reporting Inc Page lawyers saying We need people that refer us labor/employment cases to answer a couple of simple questions And I think I outlined the questions and specifically said These are the questions that are going to be asked Do you refer us business labor employment business and are you happy Then it got to the point where they agreed to that Then they unagreed to that And it was clear that they wanted to come down After a certain point in time it became clear that the due diligence was going beyond that Before that when I sent out the firm-wide email I had gotten back a couple of people Russ had sent me people and I think Stu sent me some people Maybe a couple other people sent me possible referring lawyers who would vouch for us When it got to the point that that then went by the wayside because it became clear through speaking to Mr Preve and speaking to Jack Simony who was for lack of a better term one of our confidants one of the people who we were closer to at the Murray Huberfeld group of hedge funds that they wanted to do significant due diligence and actually meet with the people that were sending us cases that of course was a huge problem for us United Reporting Inc Page I I because no one was sending us cases I went to Russ and so and I dont recall going to Lippman But to Russ and to Stu And said Listen We need to get some people together These guys want to come down The hedge funds are going to cut us off This will destroy us We need to get some people together Russ jumped right into the breach and said I got some people I said okay Are these people you trust Yes All right This is what were going to need them to do and I laid it out for him I told him very specifically We need them to say that they sent us in the hundreds of cases on a monthly basis and And that would have been an untrue statement oorrect A Yeah Everything that Im telling you right now we they needed to lie to A Okay And these are lawyers that youre alluding Yes Outside of the firm United Reporting Inc Page A Yeah Ill tell you who they are Yes A These people needed to lie to the hedge fund due diligence people to substantiate our deal flow Thats the conversation Russ and I had We had to specifically say they sent us hundreds of cases which would have been false They needed to say that these cases were big dollar cases in the millions of dollars which was false And they needed to say that we sent them huge dollar referral fees also false Huge dollars meaning hundreds of thousands if not million of dollars in referral feels So there were three main false components What Russ did to find the people I dont know I sure he had conversations with them because they needed to be instructed on which lies to tell and how to handle this And indeed lawyers stepped into the role to perform for you and lie correct A legal Yes What ended up happening was I got one legal group to do it mutual friends of United Reporting Inc Page I UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASENO9-60S U.S.C u.s.c u.s.c u.s.c U.S.C U.S.C U.S.C a U.S.C a UNITED STA TES OF AMERICA Plaintiff SCOTT ROTHSTEIN Defendant INFORMATION FILED by o.c DEC STEVEN LARIMORE CLERK DIST CT ofF FT lAUD The United States Attorney charges that at all times relevant to this lnfonnation GENERAL ALLEGATIONS Scott Rothstein was an attorney admitted to practice law in Florida Defendant Rothstein was the ChiefExecutive Officer CEO and Chairman ofRothstein Rosenfeldt and Adler P.A Rothstein Rosenfeldt and Adler P.A was a law firm with offices located at East Las Olas Boulevard Fort Lauderdale Florida and elsewhere The law firm employed approximately seventy attorneys and engaged in the practice of law involving a wide range of specialties including labor and employment law EXHIBIT COUNT Racketeering Conspiracy U.S.C The General Allegations of this Infonnation are realleged and expressly incorporated herein as if set forth in full THE ENTERPRISE The law firm Rothstein Rosenfeldt and Adler P.A hereinafter referred to as RRA was a legal entity organized under the laws of the State of Florida and constituted an Enterprise as that term is defined in Title United States Code Section The Enterprise engaged in and the activities of which affected interstate and foreign commerce THE THE PATTERN OF are utilized to pay previous investors in the absence of any underlying security legitimate investment vehicle or other commodity THE ROLES AND RESPONSIBILITIES OF THE CONSPIRATORS The roles of the conspirators were as follows A Defendant SCOTT ROTHSTEIN was a shareholder Chairman and CEO ofRRA Through his position at RRA defendant ROTHSTEIN promoted managed and supervised the administration of the Enterprise by fraudulently inducing investors through the use of false statements documents and computer records to loan money to purported borrowers based upon fraudulent promissory notes and fictitious bridge loans and invest funds based upon anticipated pay outs from purported confidential settlement agreements which had been reached between and among certain individuals and business entities These settlement agreements were falsely presented as having been reached between putative plaintiffs in civil cases and putative defendants based upon the forbearance of civil claims in sexual harassment and/or whistle 225blower cases Other conspirators known and unknown to the United States Attorney agreed with one another and with defendant ROTHSTEIN to take actions to further the operation and success of the Ponzi scheme including presenting the aforesaid investments to potential investors as legitimate investment vehicles when in fact they were not fraudulently inducing investors to place funds into these investment vehicles by making material misstatements of facts as set forth below assuring potential investors and investors that sufficient funds existed to pay returns on these investments when in fact such funds did not exist creating and transferring funds into and from various accounts at financial institutions in order to further the unlawful scheme and realizing profits from the operation of the Ponzi scheme through the acquisition of money generated as proceeds from the scheme and through the acquisition of real and personal property MANNER AND MEANS OF THE Defendant ROTHSTEIN and other co-conspirators utilized the offices ofRRA and the offices of other co-conspirators to convince potential investors of the legitimacy and success of the law finn which enhanced the credibility of the purported investment opportunity Defendant ROTHSTEIN and other co-conspirators made false and misleading statements and omissions which were intended to fraudulently induce potential investors into purchasing the confidential settlements Defendant ROTHSTEIN and other co-conspirators made the following fraudulent representations to potential investors in order to induce them to purchase the purported settlements A That the purported settlements were highly confidential in order to protect the reputation of the company authorizing the settlement and the executives involved That the plaintiffs in the purported sexual harassment and/or whistle-blower cases preferred to settle the cases in order to avoid the emotional embarrassment of pursuing a claim in a public forum That RRA originated its own cases from