IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
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IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT
IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE No. 502009CA040800XXXXMBAG
JEFFREY EPSTEIN,
Plaintiff,
-vs-
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually, and
., individually,
Defendants.
VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN
Wednesday, March 17, 2010
10:17 a.m.- 1:27 p.m.
303 Banyan Boulevard
Suite 400
West Palm Beach, Florida 33401
Reported By:
Sandra W. Townsend, FPR
Notary Public, State of Florida
West Palm Beach Office Job 41358
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APPEARANCES:
2 On behalf of the Plaintiff
3 MICHAEL PIKE, ESQUIRE
BURMAN CFUTTON LUEIER & COLEMAN, 11?
1 303 Banyan Boulevard, Suite 400
West Pailikirda 33401
Phone:
0
On behalf of the Defendant Bradley Edwards:
JACK SCAROLA, ESQUIRE
SEARCY, DENNEY, SCAROLA, BARNFIART & SHIPLEY
2139 Palm Beach Lakes Boulevard
West ' 33409
10 Photo:
11. Oat:chaff° the
12 BRADLEY EDWARDS, III‘IRE
FARMER, JAFFE, WESSINO, EDWARDS, HMS,
13 & LEEMAN, Pl.
425 North Andrews Avenue
14 Suite 2
Fon Lt. 33301
15 Phone:
16 Also Present
11 STEVEN JAFFE, ESQUIRE
FARMER, JAFFE, WEISER:I, EDWARDS, Ftb ILb
78 & LEHRMAN, P.L.
425 North Andrews Avenue
19 Suite 2
20 Fon Lit da 33301
Phcoe:
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PROCEEDINGS
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3 Deposition taken before Sandra W. Townsend, Court
4 Reporter and Notary Public in and for the State of
5 Florida at Large, in the above cause.
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25 VIDDOGRAPHER: We are now on video record.
This is media number one in the videotaped
deposition of Jeffrey Epstein in the matter of
Jeffrey Epstein versus Scott Rothstein, Bradley
Edwards and M.
Today is Wednesday, March 17,2010 at
10:17 am.
We are at the law offices of Burman,
Critton — Banyan — of Burman, Critton on Banyan
Boulevard, Suite 400, West Palm Beach, Florida.
My name is Joe Kozak. I'm the videographcr.
The court reporter is Sandra Townsend from Prose
Court Reporting Agency.
Would Counsel please introduce yourselves and
then the court reporter will swear in the witness.
MR. SCAROLA: My name is Jack Scarola. I am
Counsel on behalf of Brad Edwards in his capacity,
both as Defendant and Counter-Plaintiff in this
action. Mr. Edwards is present with me. I
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EXHIBITS
NUMBER DESCRIPTION PAGE
Exhibit number 1 Eyeglasses 133
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1 MR. PIKE: Michael Pike, on behalf of the
2 Plaintiff, Jeffrey Epstein.
3 MR. EDWARDS: Brad Edwards, on behalf of the
4 Defendant, M.
5 Also present Steve Jaffe, on behalf of the
6 Defendant, M., as well.
7 THEREUPON,
8 JEFFREY EPSTEIN,
9 having been first duly sworn or affirmed, was examined
10 and testified as follows:
11 THE WITNESS: Yes, I do. Thank you.
12 MR. PIKE: Before we get started, Jack, I just
13 wanted to get on the record, I just want to make
14 sure that you received this letter that I sent to
15 your office yesterday of March 16, 2010.
16 MR. SCAROLA: !did receive the letter.
17 MR. PIKE: Okay. And we're still on for
18 Mr. Edwards' deposition, as we sit here today?
19 MR. SCAROLA: That's correct.
20 MR. PIKE: Okay. Thank you.
21 DIRECT EXAMINATION
22 BY MR. SCAROLA:
23 Q. Please state your full name and your current
24 residence address.
25 A. My name is Jeffrey Epstein. Pm currently
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residing at 358 El BriIto in Palm Beach.
2 Q. How long have you resided at that location,
3 Mr. Epstein?
4 A. I'm sorry. On advice of Counsel today, I'm
5 going to take the Fifth, Sixth and 14th Amendment with
6 respect to that question, Mr. Scarola.
7 Q. Have you maintained any other residences over
8 the course of the last five years?
9 A. Though I'd I lice to answer each and every one
10 of your questions here today, with respect to that
11 question 15n going to have to assert my Constitutional
12 Rights as provided by the Sixth, 14th and Sixth --
13 Fifth — sorry — Fifth, Sixth and 14th Amendment.
14 Q. Does anyone reside with you at the El Milo
15 address?
16 A. Again, Mr. Scarola, though Pd like to answer
17 each and every one of your questions here today, at
18 least with respect to that question, I'm going to have
19 to assert my rights as under the Sixth, Fifth and 14th
20 Amendment.
21 And I've been advised by Counsel, though I'd
22 lute to answer these questions, if I do so, I risk
23 losing their representation.
24 Q. What did your lawyer tell you in that regard?
25 MR. PIKE: I'm going to instruct you not to 1
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25 your questions here today. However, on advice of
Counsel, I'm going to have to assert my Fifth. Sixth and
14th Amendment Right.
Q. Are you a Plaintiff in a lawsuit against Scott
Rothstein, Bradley J. Edwards and an individual
identified by the initials In, A. Yes, sir, l am.
Q. Who is the individual identified ass?
A. I believe from depositions that I've read her
full name is M.
Q. When and under what circumstances did you
first meet the individual referenced by the initials
A. Mr. Scarola, I think you arc awarc these
questions are simply designed to have me invoke my Fifth
Amendment, Sixth Amendment and 14th Amendment Right in
relation to other questions and other cases
But in response to your question, I'm going to
have to invoke my right not to testify.
Q. Do you know the individual named ■
identified by the initials Ini?
A. Mr. Scarola, at least today -- I would like to
answer that question; however, today, on advice of
Counsel, I'm going to have to refuse to answer that
question.
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1 answer that question. Attomey/client.
2 BY MR. SCAROLA:
3 Q. Well, didn't you just tell me that your lawyer
4 advised you that if you answered questions he wouldn't
5 represent you anymore?
6 MR. PIKE: Mat's exactly what he said,
7 Mr. Scarola, and Pm instructing him not to answer
8 the question.
9 BY MR. SCAROLA:
10 Q. Okay. So I want to know then — I want to
11 know what your lawyer told you about that.
12 MR. PIKE: I'm going to instruct you not to
13 answer that question. Attorney/client.
14 MR. SCAROLA: And it is our contention,
15 obviously, that by making the statement that he has
16 made, Mr. Epstein has waived any attorney/client
17 privilege with regard to that matter.
18 MR. PIKE: Your contention, definitely not
19 mine.
20 BY MR. SCAROLA:
21 Q. Mr. Epstein, who else has shared that
22 residence with you at any time over the course of the
23 last five years?
24 A. Again, Mr. Scarola, I'd like to answer that
25 question, as Pd like to answer each and every one of Page 9
1 Q. Have you ever acknowledged in the presence of
2 any other person knowing the individual identified by
3 the Initials M.?
4 MR. PIKE: Form.
5 THE WITNESS: Again? Sony. Can you repeat
6 the question, sir?
7 BY MR. SCAROLA:
8 Q. Yes, sir. Have you ever acknowledged in the
9 presence of any other person knowing the individual
10 identified by the initials M.?
11 MR. PIKE: Perm. Also could invade
12 attomey/client.
13 11-16 WITNESS: Again, I would like to answer
14 that question, but today I'm going to have to
15 Invoke my Fifth Amendment, Sixth Amendment and l,ttn
16 Amendment Right.
17 BY MR. SCAROLA:
18 Q. Have you ever acknowledged in the presence of
19 any person, other than your ownlw,=, having known the
20 individual identified by the initials M.?
21 MR. PIKE: Form.
22 THE WITNESS: Again, I'd late to answer each
23 and every one of your questions here today,
24 Mr. Scarola; however, on advice of Counsel, at
25 least today, fm going to have to reflate to answer
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1 that question.
2 BY MR. SCAROLA:
3 Q. Have you ever acknowledged to --
4 A. Excuse me.
5 Q. --Bradley-
6 A. Sir, may I suggest that if I say I refuse to
7 answer, that it means the Fifth, Sixth and 14th or would
8 you prefer that I recite it each time?
9 Q. I would prefer that you answer the questions,
10 that's my preference. But if you're going to assert a
11 privilege, I will assume that if you simply say that you
12 are refusing to answer, your refusal to answer will be
13 on the basis of various Constitutional privileges
14 against self-incrimination without the necessity of
15 specifying,
16 If your refusal to answer is on the basis of
17 any other privilege, it will be necessary for you to
18 identify that privilege.
19 A. ThanIcyou.
20 MR. PIKE: And Pm going to instruct you, too,
21 when you do invoke, invoke the Fifth, Sixth and the
22 14th.
23 THE WITNESS: Yes.
24 BY MR. SCAROLA:
25 Q. Have you ever acknowledged in the presence of Page 12
1 invoke my Fifth, Sixth and 14th Amendment Right.
2 Q. Have you ever acknowledged in the presence of
3 Terri Becker, a court reporter present at a deposition
4 taken by Brad Edwards in a — in a case in which the
S individual identified by the initials' was a
6 Plaintiff that you knew and/or liked —
7 MR. PiKE: Form.
8 THE WITNESS: Again, --
9 BY MR. SCAROLA:
10 Q.11 MR. Same objection.
12 THE WITNESS: Again, I'm going to have to
13 assert my Fifth, Sixth and 14th Amendment Right.
14 BY MR. SCAROLA:
15 Q. Have you ever acknowledged in the presence of
16 Steve Jaffe that you knew and/or liked a ?
17 A. Again, Mr. Scarola, though I'd I c to answer
18 each and every one of your questions today, Pm going to
19 have to, at the advice of Counsel, invoke my Fifth,
20 Sixth and 14th Amendment Right.
21' Q. Why are you suing.?
22 MR. PIKE: Form.
23 MR. SCAROLA: Let me state for the record that
24 I don't consider a form objection to be a proper
25 objection, unless you specify the defect in the
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Bradley J. Edwards that you knew the individual
identified by the initials.?
A. Pm going to have to refuse to answer that
question.
Q. Have you ever acknowledged in the presence of
Bradley J. Edwards that you knew.?
MR. PIKE: Again, for purposes of the record,
I'm instructing you to invoke the Fifth, Sixth and
14th, rather than just simply say --
THE WITNESS: Okay.
MR. PIKE: —I refuse to answer. I want it
to be clear for the Court that you have invoked
your Fifth, Sixth and 14th.
THE WITNESS: Fine.
Then on advice of Counsel, I'm going to have
to invoice my Fifth, Sixth and 14th Amendment Right.
BY MR. SCAROLA:
Q. Have you ever acknowledged in Brad Edwards'
presence that you liked the individual identified by the
initials.?
A. Again, Pm going to have to invoke my Fifth,
Sixth and 14th Amendment Right, Mr. Scarola.
Q. Have you ever acknowledged in Bradley Edwards'
presence that you liked
A. Again, Mr. Scarola, fm going to have to 1
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form and provide me with an opportunity to correct
the defect.
MR. PIKE: That's fine. I believe the rules
provide otherwise. But, nonetheless, i stand on my
objection to form.
THE WITNESS: Pm sorry. You have to repeat
the question.