reputation internal staff and outside referrals from other law firms That RRA retained a company that owned internet sites and well-placed numbers designed to attract a large volume of high quality cases That RRA rigorously screened the purported sexual harassment and/or whistle 225blower settlement agreements That RRA utilized former law enforcement personnel and employed highly sophisticated investigative methods in selecting and pursuing claims against purported defendants That RRA or other law firms pursued purported settlements with defendant companies prior to the initiation of litigation That RRA or other law firms negotiated with the purported defendant company after such company was made aware of the alleged claim by the plaintiff I That RRA or other law firms purportedly negotiated with the defendant company and reached an agreement which contained the settlement amount and the payment terms That because the purported settlements occurred prior to the initiation of litigation there was no court or governmental entity involved in the transaction That the alleged defendant companies sent by wire transfer to RRA or other law finns trust accounts the full proceeds of the purported settlements That during the settlement conference or other settlement negotiations when a purported plaintiff protested the extended payment schedule RRA or other law firms presented the purported plaintiff with the option of receiving a discounted lump sum payment from an unrelated confidential funding source That RRA or other co conspirators prepared a purported Assignment of Settlement Agreement in which the investor agreed to acquire the right to the purported settlement payments for a discounted lump swn payment made to the purported plaintiff That when RRA received the payment by the investor it immediately disbursed those funds to the purported plaintiff and That RRA made payment to the investor pursuant to the purported payment schedule set forth in the purported settlement agreement Defendant ROTHSTEIN and other co-conspirators falsely informed potential investors that funds were maintained in designated trust accounts for the benefit of the individual investor and that these funds were verified on a regular basis weekly if not more often by two independent verification sources one being an attorney and the other being an independent financial advisor hereinafter referred to independent verifiers Defendant ROTHSTEIN and other co-conspirators falsely informed potential investors that RRAs trust accounts were maintained with a well established intemationaJ banking institution in accordance with the rules and regulations of the Florida Bar and that access to balances in the trust accounts was allegedly monitored by one of the two independent verifiers Def ndant ROTHSTEIN and other co-conspirators falsely informed potential investors that due diligence would be undertaken with the following provisions A An independent verifier would be permitted to ask questions of Defendant ROTHSTEIN and/or other co-conspirators to review the opportunity and structure The independent verifier would have the opportunity to randomly review selected completed transactions to confirm the veracity of the information The independent verifier had already reviewed current transactions including wire transfers received from defendants and payments made to plaintiffs The independent verifier would have the opportunity to visit and speak with a senior banking officer at the local branch of the financial institution to confinn current trust account bank balances through bank statements provided on line and The independent verifier had the opportunity to meet with a senior banking officer to verify that the trust accounts were locked and to verify the strength of RRA financial position and relationship with the bank Defendant ROTHSTEIN and other co-conspirators established numerous trust accounts in the name of RRA in order to convince potential and current investors of the legitimacy of the confidential settlement agreements and the security of such investments Defendant ROTHSTEIN and other co-conspirators prepared and used altered bank statements purportedly issued from a well-established international financial institution to fraudulently convince potential and current investors that funds had been received from the purported defendant companies and were maintained in trust accounts In order to deceive investors defendant ROTHSTEIN and other co-conspirators created altered and/or maintained fictitious online banking information regarding the purported trust accounts which falsely reflected the amount of funds maintained in such accounts the receipt of funds wired from the alleged defendant companies and the transmission of funds by wire to the alleged plaintiffs Defendant ROTHSTEIN and other co-conspirators created false and fictitious documents including confidential settlement agreements assignment of settlement agreements and proceeds sale and transfer agreements and personal guaranties by Defendant ROTHSTEIN among other documents Defendant ROTHSTEIN and other co-conspirators facilitated the movement and transfer of funds between and among numerous trust accounts and operating accounts in order to perpetuate the scheme The movement and transfer of such funds insured that monies were available in the individual trust accounts in order to make scheduled payments to investors Defendant ROTHSTEIN and other co-conspirators made false statements to current investors in order to convince them to re-invest in additional purported confidential settlement agreements Defendant ROTHSTEIN and other co-conspirators facilitated the creation offalse and fictitious lock letters which were issued by an executive at the financial institution where the trust and operating accounts were maintained Such lock letters falsely reflected that the funds maintained in specific trust accounts would only be disbursed to specific investors Defendant ROTHSTEIN and other co-conspirators utilized funds received from investors to pay the promised return on investment to earlier investors Defendant ROTHSTEIN and other cowconspirators also initiated and conducted a scheme to defraud clients of RRA in order to perpetuate the Ponzi scheme Such clients had retained RRA to institute and file a civil lawsuit Unknown to the clients RRA settled the lawsuit and obligated the clients to pay to the defendant In order to commit the fraud and deceive the clients defendant ROTHSTEIN and other co-conspirators created a false and fraudulent court order purportedly signed by a Federal District Court Judge which falsely aUeged that the clients had prevailed in the lawsuit and were owed a udgement of approximately million The fraudulent court order also falsely stated that the defendant had transferred funds to the Cayman Islands in order to avoid paying the judgement Defendant ROTHSTEIN and other co-conspirators falsely advised the clients on several occasions that in order to recover the defendants funds they had to post bonds to be held in the RRA trust account Defendant ROTHSTEIN and other co conspirators fraudulently caused the clients to wire transfer approximately million over several years to a trust account controlled by defendant ROTI-ISTEIN purportedly to satisfy the bonds Defendant