BY MR. SCAROLA:
Q. Why are you suing M?
MR. PIKE: Fonn.
11W WITNESS: is part of a conspiracy
with Scott Rothstein, ley Edwards, creating --
excuse me — creating fraudulent cases of a
sexually charged nature in which the U.S. Attorney
has already charged the firm of Rothstein, a firm
of which Bradley Edwards is a partner, was a
partner, with creating, fabricating malicious cases
of a sexual nature, including cases with respect to
me, specifically, in order to fleece unsuspecting
investors in South Florida out of millions of
dollars.
BY MR. SCAROLA:
Q. What role do you contend =. played in that
conspiracy to create fraudulent cases
A. testimony before she met Mr. Edwards
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was dramatically -- sworn testimony to the FBI was
dramatically different after she came in contact with
Mr. Bradley Edwards, where her testimony then changed to
sort of a hostile and had claims of -- claims never made
before, never made to anyone before, and allegations
that i've read in her Complaint that that had been
dramatically different from the ones she had spoken to
the FBI about, sir.
Q Is it your contention that as statement to
the FBI was true?
MR. PIKE: Form.
THE WITNESS: Mr. Scarola, unfortunately,
today with respect to that question, iin going to
have to assert my Fifth, Sixth and 14th Amendment
Right. Though I know — I believe you know the
answer to that question, I can't answer the
question under advice of Counsel. And hes told me
if i chose to do so, I risk losing his
representation.
BY MR. SCAROLA:
Q. What is the basis of your belief that i know
the answer to the question?
MR. PIKE: Form.
THE WITNESS: You — I believe you have seen
this, because you're supposed to be a decent 1
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according to you, she met Mr. Edwards and changed her
testimony, true?
A. Did she change her testimony? Is that — yes,
her testimony was changed.
Q. My question to you is: Was her testimony
which you contend was changed true testimony?
A. Your question is not a good question. Is it
her testimony before or after?
Q. Was the subsequent testimony given by
after she met Mr. Edwards which you contend was
different from her testimony before the FBI, was the
subsequent testimony true or false?
MR. PIKE Form.
THE WITNESS: Sr, I'm going, at least today,
Pm going to have to assert my Fifth, Sixth and
14th Amendment Right
BY MR. SCAROLA:
Q. Did you ever engage in any sexual conduct with
. I would like to answer that question, but —
Q. You don't need to tell me what you'd like to
do, Mr. Epstein. You just need to do it, please.
THE WITNESS: Please —
MR. PIKE Mr. Smola, please let the witness
finish his response.
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1 lawyer, youfve read the testimony. I would guess
2 you've read the difference in her testimony to the
3 FBI versus her testimony after she's met your
4 client and his partners, who are currently in jail.
5 BY tvfit. SCAROLA:
6 Q. How does that respond to my question as to
7 whether you contend that her testimony to the FBI was
8 true or false?
9 MR. PIKE: Form.
10 THE WITNESS: I don't believe that was your
11 question. Will you repeat?
12 BY MR. SCAROLA:
13 Q. Okay. Well, let's let me rephrase the
14 question then.
15 Is it your contention that M.'s statement to
16 the FBI was true?
17 A. Sr, on advice of Counsel, at least today, Pm
18 going to have to assert my Fifth, Sixth and 14th
19 Amendment ejRtt.
20 Q. Was M.'s statement to the FBI false in any
21 respect?
22 A. Sir, at least, again, today, on advice of
23 Counsel, Pm going to have to assert my Fifth, Sixth and
24 14th Amendment Right.
25 Q. Was .'s subsequent testimony after, 1
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MR. SCAROLA: That's not a response to my
question.
MR. PIKE: In your mind it may not be a
response. In a Judge's mind, it may be. We may
have to certify it to the Court. If such a
procedure even exists, we can take it up with the
Court. But please let the witness finish his
response.
THE WITNESS: Again, please?
BY MR. SCAROLA:
Q. Did you engage — ever engage in any sexual
conduct with M7
A. I would u e to answer that question; however,
today Pm going to have to assert my rights as provided
by the Fifth, Sixth and 14th Amendment to that question,
sir.
Q. Have you ever exchanged anything of value with
MR. PiKE: Form.
THE WITNESS: At least today, I'm going to
have to assert my Fifth, Sixth and 14th Amendment
Right, sir.
BY MR. SCAROLA:
Q. Did you ever direct anyone to deliver anything
of value to .7
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MIL PIKE: Form.
THE WITNESS: At least today, I'm going to
3 have to refuse to answer that question based on the
4 Fifth, Sixth and 14th Amendment
5 BY MR. SCAROLA:
6 Q. Do you Imow
A. At least today, sir, 1'm going to have to
3 refuse to testify about that question. Based on advice
9 of Counsel, I'm going to have to assert my Fifth, Sixth
10 and 14th Amendment Ri t.
11 Q. Di introduce you to M.?
12 A. Sir, nape...tfully, I'd like to answer that
13 question today. As I said, I'd like to answer each and
14 every one of your questions. However, on advice of my
15 Counsel today, inn going to have to assert my Fifth,
16 Sixth and 14th Amendment Right.
17 Q. Did M. suffer any damats a consequence of
18 any interaction between you and M.?
19 MR. PIKE: Form.
20 THE WITNESS: Could you repeat the question,
21 please?
22 BY MR. SCAROLA:
23 Q. Did IN. suffer any damage as a consequence of
24 any interaction between you and M.?
25 MR. PIKE: Form. 1 which is outrageous.
2 BY MR. SCAROLA:
3 Q. How much have you settled claims for?
4 MR. PIKE: ism going to instruct you not to
5 answer that question.
6 MR. SCAROLA: And the basis of that
7 instruction is?
8 MR. PIKE: Confidential settlement agreements.
9 to the extent that they exist. And the terms would
10 be confidential.
11 BY MR. SCAROLA:
12 Q. Have you settled claims?
13 A. Yes, l have.
14 Q. What is the nature of the claims you settled?
15 MR. PIKE: Pm going to instruct you not to
16 answer that question.
17 BY MR. SCAROLA:
18 Q. How many claims have you settled?
19 MR. PIKE: IN going to instruct you not to
20 answer that question as well.
21 MR. SCAROLA: What is the basis for those
22 instructions?
23 MR. PIKE: Confidential, as well as there is a
24 VICTIM'S Right Statute that may — you may be
25 tiptoeing into the identity of -
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1 THE WITNESS: I'd hie to answer each and
2 every one of your questions here today,
3 Mr. Scarola; however, on advice of Counsel, today,
4 Pm going to have to assert my Fifth, Sixth and
5 14th Amendment Right.
6 BY MR. SCAROLA:
Your Complaint in this action alleges that
8 . made claims for damages out of proportion to her
9 alleged damages. What does that mean?
10 A. It means what it says.
11 Q. I don't understand it. Explain it to me.
12 MR. PiKE: To the extent you can answer that
13 question without disclosing my conversations with
14 you or Mr. Critton's conversations with you, as
15 well as my work product, you can answer the
16 question.
17 THE WITNESS: I believe that as part of the
18 scheme to defraud investors in South Florida out of
19 millions of dollars, claims of outrageous sums of
20 money were made on behalf of alleged victims across
21 the board. And the only way — in fact, Scott
22 Rothstein sits in jail. And what I've read in the
23 paper, claims that I've settled cases for
24 S200-million, which is totally not true.
25 She has made claims of serious sum of money, Page 21
1 MR. SCAROLA: Pm not tiptoeing anywhere.
2 MR. PIKE: Let me finish my objection,
3 Mr. Scarola.
4 You may be tiptoeing into the identity of
5 various alleged victims underneath the Victims
6 Right Statute, as well as ongoing investigations or
7 past investigations that have remained open with
the State, as well as the Federal Government.
9 So in that regard, we would have to put the
10 State Attorney, as well as the Federal Government
11 on notice that you were seeking to potentially back
12 door certain identities at this deposition.
13 BY MR. SCAROLA:
14 Q. Other than having allegedly given different
15 testimony before she met Mr. Edwards then given after
16 she met Mr. Edwards, did S do anything else that
17 forms the basis for your claim against her?
18 MR. PUCE: Form. Asked and answered.
19 THE WITNESS: I'd like to answer that
20 question, as well as every one of your questions
21 with respect to M. here today; however, on advice
22 of Counsel, at least today, Mr. Scarola, Pm going
23 to have to assert my Sixth Amendment, Fifth
24 A•essIntent and 14th Amendment Right.
25 BY MR. SCAROLA:
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1 Q. Did fail to do anything that she had an
2 obligation, duty or responsibility to do
3 MR. PIKE: Form.
4 BY MR. SCAROLA:
5 Q. — that forms the basis for your claim against
her?
7 MR. PIKE: I apologize. Form.
8 THE WITNESS: Again? I'm sorry. Has she
9 failed to do? Can you repeat?
10 BY MR. SCAROLA:
11 Q. Yes, sir. Lawsuits are generally based, civil
12 lawsuits are generally based on a claim that someone has
13 done something that they shouldn't have done or failed
14 to do something that they should have done.
15 I asked you whether did anything that she
16 shouldn't have done and you asserted a Fifth Amendment
17 privilege in refusing to answer that question.
18 I'm now attempting to find out whether ■.
19 failed to do something that she should have done that
20 forms the basis of your claims against her.
21 Did M. do anything that she should have done
22 that forms the basis of your claims against her?
23 MR. PIKE: Form.
24 THE WITNESS: On advice of Counsel, at least
25 today, Mr. Scarola, Pm going to have to refuse to Page 24
1 MR. PIKE: Mr. Scarola, that's the second time
2 that I'm going to ask you not to interrupt the
3 witness when he's giving a response. He is giving
4 a response. When he finishes his response, you can
5 go on with your next question or you can — you can
6 elicit any sort of information you intend to elicit
7 from the witness.
8 MR. SCAROLA: He's being unresponsive.
9 MR. PIKE: No, that's your contention.
10 MR. SCAROLA: No, that's a fact.
11 MR. PIKE: And you can take it up with a
12 Judge. And if we want to continue going back and
13 forth and bantering, not allowing the witness to
14 answer the question — we're here for you today,
15 for you to ask the questions and for you to get
16 answers. But if you continue to banter with the
17 witness and interrupt the witness, I will adjourn
18 the deposition. This is not proper and we
19 certainly can take it up with the Judge. So that's
20 the second warning, Mr. Scarola. Please —
21 MR. SCAROLA: How many do I get?
22 MR. PIKE: Inn not sure yet today.
2 3 MR. SCAROLA: Okay.
24 MR. PIKE: Okay?
25 MR. SCAROLA: Good. Then let's move on.
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1 answer that question based on my Fifth Amendment, 1
2 Sixth Amendment and 14th Amendment Right. 2
BY MR. SCAROLA: 3
4 Q. Did Brad Edwards do anything that he shouldn't 4
have done that forms the basis of your lawsuit against 5
6 him? 6
MR. PIKE: Form. 7
8 THE WITNESS: Yes, many things. 8
9 BY MR. SCAROLA: 9
10 Q. List them forme, please. 10
11 A. He has — he has gone to the media out of, I 11
12 believe, in an attempt to gin up these allegations. Ho 12
13 has contacted the media. He has used the media for his 13
14 own purposes. He has brought discovery — he has 14
15 engaged in discovery proceedings that bear no 15
16 relationship to any case filed against me by any of his 16
17 clients. 17
18 His firm, which he's the partner of, has been 18
19 accused of forging a Federal Judge's signature. 19
20 Q. I want to know what Mr. Edwards — 20
21 MR. PIKE: One second. 21
22 THE WITNESS: Excuse me. I'm answering. 22
23 BY MR. SCAROLA: 23
24 Q. I %nut to know what Mr. Edwards did. I'm not 24
25 asking you about allegations concerning his law firm. 25 Page 25
MR. PIKE: But I can tell you one thing: On a
professional nature, just because you are
interrupting the witness and bantering with me, I
will adjourn the deposition.