ROTHSTEIN and other co-conspirators caused the funds transmitted by the clients to be transferred to other RRA trust accounts in order to perpetuate the Ponzi scheme and to enrich those co-conspirators who were associated with the Enterprise Defendant ROTHSTEIN and other co-conspirators were questioned by the clients as to the progress of the alleged lawsuit In order to delay the return of funds to the clients defendant ROTHSTEIN fraudulently created a false Federal court order purportedly issued by a United States Magistrate Judge allegedly ordering RRA to return the transmitted funds by a later date Defendant ROTHSTEIN and other co-conspirators utilized funds obtained through the Ponzi scheme to supplement and support the operation and activities of RRA to expand RRA by the hiring of additional attorneys and support staff to fund salaries and bonuses and to acquire 1arger and more elaborate office space and equipment in order to enrich the personal wealth of persons employed by and associated with the Enterprise Defendant ROTHSTEIN and other co-conspirators utilized funds illegally obtained through the Ponzi scheme to make political contributions to local state and federal political candidates in a manner designed to conceal the true source of such funds and to circumvent state and federal laws governing the limitations and contribution of such funds Defendant ROTHSTEIN and other co-conspirators used other corporations in order to launder proceeds generated from the Ponzin scheme to conceal the source of the funds utilized to make political contributions in order to promote the Ponzi scheme Defendant ROTHSTEIN and other co-conspirators paid large bonuses to employees of RRA purportedly as an award for exemplary work Prior to the receipt of the bonuses the employees were instructed to make large contributions to political candidates in the employees names Such conduct was designed to conceal the true source of the contribution and to illegally circumvent campaign finance laws Defendant ROTHSTEIN and other co-conspirators distributed lavish gifts including exotic cars,jewelry boats loans cash and bonuses to individuals and members ofRRA in order to engender goodwill and loyalty and to create the appearance of a successful law firm Defendant ROTHSTEIN and other co-conspirators made large charitable contributions to public and private charitable institutions including hospitals and other legitimate charitable and nonprofit organizations using funds derived from the Ponzi scheme Defendant ROTHSTEIN and other co-conspirators utilized funds iHegally obtained through the Ponzi scheme to hire members of local police departments purportedly to provide security for RRA and defendant ROTHSTEINs personal residence Ponzi scheme funds were also used to provide gratuities to high ranking members of police agencies in order to curry favor with such police personnel and to deflect law enforcement scrutiny of the activities of RRA and defendant ROTHSTEIN Defendant ROTHSTEIN and other co-conspirators utilized funds obtained through the Ponzi scheme in order to purchase controlling interests in restaurants located in the Southern District of Florida Such restaurants were used in part as a mechanism to give gratuities to individuals including politicians business associates and attorneys in order to foster goodwill and loyalty as a location to solicit potential investors and as a secure location for conspiratorial meetings Defendant ROTHSTEIN and other co-conspirators associated with affluent and politically connected individuals in order to lure wealthy investors into the Ponzi scheme Defendant ROTHSTEIN and other co-conspirators associated with well known sports figures and politicians in public forums and elsewhere in order to gain greater notoriety and to create the appearance of wealth and legitimacy Such acts were calculated in part to enhance defendant ROTHSTEIN ability to solicit potential investors in the Ponzi scheme Defendant ROTHSTEIN and other co-conspirators used funds derived from the uPonzi scheme to maintain the appearance of affluence and wealth by purchasing expensive real and personal property in order to convince potential investors of the legitimacy of RRA and of the purported investment opportunities Defendant ROTHSTEIN purchased expensive real property personal property business interests vessels vehicles and other indicia of success and wealth All in violation of Title United States Code Section I COUNT2 Money Laundering Conspiracy U.S.C The General Allegations and paragraphs through of Count of the Information are realleged and incorporated herein by reference TD Bank N.A hereinafter referred to as TD Bank was a commercial bank with branch offices in thirteen states including a branch office in Weston Florida The executive offices of TD Bank were located in Portland Maine and Cherry Hill New Jersey Defendant ROTHSTEIN and RRA maintained approximately thirty-eight bank accounts at TD Bank which were utilized during the course of the Ponzi scheme Gibraltar Private Bank and Trust hereinafter referred to as Gibraltar Bank was a commercial bank with seven branch offices including a branch office in Fort Lauderdale Florida Defendant ROTHSTEIN and RRA maintained at least four bank accounts at Gibraltar Bank which were utilized during the course of the Ponzin scheme From in or about and continuing thereafter through in or about November in Broward County in the Southern District of Florida and elsewhere the defendant SCOTT ROTHSTEIN did knowingly conspire confederate and agree with persons known and unknown to the United States Attorney to commit offenses against the United States in violation of Title United States Code Sections and that is i to knowingly conduct and attempt to conduct financial transactions affecting interstate and foreign commerce which involved the proceeds of a specified unlawful activity that is mail fraud and wire fraud in violation of Title United States Code Sections and with the intent to promote the carrying on of said specified unlawful activities and that while conducting and attempting to conduct such financial transactions knew that the property involved in the financial transaction represented the proceeds of some form of unlawful activity in violation of Title United States Code Section a A i ii to knowingly conduct and attempt to conduct financial transactions affecting interstate commerce and foreign commerce which transactions involved the proceeds of specified unlawful activity that is mail fraud and wire fraud in violation of Title United States Code Sections and knowing that the transactions were designed in whole or in part to conceal and disguise the nature location source ownership and control of the proceeds of specified unlawful activity and that while conducting and attempting to conduct such financial transactions knew that the property involved in the financial transactions represented the proceeds of some form of unlawful activity in violation of Title United States Code Section a i and i to knowingly engage and attempt to engage in monetary transactions by through or to a financial institution affecting interstate and foreign commerce in criminally derived property of a value greater than which property having been derived from a specified unlawful activity that is mail fraud and wire fraud in violation of Title United States Code Sections and in violation of Title United States Code Section All in violation of Title United States Code Section COUNT3 Mail and Wire Fraud Conspiracy U.S.C I The General Allegations and paragraphs through of Count of the Information are realleged and incorporated herein by reference From in or about and continuing thereafter through in or about November in Broward County in the Southern District of Florida and elsewhere the defendan4 SCOTT ROTHSTEIN did knowingly combine conspire confederate and agree with other persons known and unknown to the United States Attorney to commit offenses against the United States in violation of Title United States Code Sections and that is i to knowingly and with intent to defraud devise and intend to devise a scheme and artifice to defraud and to obtain money and property from others by means of materially false and fraudulent pretenses representations and promises knowing that they were false and fraudulent when made and causing to be delivered certain mail matter by any private and commercial interstate carrier according to the directions thereon for the purpose of executing the scheme in violation of Title United States Code Section ii to knowingly and with intent to defraud devise and intend to devise a scheme and artifice to defraud and to obtain money and property from others by means of materially false and fraudulent pretenses representations and promises knowing that they were false and fraudulent when made and transmitting and causing to be transmitted by means of wire communications in interstate and foreign commerce certain signs signals and sounds for the pwpose of executing the scheme in violation of Title United States Code Section THE PURPOSE AND OBJECT OF THE CONSPIRACY The purpose and object of the conspiracy was to enrich defendant ROTHSTEIN and his co-conspirators by illegally obtaining money from investors and converting the investors money to their own use and benefit through the operation of the above-described Ponzi scheme All in violation of Title United States Code Section COUNTS and Wire Fraud U.S.C The General Allegations and paragraphs through of count of the Infonnation are realleged and incorporated herein by reference On or about the dates enumerated as to each count below at Broward and Miami Dade Counties in the Southern District of Florida and elsewhere the defendant SCOTT ROTHSTEIN did knowingly and with intent to defraud devise and intend to devise a scheme and arti flee to defraud and to obtain money and property from others by means of materially false and fraudulent pretenses representations and promises knowing that such pretenses representations and promises were false and fraudulent when made and for the purpose of executing the scheme transmitted and caused to be transmitted certain wire communications in interstate and foreign commerce as more particularly described below COUNT DATE WIRE COMMUNICATION December Interstate wire transfer sent from TD Bank to Gibraltar Bank October Interstate wire transfer sent to TD Bank from JP Morgan Chase All in violation of Title United States Code Sections and FORFEITURE ALLEGATIONS The allegations of this Information are realleged and by this reference fully incorporated herein for the purpose of alleging forfeitures to the United States of America of certain property in which the defendant has an interest pursuant to and a Federal Rules of Criminal Procedure Forfeiture is being sought pursuant to the provisions of Title United States Code Sections a a and a as made applicable hereto by Title United States Code Section Upon conviction of the offense of RICO Conspiracy set forth in Count of the Information the defendan SCOTT ROTHSTEIN shall forfeit to the United States the following property i Any interest acquired or maintained pursuant to Section ii Any interest in security of claim against or property or contractual rights of any kind affording a source of influence over the enterprise described in the Information which was established operated controlled and conducted pursuant to Title United States Code Section and i Any property constituting or derived from proceeds obtained directly and indirectly from racketeering activity pursuant to Title United States Code Section Upon conviction of the offense of Money Laundering Conspiracy set forth in Count of the Infonnation the defendant SCOTT ROTHSTEIN shall forfeit to the United States all property real or personal involved in or traceable to the offense which property shall include i all money and other property that was the subject of each transaction transportation transmission and transfer in violation of Section ii all commissions fees and other property constituting proceeds obtained as a result of those violations and i all property used in any manner and part to commit and to facilitate the commission of those violations Upon conviction of the offense of Conspiracy to Commit Mail Fraud and Wire Fraud and to Commit Wire Fraud as set forth in Counts and of the Information the defendant SCOTT ROTHSTEIN shall forfeit to the United States all property real or personal which constitutes or is derived from proceeds traceable to the offense The property subject to forfeiture pursuant to Title United States Code Sections a and a includes but is not limited to A A swn of money equal to in United States currency Real Properties RP RPI Castilla Isle Fort Lauderdale Florida hereafter also referred to as Defendant RP includes all buildings improvements fixtures attachments and easements found therein or thereon and is more particularly described as Lauderdale Shores Reamen Plat Lot Blk with a Folio Number of RP2 Castilla Isle Fort Lauderdale Florida hereafter also referred to as Defendant RP2 includes all buildings improvements fixtures attachments and easements found therein or thereon and is more particularly described as Lauderdale Shores Reamen Plat Lot Blk with a Folio Number of RP3 Castilla Isle Fort Lauderdale Florida hereafter also referred to as Defendant RP3 includes all buildings improvements fixtures attachments and easements found therein or thereon and is more particularly described as Lauderdale Shores Reamen Plat Lot Lot Blk with a Folio Number of RP4 Isla Bahia Drive Fort Lauderdale Florida hereafter also referred to as Defendant RP4 includes all buildings improvements fixtures attachments and easements found therein or thereon and is more particularly described as Isla Bahia Lot with a Folio Number of RPS Isla Bahia Drive Fort Lauderdale Florida hereafter also referred to as Defendant RPS includes all buildings improvements fixtures attachments and easements found therein or thereon and is more particularly described as Isla Bahia Lot with a Folio Number of RP6 SE nd Street Unit Fort Lauderdale Florida hereafter also referred to as Defendant RP6 includes that portion of the condominiwn improvements fixtures attachments and easements found therein or thereon and is more particularly described as Las Olas Place Condo Unit with a Folio Number of AN RPS Imperial Point Drive Fort Lauderdale Florida hereafter also referred to as Defendant RPS includes all buildings improvements fixtures attachments and easements found therein or thereon and is more particularly