BY MR. SCAROLA:
Q. Besides having gone to the media in an attempt
to, quote, gin up, unquote, these allegations and
engaged in what you contend to be irrelevant discovery
proceedings, what else did Mr. Edwards, personally, do
that forms the basis for this lawsuit?
A. Mr. Edwards, personally, engaged with his
partners, Scott Rothstein, who sits in a Federal jail
cell, potentially for the rest of his life, he shared
information, what I've been told and — excuse me —
what I've read in the newspapers, 13 boxes of
information that had my name on it, with other attorneys
at his fum
Ho counseled his clients to maintain a
position alleging multi-million dollar damages in order
for them to scam local investors out of millions of
dollars.
He and his — many of his other partners
already under investigation by the FBI and the U.S.
Attorney have been accused by the U.S. Attorney of
running a criminal enterprise.
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1 Q. Anything else?
2 MR. PIKE: Form.
3 THE WITNESS: Not I can think of at the
4 moment.
5 BY MR. SCAROLA:
6 Q. Okay. What media did Mr. Edwards go to?
7 A. I am aware of at least the Daily News in New
8 York City.
9 I have been told by other people that there
10 were other media, local media.
11 I've been told that the -- his investigator
12 was sent to California to harass people representing
13 his — Brad Edwards' investigator -- representing
14 fictitiously, fraudulently that he was a FBI agent to
15 try to gather information for Mr. Edwards' claims.
16 Q. Does that have something to do with going to
17 the media?
18 MR. PIKE: Form.
19 THE WITNESS: I've answered your question.
20 BY MR. SCAROLA:
21 Q. Does the investigator going to California to
22 do something have something to do with the media?
23 A. I believe I've also told that you that he's
24 gone to the Daily News, sir, is that coned?
25 MR. PIKE: Form. Mischaracterizes the Page 28
1 Q. Do you understand the question you're supposed
2 to be answering, Mr. Epstein?
3 MR. PIKE: And Fm going to instruct you not
4 to answer that question right now because as your
5 Counsel I cannot let you answer that question until
6 I understand what question is on the table.
7 There's been a lot of bantering back and
8 forth, so, Mr. Scarola, if you would respectfully
9 repeat the question and then you may be able to ask
10 him whether or not he understands the question.
11 But I cannot allow him to answer a question that I
12 don't understand is on the table.
13 BY MR. SCAROLA:
14 Q. What does an investigator going to California
15 have to do with Mr. Edwards allegedly going to the media
16 in an attempt to, quote, gin up, unquote, these
17 allegations?
18 MR. PIKE: Please answer the question.
19 THE WITNESS: Good. It's part of Mr. Edwards'
20 scheme to involve people who have nothing to do
21 with any of his cases in order to, in fact, go back
22 to the media and gin up his stories and make false
23 allegations of people that have sexually charged
24 nature cases in order to attempt to fleece
25 investors, local investors out of millions of
Page 27
1 witness' testimony as well.
2 BY MR. SCAROLA:
3 Q. Do you understand the question that you're
4 supposed to be answering?
S MR. PIKE: Well, let's go ahead and repeat it.
6 MR. SCAROLA: No, let's get an — let's get an
7 answer to that question.
a BY MR. SCAROLA:
9 Q. Do you understand the question you're supposed
10 to be answering?
11 A. When-
12 MR. PIKE: I'm confused. Wait one second.
13 THE WITNESS: Sony.
14 MR. PIKE: I'm confused as to what question is
15 on the table.
16 MR. SCAROLA: And when your deposition is
17 being taken, your confusion is relevant and
18 material.
19 MR. PIKE: Right. And it's —
20 MR. SCAROLA: When Mr. Edwards' — excuse
21 me — when Mr. Epstein's deposition is being taken,
22 I'm concerned with whether he understands the
23 question being asked.
24 MR. PIKE: Right. So...
25 BY MR. SCAROLA: Page 29
1 dollars.
2 His firm has been accused by the U.S. Attorney
3 of manipulating the media, by hiring investigators,
4 by illegal wire taps, by illegal methods of
5 eavesdropping in order to go to the media and
6 generate cases.
7 BY MR. SCAROLA:
8 Q. When did Mr. Edwards go to the Daily News?
9 A. I don't know.
10 Q. How did he go to the Daily News?
11 A. I don't know.
12 Q. What did he say to the Daily News?
13 A. I believe Mr. Edwards knows that. I don't
14 know exactly what he said.
15 Q. What is the source of your information that he
16 went to the Daily News at all, ever?
17 MR PIKE: To the extent you can answer that
18 question without violating any attorney/client
19 privileges, you can answer the questions.
20 THE WITNESS: It's attorney/client
21 BY MR. SCAROLA:
22 Q. You said you were told by other people that he
23 went to other media representatives?
24 A. Yes, sir.
25 Q. Who are the other people that told you that? A......e..14A4 ,
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1 A. I don't recall at the moment-
2Q. What did these other people who you don't
3 remember tell you Mr. Edwards did with respect to other
4 media representatives besides the Daily News?
S A. Again, the question again?