described as Imperial Point I Sec Lot Blk with a Folio Number of RP9 Castilla Isle Fort Lauderdale Florida hereafter also referred to as Defendant RP9 includes all buildings improvements fixtures attachments and easements found therein or thereon and is more particularly described as Lauderdale Shores Reamem Plat Lot Blk with a Folio Number of RP10 NW th Street Apt Plantation Florida hereafter also referred to as Defendant RP includes that portion of the condominium/townhome improvements fixtures attachments and easements found therein or thereon and is more particularly described as OPTIMA VILLAGE CONDO UNIT BLDG with a Folio Number of AC RP Garden Court Lauderdale by the Sea Florida hereafter also referred to as Defendant RPI I includes that portion of the buildings improvements fixtures attachments and easements found therein or thereon and is more particularly described as SILVER SHORES UNIT A POR of Lot BLK DESC AS TO BEG AT SECOR SAID LOT TO POB AKA UNIT MARINA VILLAGE TOWNHOMES 227GARDEN with a Folio Number of RP12 Spangler Boulevard Bay Hollywood Florida hereafter also referred to as Defendant RP12 includes all buildings improvements fixtures attachments and easements found therein or thereon and is more particularly described as HARBOR VIEW PORTION OF LOTS BLK DESC AS COMM 2S OF NE COR OF LOT ON E/L ALO S/RJW/L OF ST RD TO POB TO POB AKA BAY I PORTSIDE with a Folio Number of RP13 East Broward Boulevard Fort Lauderdale Florida hereafter also referred to as Defendant RP13 includes all buildings improvements fixtures attachments and easements found therein or thereon and is more particularly described as BEYERL HEIGHTS LOT LOT BLK with a Folio Number of RP14 Federal Highway Fort Lauderdale Florida hereafter also referred to as Defendant RP14 includes all buildings improvements fixtures attachments and easements found therein or thereon and is more particularly described as OD FOL DESC BEG INTER R/W/L ST RD TO POB with a Folio Number of RPI Las Olas Boulevard Commercial Unit Fort Lauderdale Florida hereafter also referred to as Defendant RP15 includes all portion of that condominium improvements fixtures attachments and easements found therein or thereon and is more particularly described as LAS OLAS PLACE COMM CONDO UNIT CU2 with a Folio Number of IO AP RP SE Lane Boca Raton Florida hereafter also referred to as Defendant RP includes all buildings improvements fixtures attachments and easements found therein or thereon RPl Old Dixie Highway Boca Raton Florida hereafter also referred to as Defendant RPI includes all buildings improvements fixtures attachments and easements found therein or thereon RP18 Federal Highway Boca Raton Florida hereafter also referred to as Defendant RP includes all buildings improvements fixtures attachments and easements found therein or thereon RP East Street Apartment New York New York hereafter also referred to as Defendant RPI includes all portion of that condominium improvements fixtures attachments and easements found therein or thereon RP20 Bluff Hill Cove Farm Narragansett Rhode Island hereafter also referred to as Defendant RP20 includes all buildings improvements fixtures attachments and easements found therein or thereon RP21 Bluff Hill Cove Fann Narragansett Rhode Island hereafter also referred to as Defendant RP21 includes all buildings improvements fixtures attachments and easements found therein or thereon RP22 Ave Unit Brooklyn NY hereafter also referred to as Defendant RP22 includes all portion of that condominium improvements fixtures attachments and easements found therein or thereon RP23 11th St NY NY hereafter also referred to as Defendant RP23 includes all portion of that condominium improvements fixtures attachments and easements found therein or thereon and RP24 Versace Mansion/Casa Casuarina Ownership hereafter also referred to as Defendant RP24 includes all buildings improvements fixtures attachments and easements found therein or thereon Vehicles and Vessels VV VVI Red Ferrari Coupe VIN VV2 White Bentley Convertible VIN VV3 Yellow McLaren Mercedes Benz SLR VIN VV4 Black Limousine Ford Expedition VIN VV5 Red Ferrari Spider VIN VV6 Silver Rolls Royce Convertible VIN VV7 Silver Hummer HI VIN VV8 Cadillac Escalade VIN VV9 Red Convertible Corvette VIN VVIO Black Bugatti Veyron EB VIN VV Blue Rolls Royce Drophead Convertible VIN SCA2D68528UX VVI Warren Hull VV18 Aquariva Hull VV19 Yamaha Jet Ski Hull VV20 Yamaha VS Hull VV2 Yamaha VS Hull VV22 Sea Ray Sundancer VV23 Yamaha Jet Ski Hull and VV White Lamborghini lp-670sv VIN ZHWBU8AHXALA03837 Tangibles Tl pieces of jewelry watches necklaces and earrings seized on or about Monday November from the residence of Scott and Kimberly Rothstein T2 DuPont Lighters seized on or about Monday November from the residence of Scott and Kimberly Rothstein T3 pieces sports memorabilia seized on or about Monday November from the residence of Scott and Kimberly Rothstein T4 in United States currency seized on or about Monday November from the residence of Scott and Kimberly Rothstein TS in United States currency seized on about Wednesday November from the office of Scott Rothstein at the law firm of Rothstein Rosenfeldt and Adler P.A օsD g?R?ޢ a??Nv/Dx??N lwc ǿ??HJ 9w V?D P?U?/o A?mr??2?Kd pJ??w O1 Hu U?S jZ T?u?it 1r z?h Xȴv 6?AD J?hN?op a t?G v9 k3Lt FrQ 3?;Zb?Fh P5 Wf l?N??X QL k??ñ hFye?b!?V??n Nˆ?u Sĕˮ?y A?K 2?dv Y5߃G M??D C??GYKp?_ a vaiFK?u㭔 A?Hѹ K?e Ak?Isc 8I7G 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Q?",R?dL fd bR c??ו w?ѡCl?R?q??WC bzB uB Pg Lպ?q Ex giQ o?e r6?u rH DEo Ԟ?Ms L?Ҫ Łh 3X?A 1H?HWª?C dJ ǍC?ƺF kh tql??ZJlH A?ON Y?L?ʓ?2m qЉs m?e H??f Hf S??W ײ?NC r?D5M Z?ߛ GG q??AIi?ض ϲ?l??Qw Ne h??i Ty N2S Hw Ԋ?hѹZg E?J0t E䊸 Q?S?ks lR IQ3?t i ɀ?CQ rh??W B)k XW?B i i aP vP M?)p P?IU q?M v?j o,?Nc?T N?J ad?s IQ?Fl v?ҧ lZ?W Gi SBgP Қm Ȗ?YY ZH XLg퉙7NK??hӸ?GP X?q D?BxTeSa Qחś v?rb??вZ7?R t?7p Aԝ?4 d?f A 4ۍmʉoy??Ģ i JN xE EM rho l?bЎ ay F,l J6 p?D T?W An A?.aa c?Q m?b L?L?g Ս?c I?vg ԷJ?b xY izh?R j?y Yƞ Ҳw kv??r i R?ݛ9 yB?W pga??W dh d?i?ұ In?;)pk T?u?Ɗ gYc?w l?q 6E B?c A S?o ڳK?5CN ɖv 4?ANs?;v ջ?N?wp q??o I UM"9 k??e qhhp?/?1 k?l W??n G9w Yg яE Yȉ??sv n/F ae bs Iə r?Kg G??we?2AI y?OT _B qq??u AI?a3 r??j a CD?1 Xe WG??:l??X?IV xC ƀo Bk 9r S?X?F 6q HR wIs?j Hr??Tm?ȳ?(B Υ9?v a P?u ć8 NH?o M?q??(cϢ Te?ly C?B?Vi K?P W?Z sSL Uj 1P vvJ kY b?i xը Lh?A T?d3 nN Q?DGޟ1g?1??ʳj 6lh ƓP?8 ϯ?z E?hc RݖR?h qL Ec WҮߵ?X?M?g L?Cy Y?x 0?Xx c??GTh W?RƼ?Nj?42D?Β A?Anr0g?ئ,e?mc Iq??h bJշ a o?i J??A D?c R9 X?ԽR h?æ z?n I g8 hӼ I l?P N?b Lw 㿅fTy wI y?ڹ6 vɃ c??t??OC?r?Y i Zt e??es8?Yr uś3 ҝ6 t6?x?M?L tOU?SUt?d ҳY q?lD x8LW?F?Hc Xp y?E?t G??V??Cv?g x?v?Nq A s5u l9 v6 Co fW _7 8??CzfEm??b?ސ ݩ?a Yс se QѴ vt K0K Y?Z Nx?c zi A0 f?7Ԛb ED a kN L??bh P?8X0?CŦ?MGP m?Z0?Wl??n I?m?ݼ pҠ ߞ?n??b s??a?h n?Ѣ x?p F?u m?mz vT o??T?y f?Y?5i?T Nץ Ȍ?qf1a c?ٺ 9o?i XK 2t I G??M kR Ouw C?q t?W?wi l??m l??g 3n??ty i cr?4 i??Q v?6L N?w wi GK ߥ??yopq EBL Ψ??v i 4?os Ts Ay SM ÖPs I??l w"Օ P??z A z?zz?K j?3珨 O?b?f Zt0 ڊ앸 j?c Rk4 Bv!o uW?뱶 劖sSן??d??Ys Xk OTc S??q oc BP B?61C?xnQ WD4??F qWşzX Q??O lQiT z?UC pV of?FT(??ߘ kvm Lں E:Į??X?Yj?D?a?a fj?e qb3 Ts?p?I v?t?3R?t ht4h HD??l q?q aQ yaKaL??a?wP Ӑ,?倌 ޒx Wi FD2??Es?u V3 l??7wU w_ z?P ԁXM?iQ)U庿l Igx q?I Rq9þb P?i Ġo1 AD?3 A R?S5 F_ e9 p?P o?s?q oIې l?F 7f xB?8?I 0qJ Iz YĬ?R??C E??K t?Y N?yǺ e理 X?íe??A dU C2o E?M i I A?U lv?B ͺ?y?S Mʒ CqI T6 in American Express Gift Cards to the attention of Scott Rothstein obtained from UPS on or about November T7 in American Express Gift Cards to the attention of Scott Rothstein obtained from UPS on or about November TS additional watches being voluntarily turned over to the United States and T9 Guitar collection of Scott Rothstein located at the residence of Scott and Kimberley Rothstein valued between and Bank Accounts BA BAI Fidelity Investments Stock Account in the name of Scott Rothstein valued at approximately BA2 Gibraltar Bank account in the approximate amount of BA3 Gibraltar Bank account BA4 Gibraltar Bank account BA5 Gibraltar Bank account in the approximate amount of in the approximate amount of in the approximate amount of BA6 Bank account at Banque Populaire Morocco in the name of Scott Rothstein in the approximate amount of BA Bank account at Banque Populaire Morocco in the name of Ahnick Khalid up to the amount of BAS Bank account at Banque Populaire Morocco in the name of Steve Caputi up to the amount of BA9 Toronto Dominion Bank N.A account in the name of Rothstein Rosenfeldt Adler P.A which on or about November contained the approximate amount of BAl0 Toronto Dominion Bank N.A account in the name of Rothstein Rosenfeldt Adler P.A which on or about November contained the approximate amount of BAll Toronto Dominion Bank N.A account in the name of Rothstein Rosenfeldt Adler P.A Attorney Trust Account which on or about November contained the approximate amount of BA12 Toronto Dominion Bank N.A accoW1t in the name of DJB Financial Holding which on or about November contained the approximate amount of BA13 Toronto Dominion Bank N.A account the name of RRA Sports and Entertainment LLC which on or about November contained the approximate amount of BA Toronto Dominion Bank N.A account in the name of RRA Goal Line Management LLC which on or about November contained the approximate amount of BA15 Toronto Dominion Bank N.A account in the name of Rothstein Rosenfeldt Adler P.A which on or about November contained the approximate amount of Business Interests Bl Bil Stock certificates ifissued or the beneficial interest in such shares of shares of capital stock in Gibraltar Private Bank Trust a federally chartered stock savings association pWChased in or about September by GBPT LLC a Delaware Limited Liability Company by its manager Bahia Property Management LLC a Delaware Limited Liability Company by its co-manager Scott Rothstein BI2 Scott Rothsteins equity interest in QTask Scott Rothsteins equity interest in Broward Bank of Commerce Bl4 Scott Rothsteins equity interest in Bova Ristorante BIS Scott Rothsteins equity interest in Bova Cucina Scott Rothsteins equity interest in Bova Prime Scott Rothsteins equity interest in Cafe Iguana Pembroke Pines Florida Scott Rothsteins equity interest in Cart Shield USA LLC Scott Rothstein equity interest in Renato Watches Scott Rothsteins equity interest in Edify LLC Bll I Scott Rothsteins equity interest in Georgio Vodka Scott Rothsteins equity interest in Sea Club Scott Rothsteins equity interest in North Star Mortgage Bl14 Scott Rothsteins equity interest in Kip Hunter Marketing BllS Scott Rothsteins equity interest in RRA Sports and Entertainment LLC Scott Rothsteins equity interest in Versace Mansion/Casa Casuarina including year Operating Agreement with ten year options Scott Rothsteins equity interest and licensing rights in Alternative Biofuel Company Scott Rothsteins equity interest in RRA Goal Line Management Scott Rothsteins equity interest in Iron Street Management LLC Scott Rothsteins equity interest in and loan to Africat Equity IG Decide Scott Rothsteins equity interest in and rents derived from Dixie LLC Scott Rothsteins equity interest in and rents derived from Federal LLC Promissory Note by Uniglobe in favor of Scott Rothstein and BI24 All equity interest held by or on behalf of Scott Rothstein in the following corporations and entities a Bahia LLC GC LLC LOP LLC BR LLC LLC Spangler LLC Broward LLC Dixie LLC I Federal LLC IP LLC LLC I AANGLLC AAMGl LLC AAMM Holdings ABT Investments LLC Advanced Solutions Bahia Property Management LLC Boat Management LLC BOSM Holdings LLC BOVA Prime LLC BOVA Restaurant Group LLC The BOVA Group LLC BOVA Smoke LLC BOVCU LLC BOVRILLC Broward Financial Holdings Inc aa CI07 LLC ab CI08 LLC ac CI16LLC ad CI27 LLC ae CSU LLC af Management Investment LLC ag Management and Investment LLC ah DJB Financial Holdings LLC YMMULLC at I ull Circle Fort Lauderdale LLC aj I ull Circle Trademark Holdings LLC ale I 3HW1 LLC al DNL GEAH LLC am I LK3 LLC an I Management LLC ao I fRCLC ap fudah LLC aq endall Sports Bar ar I ip Hunter Marketing LLC as I Servicing LLC at RI LLC au RI LLC av JS Holdings LLC aw RCH LLC ax Adventures LLC ay Ks Wild Ride Ltd az lothstein Family Foundation ha lRA Consulting Inc bb mA Goal Line Management LLC be lRA Sports and Entertainment LLC bd be RSA 1h Street LLC bf RW Collections LLC bg KEALLC bh Scorh LLC bi Tipp LLC bj VOS LLC bk The Walter Family LLC bl Walter Industries LLC bm WPBRS LLC bn WAWW bo WAWW2LLC bp WAWW3LLC bq WAWW4LLC br WAWWSLLC bs WAWW6LLC ht WAWW7LLC bu WAWWSLLC bv WAWW9LLC bw WAWW l0LLC bx WAWW LLC by WAWW 12LLC bz WAWW 14LLC ca WAWW ISLLC cb WAWW 16LLC cc WAWW 17LLC ed WAWW 18LLC ce WAWW 19LLC cf WAWW20LLC cg WAWW21 LLC ch WAWW22LLC ci JB Boca Holdings LLC and Contributions hereinafter collectively referred to as the defendant contributions Cl in campaign contributions made to Alex Sink and voluntarily offered and turned over to the United States on behalf of Alex Sink C2 in campaign contributions to Republican Party of Florida Florida account and voluntarily offered and turned over to the United States by the Republican Party of Florida C3 in campaign contributions to Republican Party of Florida Federar account and voluntarily offered and twned over to the United States by the Republican Party of Florida C4 in campaign contributions to Republican Party of Florida and voluntarily offered and turned over to the United States by the Republican Party of Florida C5 in campaign contributions to Republican Party of Florida by Rothstein business entity known as WA WW and voluntarily offered and turned over to the United States by the Republican Party of Florida C6 Charitable Donation to Joe DiMaggio Childrens Hospital which hospital voluntarily advised the United States of the donation from the Rothstein Family Foundation for the purpose of facilitating forfeiture C7 Charitable Donation to Holy Cross Hospital which hospital voluntarily advised the United States of the donation from the Rothstein Family Foundation for the purpose of facilitating forfeiture CS in campaign contributions to Governor Charlie Crist voluntarily offered and turned over to the United States by the office of Charlie Crist and C9 All funds voluntarily turned over to the United States IRS/FBI since in or about October in response to publicity regarding Scott Rothstein If any of the property described above as being subject to forfeiture as a result of any act and omission of the defendant i cannot be located upon the exercise of due diligence ii has been transferred or sold to or deposited with a third party i has been placed beyond the jurisdiction of the court iv has been substantially diminished