6 Q. What did these other people tell you
7 Mr. Edwards did with respect to going to other media?
8 MR. PIKE: Form.
9 THE WITNESS: Mr. Edwards went to the media to
10 gin up his cases in order that the Rothstein firm
11 could generate profits, falsely taking in
12 investors, creating false stories to the local
13 medial and making statements to local press
14 regarding false claims made by his clients in order
15 that Scott Rothstein, who currently sits in jail,
16 could defraud, along with his other partners of his
17 fimi, local Florida investors, Mr. Scarola, out of
18 millions of dollars.
19 BY MR. SCAROLA:
20 Q. When did these other people whose identity you
21 can't remember tell you these things that Brad Edwards
22 did?
23 A. Sometime in the past year.
24 Q. How many other people were there who told you
25 these things about Mr. Edwards? 1
2
3
4
5
6
7
8
9
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25 themselves or were these anonymous callers?
MR. PIKE: Form. 1
THE WTINESS: Sitting here today, Mr. Scarola,
I don't recall with specificity.
BY MR. SCAROLA:
Q. What specifically did Mr. Edwards allegedly
communicate to the Daily News to, quote, gin up these
allegations, unquote?
A. The newspapers have quoted Mr. Edwards -- not
quoted Mr. — newspapers have made allegations referred
to as Mr. Edwards' statements.
MR. SCAROLA: Would you read the question
back, please, Sandy?
(Pending question was read.)
MR. PIKE: Did he answer your question?
MR. SCAROLA: No.
MR. PIKE: Are you asking him again?
THE WITNESS: So you're asking the question
again?
BY MR. SCAROLA:
Q. Yes.
THE WITNESS: Sony. Could you repeat the
question again?
(Pending question was read.)
THE WITNESS: He alleged that third parties
Page 31
1 A. I don't recall with specificity.
2 Q. Well, do you recall in any degree how many
3 there were?
4 A. I would say, probably five to ten.
5 Q. Where were you when these conversations took
6 place that you can't -- the identity of whose
7 participants you can't remember?
8 MR. PIKE: So we're clear, within the last
9 year -- correct? — timewise?
10 MR. SCAROLA: Well, that's what your client
11 said. I don't believe a word he says, but that's
12 what he said.
13 MR. PIKE: Form. Objection. Overbroad.
14 THE WITNESS: Again, sir?
15 BY MR. SCAROLA:
16 Q. Yes, sir. Where did these conversations with
17 these five to ten people take place whose identity you
18 can't remember?
19 MR. PIKE: Form.
20 THE WITNESS: On the telephone.
21 BY MR. SCAROLA:
22 Q. Who initiated the phone calls?
23 A. Sir, these questions, l have no -- I don't
24 have any recollection.
25 Q. Did the people who were on the phone identify 1
2
3
4
5
6
8
9
10
11.
12
13
14
15
16
17
18
19
20
21
22
23
24
25 Page 33
had already been involved in some allegations to do
with sexual misconduct.
BY MR. SCAROLA:
Q. Which third parties?
A. 1 don't recall sitting here today.
Q. Involved how?
MR. PIKE: Form.
THE WITNESS: If 1 recall with specificity, if
I had the articles in front of me, l would be able
to recall. Maybe next time.
BY MR.. SCAROLA:
Q. What does "gin up these allegations' mean?
MR. PIKE: Form.
THE WITNESS: It means craft allegations of
multi-million dollar cases; in fact, alleging in
case damages of $50-million, settlements in
order for Scott Rothstein and the rest of
Mr. Edwards' partners to fleece unsuspecting
investors out of millions and millions of dollars
based on cases that didn't exist or alleged cases
that I had settled.
Can I take a break?
VIDEOGRAPHER: Going off video record, 10:50.
(Brief recess.)
VIDEOGRAPHER: We're now on video record at
9 (Pages 30 to 33)
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1 10:57 a.m.
2 BY MR. SCAROIA:
3 Q. Was your reference to, quote, gin up these
4 allegations, unquote, a reference to allegations made
5 against you?
6 MR. PIKE: Form.
7 THE WITNESS: As part of the vast conspiracy
8 of the Rothstein firm and Mr. Edwards'
9 participation in it, it has been alleged that many
10 cases were fraudulently brought — alleged that
11 have been brought; ginned up, meaning, crafted,
12 multi-million dollar numbers put on cases in order
13 to fleece investors, where his partner, Scott
14 Rothstein, currently sits in jail for just those
15 purposes, Mr. Scarola.
16 BY MR. SCAROLA:
17 Q. My question to you is: Did the reference to,
18 quote, gin up these allegations refer to allegations
19 against you?
20 A. Reported in the newspaper the answer is, yes.
21 And others, but specifically me, yes, by the newspaper
22 reports.
23 Q. Specifically what are the allegations against
24 you which you contend Mr. Edwards ginned up?
25 A. I would like to answer that question. A, many Page 36
1 Q. I want to know whether when you use the phrase
2 "gin up" and the word "crafted," which you have told us
3 is synonymous with gin up, --
4 A. Yes.
5 Q. -- you mean fabricated?
6 A. I'm sorry. On advice of Counsel, sir, and
7 I've answered that question before, but if you didn't
8 hear me the first time, I must assert my Fifth, Sixth
9 and 14th Amendment Right.
10 Q. What specific discovery proceedings did
11 Mr. Edwards engage in which you contend form the basis
12 for your lawsuit?
13 A. The discovery proceedings of bringing my
14 attorneys to various people that had nothing to do with
15 any of his clients or these lawsuits.
16 Q. Which various people? Who?
17 MR. PIKE: Form.
18 THE WITNESS: For example, he tried to depose
19 Bill Clinton, strictly as a means of getting
20 publicity so diat he and his firm could
21 fraudulently steal, craft money from unsuspecting
22 investors in South Florida out of millions of
23 dollars.
24 BY MR. SCAROLA:
25 Q. Who else besides Bill Clinton is included in
Page 35
1 of the files and documents that we've requested from
2 Mr. Edwards and the Rothstein firm are still
3 unavailable.
With respect to anything that I can point to
5 today, I'm, unfortunately, going to have to take the
6 Fifth Amendment on that, Sixth and 14th.
7 Q. You seemed to be defining ginned up as
3 crafted; is that correct?
9 A. That's correct.
10 Q. Does ginned up or crafted mean fabricated?
11 MR PIKE: Form.
12 THE WITNESS: I'm sorry, Mr. Scarola.
13 understand that you are trying to back door your
14 way into a waiver of my Fifth Amendment. But
15 respect to that question, I'm going to have assert
16 my Fifth Amendment, Sixth Amendment and 14th
17 Amendment Right.
18 BY MR. SCAROLA:
19 Q. So you are asserting your Fifth Amendment,
20 Sixth Amendment and 14th Amendment Right to remain
21 silent about what you mean when you use the words "gin
22 up" and "crafted;" is that correct?
23 A. I don't believe that was your question.
24 Q. Yes, sir, that's exactly my question.
25 A. Would you repeat the question for me? Page 37
1 your reference to various people?
2 A. There are people in California There are
3 people in New York.
4 Q. Would you name them for us, please?
5 A. I'm sony. Sitting here today, Mr. Scarola,
6 Fm going to have to assert my Fifth Amendment, Sixth
7 Amendment and 14th Amendment Right.
8 Q. Let's then talk about Bill Clinton, by whom !
9 assume you mean fonner President Clinton; is that
10 correct?
11 A. That's correct.
12 Q. All right. Do you know former President
13 Clinton personally?
14 A. I'm sorry. As I sit here today, though Id
15 like to answer that question, on advice of my Counsel,
16 at least today, I'm going to have to take the Fifth,
17 Sixth and 14th Amendment.
18 Q. You said something about Mr. Edwards sharing
19 13 boxes of information with somebody —
20 A. Yes.
21 Q. — as forming part of the basis for your
22 lawsuit against Mr. Edwards, correct?
23 A. Correct.
24 Q. All right. With whom did Mr. Edwards share
25' these 13 boxes of infomartion?
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1 A. It has been reported in the Scherer Complaint
2 that he shared those boxes with the partners of his firm
3 that was then formally accused by the U.S. Attorney,
4 sir, of being a criminal enterprise.
5 MR. PIKE: And just for purposes --
6 BY MR. SCAROLA:
7 Q. Do you remember my question?
8 A. You asked me who he shared it with?
9 Q. Yes.
10 A. The partners of his firm, sir.
11 Q. Okay. So part of the basis of your lawsuit is
12 that Mr. Edwards allowed members of his own law firm to
13 see 13 boxes of information; is that correct?
14 A. No. that's not correct. My claim is that the
15 13 boxes of information that wore shown to investors by
16 Mr. Edwards' partners, 13 boxes that we've been told by
17 the press contain multiple cases, fraudulently -- and if
18 you like the word -- fabricated in order to fleece
19 investors out of money. The 13 boxes were shared with
20 investors, Mr. Edwards, Mr. Edwards' partners and some
21 of those partners currently under inditement, the others
22 already sitting in jail.
23 Q. I had asked you earlier whether ginned up and
24 crafted meant fabricated and you asserted your Fifth
25 Amendment privilege. Page 40
1 Amendment Right, sir.
2 Q. Your Complaint also makes reference to a claim
3 on behalf of Jane Doe, referred to as Jane Doe versus
4 Epstein, case number 08-CIV-80893, a case pending in the
5 United States District Court for the Southern District
6 of Florida.
7 Is it your contention that the claim on behalf
8 of Jane Doe is a fabricated claim?
9 A. Sir, though I'd like to answer that question,
10 as well as every one of your other questions here today,
11 today I'm going to have to assert my rights as under the
12 Constitution of the Fifth, Sixth and 14th Amendment.
13 Q. Do you blow the real name of the person
14 referred to as Jane Doe in that case?
15 A. i don't know which — I5n sorry, sir. Ho
16 not, sitting here today.
17 Q. Did you ever have personal contact with the
18 person referred to by the name Jane Doe in that lawsuit?
19 A. I'm sorry, sir. Sitting here today, I'm going
20 to have to assert my Fifth, Sixth and 14th Amendment
21 Right.
22 Q. When did you first meet the person referred to
23 as Jane Doe?
24 A. Sir, though I'd like to answer each and every
25 one of your questions here today, at least with respect
Page 39
1 Are you now telling us that there were claim
2 against you that were fabricated by Mr. Edwards?
3 A. I'm going to again assert my Fifth, Sixth and
4 14th Amendment Right, sir.
5 I would respond that the newspapers are very
6 clear that the cases were fabricated.
7 Q. Which newspaper said which case was
fabricated?
9 A. Bob Norman's blog said most of the eases were
10 fabricated, to my best recollection.
11 The Scherer Complaint alleged many fabricated
12 cases, sir.
13 Q. Well, which of Mr. Edwards' cases do you
14 contend were fabricated?
15 A. Again, we've requested most of the --
16 information from the bankruptcy trustee. We've been
17 unable — Mr. Edwards has not given us the total file,
18 but respect to any individual, I would have -- at the
19 moment I would have to assert my Fifth, Sixth and 14th
20 Amendment claim, sir.
21 Q. So you will not answer questions about whether
22 the claim on behalf of.. was fabricated; is that
23 correct?
24 A. I believe I've already answered that, but, if
25 again, have to assert my Fifth, Sixth and 14th Page 41
1 to that question, I'm going to have to assert my rights
2 under the Sixth Amendment, 14th Amendment and Fifth
3 Amendment.
4 Q. Where did you first meet the person referred
5 to as Jane Doe?