in value or has been commingled with other property which cannot be divided without difficulty it is the intent of the United States pursuant to Title United States Code Section and pursuant to Title United States Code Section made applicable hereto by Title United States Code Section and pursuant to Rule Fed Crim to seek forfeiture of any other property of said defendant up to the value of the forfeitable property described above All pursuant to Title United States Code Section Title United States Code Section a and Title United States Code Section a made applicable through Title United States Code Section and the procedures outlined at Title United States Code Section JE ACTING UNITED STA TES ATTORNEY PAULF SCHWARTZ ASSISTANT UNITED STATES ATTORNEY UNITED STATES ATTORNEY ASSISTANT UNITED sT ASATToRNEY UNITED STATES OF AMeRICA vs UN I CU I I I CO UIO I Rllw I vVvn I SOUTHERN DISTRICT OF FLORIDA CASE NO CERTIFICATE OF TRIAL ATTORNEY SCOTT ROTHSTEIN Defendant Superseding Ca lnfonnation Court Division SIied One New Defendant Yes Miami __ Ke_y West FTL WPB FTP I do hereby certify that Number of New Defendants Total number of counts I have carefully considered the allegations of the indictment the number of defendantshthe number of probable witnesses and the legal complexities of the Indictment/Information attached ereto I am aware that the information supplied on this statement will be relied upon by the Judges of this Court in settin_g their calendars and scheduling crtminal trials under the mandate of the Speeay Trial Act Title U.S.C Section lntelJ reter Yes or No List language andor dialect This case will take days tor the parties to try Please check appropriate category and type of offense listed below Clledtonly Cnedlonlrona I II Ill IV to days to days to days to60 days days and over Petty Minor Misdem Felony Has this case been previously filed in this District Court Yes or No If yes Judge Case No Attach copy of dispositive order Has a complaint been filed in this matter Yes or No If yes Maaistrate Case No Related Miscellaneous numbers Defendant in federal custody as of Defendant in state custody as of Rule from the District of Is this a potential death penalty case Yes or No No Does this case originate from a matter pe,nding in the U.S Attorneys Office prior to April Yes No Does this case originate from a matter pe,nding in the U.S Attorneys Office prior to ril Yes No If yes was it pending in the Central Region Yes No Does this case originate from a matter pendinj in the Northern Region of the U.S Attorneys Office prior to October __ Yes No Does this case originate from a matter pending in the Narcotics Section Miami prior to May Yes No Does this case originate from a matter pending in the Central Region of the U.S Attorneys Office prior to September Yes No ASSISTA UNITED STA ES ATTORNEY Florida Bar No UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA PENAL TY JNITED STATES DISTRICT COURT SOUTHEBN DISTRICT OF FLORIDA lJNITBD STATES OF AMBR.lCA CASBNUMBBR CR Ot Plaintiff VI SstH _f:ltrbJ REPORT COMMENCJNO ctUMlNAL fr ACTION r_Jf zfb oo._ De ndant TO CLERKS OFFICE MIAMI PALM BEACH U.S DISTRICT COURT NOTS CIRCLS APPROPR.lA LC CATION FOR APPBARANCB IN MAGISTRA TBS COUR.T ABOVE COMPLBTB ALL ITBMS INFORMATION NOT APPIJCABLE BNTER NIA DA AND TIME OP AllRBST e_ _c GUAOB SP l,J:,J OPFBNSB CHARGED Nk,4v CWf12cy fCJJc Lt w:rt fuwJ tc f:ie h,uwl,r Ir u1e-l1l UNITED STATBS CnttEN JYBS NO UNKNOWN I TBOlBll!-TH __ TYPE OF CHAROINO iqJMI!NT JNDICTMBNT COMPLAINT i BENCH WARRANT FOR PAILllB TO APPEAR PAllOL VIOLATION WARR.ANT ORJOINATING DJS1"RIC1 I COPY OF WARRANT LBFT fM1 BOOKING OFPICEk YBS NO AMOUNT OF BOND Oef:tJdflM SBT BOND R.BMARK.S DATE ARR.BSTINOOPFICB.R I,,tJ!f A/e JO AGENCY PHONB ra.r-,rr 7/ol COMMBNTS Report Selection Criteria Case ID XMB Docket Start Date Docket Ending Date Case Description Case ID XM Case Caption JEFFREY EPSTEIN Division AB GILLEN Filing Date Court Thursday September 11th CA CIRCUIT CIVIL Location MB MAIN BRANCH Jury Y-Jury Type ON OTHER NEGLIGENCE Status DAO DISPOSED AFTER OTHER Related Cases No related cases were found Case Event Schedule No case events were found Case Parties Seq Assoc Expn Date Type PLAINTIF TTORNEY ID Name M,L DWARDS BRAD DEFENDANT EPSTEIN JEFFREY 24-APR II JUDGE KEYSER JUDGE Aliases I none I Aliases I none I Aliases II none Aliases none http courtcon.co.palm-beach fl.us pis jiwp/ck_public_qry_doct.co reoort?backto case_id lXMB begin_date end_date Page of EXHIBITG LJ II II IIGREGORYM II I Hm 3j ATTORNEY CRITTON JR ESQ Aliases Jnonel I i ROBERT DEWEESE DEFENDANT KELLEN SARAH Aliases I none I _j ATTORNEY GOLDBERGER ESQ Aliases I none I JACKA ON HT OUou TT NOU,o JUDGE AB GILLEN JUDGE I Aliases i none I JEFFREY DANA ATTORNEY HOWELL ESQ JAY __ Aliases I none I Docket Entries Docket Docket Type Book and Page No Attached To Number DDITIONAL COMMENTS Date i c:mna Party Disposition Amount Docket Text none GAFF Filing Date iling Party I Disposition Amount Docket Text none I PE PENDING Filing Date us/pls/jiwp ck_public_qry_doct.cp report?backto case_id lXMB begin_date end_date Page of Filing Party Disposition Amount ocket Text Inane rca I ii I CMP COMPLAINT Date Filing Party IM i Disposition Amount Docket Text Inane I CCS CIVIL COVER Docket Text I MOTION TO PR6CEED-ANONYMOUSL.Y GRANTED.DE FRENCH._ I ORDG ORDER GRANTING Filing Date Filing Party I Disposition Amount I Docket Text MOTION TO PROCEED ANONYMOUSLY GRANTED.DE FRENCH I NOAP NOTICE OF APPEARANCE ng Date II i ng Party CRITTON JR I ESQ ROBERT DEWEESE I Disposition Amount Docket Text AS COUNSEL FOR OFT JEFFREY EPSTEIN MDIS MOTION TO DISMISS Date I Filing Party EPSTEIN JEFFREY oa.J Disposition Amount Docket Text FOR MORE DEFINITE STATEMENT AND TO STRIKE DIRECTED TO PL LMS COMPLAINT RESP RESPONSE TO II Filing Date Filing Party jM Disposition Amount Docket Text DFTS MOTION TO DISMISS FOR MOER DEFINITE STATEMENT AND TO STRIKE COMPLINT ORSH ORDER Docket Text jj DFTS SUPPLEMENT TO COUNT IV OF PL TS COMPLAINT D-ORDER IIFiling Date Filing Party i pc sition Amount I Docket Text ON DFTS MOTION TO DISMISS GRANTED IN PART DENIED IN PART VIEW ORDER FRENCH I REQP REQUEST TO PRODUCE n::ate Filing Party EPSTEIN JEFFREY i Disposition Amount I ro cket Text I DFTS FIRST TO PLT I I NOS NOTICE OF SERVICE Filing Date Filing Party EPSTEIN JEFFREY I nAmount xt FIRST ket Text POND TO AMENDED COMPLAINT AGOR AGREED ORDER Filing Date Filing Party Disposition Amountj ket Text TO DIS MOTION TO DISMISS Date ount I I COUNT IV OF AMENDED COMPLAINT AND MOTION TO STRIKE NOTICE OF APPEARANCE Filing Date i Filing Party GOLDBERGER ESQ JACK A isposition Amount cket Text AS COUNSEL FOR DFT JEFFREY EPSTEIN ition Amount OR TO AM._D FRE_N5:?H _J RESP RESPONSE TO Filing Date Filing Party Disposition Amount Docket Text DFTS MOTION TO DISMISS COUNT IV OF AMENDED COMPLAINT AND MOTION TO STRIKE NOS NOTICE OF SERVICE M,L Disposition Amount http://courtcon.co palm-beach fl.us/pls/jiwp/ck_pu blic_qry _doct.cp report?backto case_id lXMB begin_date end_date Page of jDocket Text IOF TS ANSWERS TO DFTS INTERROGATOR_I_ES SMIS SUMMONS ISSUED jj Filing Date II Filing Party KELLEN SARAH I i Disposition Amount Docket Text RCPT RECEIPT FOR PAYMENT Nm-m i Date I Party jM Disposition Amount i Docket Text A Payment of was made on receipt onnc REPLY/RESPONSE I Filing Date Filing Party EPSTEIN JEFFREY I isposition Amount Docket Text TO PL TS RESPOSNE TO DFTS MOTION TO DISMISS COUNT IV OF AMENDED COMPLAINT AND MOTION TO STRIKE MOT-MOTION mng Date mng Party JEFFREY Disposition Amount I Docket Text TO REASSIGN ANO/OR TRANSFER NOTO NOTICE OF TAKING DEPOSITION __ II Filing Date I IIFiling Party EDWARDS BRAD Disposition Amount Docket Text OF JEFFREY EPSTEIN ON _J NOH NOTIC OF HEARi Date Filina Party CRITTON JR ESQ ROBERT DEWEESE isposition Amount http://courtcon.co.pa.lm-beach fl.us pis jiwp ck_public_qry_doct.cp report?backto case_id lXMB begin_date end_da.te Page of Docket Text Filing Date Filing Party i!ON ORD-ORDER Disposition Amount Docket Text ON DFTS MTN TO DISMISS CT IV OF PL TFS AMENDED COMPLAINT-GRANTED AS STATED I JI NOS N?TICE OF SERVICE i Filing Date i iilJ 1no Party Disposition Amount com Docket Text OF PL EXPERT WITNESS INTERGS TO OFT REQUEST FOR ADMISSIONS Filing Date Filing Party i position Amount I Docket Text FIRST I NOS NOTICE OF SERVICE Filing Party sposition Amount Docket Text OF PL FIRST NOTO NOTICE OF TAKING I _J DEPOSITION ing Date I ing Party CRITTON JR ESQ ROBERT DEWEESE I om Disposition Amount Text OF DOMINIQUE HYPPOLITE ON NNAC NOTICE NAME/ADDRESS CHANGE Filing Date Filing Party I I Disposition Amount I I et Text AS TO COUNSEL ANAD ANSWER AFFIRMATIVE DEFENSES Filing Date Filing Party EPSTEIN JEFFREY Disposition Amount Docket Text TO PL AMENDED COMPLAINT OTION TO COMPEL jFiling Date I l_ iling Party EPSTEIN JEFFREY Disposition Amount Docket Text none CT!C TO COMPEL _J Date i Party EPSTEIN JEFFREY Disposition Amount Docket Text none ORD-ORDER ua ng Party Disposition Amount I http courtcon.co palm-beach fl.us pls/j iwp ck_pu blk_qry _doct.cp report?backto case_id lXMB begin_date end_date Page of Docket Text ION MOTION TO REASSIGN IS DENIED FRENCH I NOF NOTICE OF FILING Date Filing Party CRITTON JR ESQ ROBERT DEWEESE Docket Text none SRTN SERVICE IMOT MOTION II II Filing Date Filing Party EDWARDS BRAD Disposition Amount ket Text FORPROTECTIVE ORDER __ NOT-NOTICE Filing Date Filing Party EPSTEIN JEFFREY i I i Disposition Amount Docket Text OF PROPOUNDING EXPERT INTERROGATORIES TO PL i:,i RESPONSE TO Filing Date fM,-L rn_ Filing Party I sposition Amount Docket Text IN OPPOSITION OT DFT MOTION ORSH ORDER rn NOH NOTICE OF HEARING Date ing Party I position Amount et Text um umH UH onn u-u NOH NOTICE OF HEARING ling Date I jCRITTON JR I Filing Party ESQ ROBERT DEWEESE I I Disposition Amount xt 225umoumu uu __ NOH NOTICE OF HEARING II I http://courtcon.co.pal m-beach us pis jiWP ck_pub lic_q ry _doct.c epo rt?backto case_id lXMll begin_date end_date Page of Filing Date I I Filing Party CRITTON JR I ESQ ROBERT DEWEESE Disposition Amount T-xt I NOH NOTICE OF HEARING Filing Date I Filing Party CRITTON JR ESQ ROBERT DEWEESE Disposition Amount Docket Text NOH NOTICE OF HEARING ling Date Filing Party CRITTON JR ESQ ROBERT DEWEESE I Disposition Amount I Docket Text i RESP RESPONSE TO Filing Date A Filing Party EPSTEIN JEFFREY position Amount Text I AND OBJECTIONS TO PL FIRST REQ FOR PRODUCTION ANS-ANSWER Date A Filing Party EPSTEIN JEFFREY Disposition Amount Docket Text AND OBJECTIONS TO PL INTERGS RESP RESPONSE TO IIFiting Date Fili EPSTEIN JEFFREY Disposition Amount et Text AND OBJECTIONS TO PL INTERGS ANS-ANSWER ate I Filing Party EPSTEIN JEFFREY http://courtcon.co.palm-beach fl.us/pis jiwp ck_publfc_qry_doct.c eport?backto case_id lXMB begin_date end_date Page of Disposition Amount Docket Text TO PL REQ FOR ADMISSIONS NOF NOTICE OF FILING Filing Date Filing Party EPSTEIN JEFFREY Disposition Amount Docket Text none NOF NOTICE OF FILING I I Date I 267mng Party CRITTON JR ESQ ROBERT DEWEESE I I isposition Amount PL TFS ANSWERS I _J SUP SUPPLEMENT Filing Date i rh __ Filing Party i I sition Amount Docket Text BRIEF IN SUPPORT OF MOTION FOR PROTECTIVE ORDER I MOT MOTION Filing Date Filing Party Disposition Amount __ et Text TO DISQUALIFY TRIAL JUDGE 225mmH me H"CHm UOUO II RPRS REPLY/RESPONSE Filing Date fza-MA!_-2 __ i ffi ng Party EPSTEIN JEFFREY I i tion Amount xt IN OPPOSITION TO PL TF MOTION TO DISQUALIFY I NU:i NOTICE OF SERVICE Filing Date 1n I __ _J Filing Party EDWARDS BRAD Disposition Amount Docket Text jnone http://courtcon.co.palm-beach fl us pis jiwp k_public_qry _doct.c eport?backto case_id lXMB begin_date end_date Page of ORDER __ anM n_ I DENIED HAFELE MOTION I I FOR LEAVE TO ADD COUNT FOR BATTERY AND SEEK PUNITIVE DAMAGES NOTICE OF HEARING i RITTON JR ESQ ROBERT DEWEESE ON NOTICE none ORDER I I i ON MTN TO COMPEL-MTN IS MOOT SEE ORDER AGREED ORDER I I ON DFTS MTN TO COMPEL-GRANTED I AGREED ORDER II I i iwp ck_pu blic_ qry doct eport?backto case_id lXMB begin_date end_date Page of I ORD Filing Date iling Party osition Amount cket Text MOT Date Party Disposition Amount Docket Text NOH osition Amount ket Text OT-I ing Date ng Party osition Amount ket Text ORD Date Amount Docket Text GOR I Filing Date Filing Party Disposition Amount joocke Te AGOR us pis ll Filing Date I f.iling Party isposition Amount I Docket Text ON DFTS MTN TO COMPEL fo ORDER Filing Date Filing Party __ _J Disposition Amount Docket Text ON NON-PARTYS MTN FOR PROTECTIVE ORDER-AS IN ORDER ORSH ORDER Filing Party ilEPSTEIN JEFFREY I I i Disposition Amount Docket Text ATTACHED ORD-ORDER Filing Date Filing Party I Dispo iti A:!llount I Docket Text ON DFTS MTN TO COMPEL-SEE ORDER NOT NOTICE m_ Date _J Party GOLDBERGER ESQ JACK A i isposition Amount ocket Text ilnone I NOF NOTICE OF FILING II Filing Date Filing Party EPSTEIN JEFFREY Disposition A:!lount cket Text XHIBIT A M-H.n NOH NOTICE OF HEARING i I mH Filing Date i Party EDWARDS BRAD position Amount cket Text ON I NOF NOTICE OF FILING II Filing Date Filing Party CRITTON JR ESQ ROBERT DEWEESE isp sitio mount ocket Text none O!_IC_ OF FILING Filing Date i Filing Party EPSTEIN JEFFREY I Disposition Amount I http://courtcon.co.palm-beach fl.us pls/jiwp k_public_q ry _doct.c eport?backto case_id lXMB begin_ date end_ date Page of lATTACHED Docket Text ORD-ORDER J_ I ul.t Filing Party Disposition Amount et Text ON MTN FOR LEAVE GRANTED NOTICE OF HEARING Filing Date il d,ng Party_:_ JEDWARDS BRAD Disposition Amount i xt 1jON OT-MOTION Filing Date Filing Party M,L Disposition Amount STAY OF JUNE ORDERS REQUEST Party M,L sition Amount Text FOR PRODUCTION Party CRITTON JR ESQ ROBERT DEWEESE osition Amount none Ml Ml nOTION TO COMPEL EPSTEIN JEFFREY sition Amount COMPLIANCE http://courtcon.co palm-beach fl.us pls/jiwp/ck_pu blic_q ry _doct.c eport?backto case_id beg in_date end_date Page of ll RPRS-REPLVRESPONSE JI jj I Filing Date ii I Filing Party EPSTEIN JEFFREY I I i position Amou I Docket Text IN OPPOSITION NPNP NOTICE OF PRODUCTION NON PARTY Filing Date Filing Party EDWARDS BRAD I __ __ Disposition Amount ket Text none NOTO NOTICE OF TAKING DEPOSITION I Filing Date II Filing Party I I Disposition Amount I Docket Text OF WILLIAM BILL RILEY NPNP NOTICE OF PRODUCTION NON PARTY Date II Filing Party EDWARDS BRAD Disposition Amount ket Text none NPNP NOTICE OF PRODUCTION NON I I PARTY Filing Date I Filing Party EDWARDS BRAD Disposition Amount Docket Text none NPNP NOTICE OF PRODUCTION NON I PARTY Filing Date Filing Party EDWARDS BRAD i http cou rtcon.co.palm-beach fl.us pis iwp ck_public_ qry_doct.c eport backto case_id XMB beg in_ date end_date Page of