6 A. Sir, though I'd like to answer that question
7 here today, at least today on advice of Counsel, I'm
8 going to have to assert my Fifth Amendment, Sixth
9 Amendment and 14th Amendment Right
10 Q. How many times have you been in the physical
11 presence of the person referred to as Jane Doe?
12 A. The person referred to as Jane Doe?
13 Q. Yeah. How many times have you been in her
14 physical presence?
15 MR. PIKE: Form.
16 THE WITNESS: At least -- at least sitting
17 here today, Mr. Scarola, I'm going to have to
18 assert my Fifth Amendment, Sixth Amendment and 14th
19 Annulment Right
20 BY MR. SCAROLA:
21 Q. Dld you ever have any physical contact with
22 'arse Doe?
23 MR. PIKE: Form.
24 THE WITNESS: Now, for this purposes, you're
25 assuming this Jane Doe is somebody I know? 1 don't
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1 think so, since this question makes no sense to me.
2 BY MR. SCAROLA:
3 Q. You have alleged in your Complaint that there
4 is a claim on behalf of Jane Doe versus Epstein pending
5 in the Federal District Court of the Southern District
of Florida.
7 I would like to 'mow whether you ever had any
a physical contact with the person referred to as Jane Doe
9 in that Complaint?
10 A. Ah, that lane Doe. Pm sorry. But sitting
11 here today, Mr. Scuola, I'm going to have to refuse to
12 answer that question based on the Fifth Amendment, Sixth
13 Amendment and 14th Amendment.
14 Q. Did you ever exchange any money or gifts with
15 Jane Doe?
16 A. Again, Mr. Scarola, sitting here today, fm
17 going to have to on advice of Counsel assert my Sixth
18 Amendment, Fifth Amendment and 14th Amendment Right.
19 Q. Your Complaint makes reference to a case
20 stylec=aetsus Epstein, case number
21 502008CA028058XXXXMBAB, a case pending in the Circuit
22 Court of Pahn Beach CotFlorida.
23 Do you know who MI. is?
24 A. Sitting here today, Mr. Scarola, I'm going to
25 have to assert my rights as under the Fifth, Sixth and 1
2
3
4
5
6
7
8
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25 Page 94
to as M.?
A. I believe it is
Q. How long have you known
A. Well, with respect to that question,
Mr. Scarola, I'm going to have to assert my Fifth, Sixth
and 14th Amendment Rights, though rd like to answer
every, single question you have about
Q. How many times have you been in the physical
presence of.?
A. I'd like to answer every question about..
that you have today, Mr. Scarola; however, on advice of
Counsel, Fm going to have to assert my Fifth, Sixth and
14th Amendment Right.
Q. How old is M.?
A. I don't know.
Q. How old was she when you met her?
A. Mr. Scarola, Fm going to have to assert my
rights under the Fifth, Sixth and 14th Amendment on
advice of Counsel, though I would like to answer every
one of these questions.
Did you ever have any physical contact with
A. Mr. Scarola, once again, I would like to
answer each one of your questions here today, but on
advice of Counsel rm going to have to assert my Fifth,
Page 43
1 14th Amendment.
2 Q. Have you ever learned the real name of.'"
3 A. Yes, sir.
4 Q. Did that person whose real name you learned
5 ever spend any time in your physical presence?
6 A. Sir, at least sitting here today, I would like
7 to answer each and every one of your questions regarding
8 your ft and — are we not allowed to use the names of
9 these people, sir?
10 MR. PIKE: In the past — in the past cases
11 the names of these individuals have been utilized
12 for deposition purposes.
13 Brad Edwards, sitting here today, knows that
14 we have used; however, any documents that are filed
15 with the Court will redact those names.
16 So the answer to the question is, yes, for
17 purposes of this deposition, to the extent you know
18 the names of individuals, you can utilize them with
19 agreement of Mr. Edwards.
20 MR. EDWARDS: 1 have no problem with that.
21 THE WITNESS: I think to avoid conflision, so
22 there's not — I know who you're talking about.
23 That's all.
24 BY MR. SCAROLA:
25 Q. What is the real name of the person referred 1
2
3
4
5
6
7
8
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
25 Page 45
Sixth and 14th Amendment Right.
Q. Did you ever exchange any money or gifts with
A. Sir, Tel like to answer every question you
have about..; however, today, on advice of Counsel
Pm going to have to assert my Fifth, sixth and 14th
Amendment Right.
Q. Did you ever cause any money or gifts to be
delivered to..?
A. Mr. Scarola, as I've answered most of your
ILquestions here today regarding I would like to
answer every question regarding ; however, today, on
advice of Counsel, I'm going to have to assert my Fifth,
Sixth and 14th Amendment Right because though I would
choose to do so, I've been told that if I do so, I risk
losing my Counsel's representation.
Q. What is the actual value that you contend the
claim of.. against you has?
MR. PIKE: Form. Relevance.
THE WITNESS: _i riS_though I'd like to answer
every question about M. and her claims and the
claims of your other people, on advice of Counsel
here today, I cannot do so. I must assert my
rights under the Sixth, Fifth and 14th Amendment.
BY MR. SCAROLA:
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Would your answer be the same with regard to
and to Jane Doe?
MR. PIKE: Fm going to instruct you if your
4 answer is the same, to invoke in full.
5 THE WITNESS: With respect to, I believe, Janc
o Doe — and who is the other person? Fm sorry.
7 BY MR. SCAROLA:
3 Q.
9 A. Thmigh I'd lthe to answer your claims
10 with respect to all three of Mr. Edwards' clients, on
11 advice of Counsel, at least today, I'm going to have to
12 invoke my Fifth, Sixth and 14th Amendment Rights.
13 Though I'd prefer to answer the question, I've been told
14 that if I choose to do so, I risk losing their
15 representation.
16 Q. Among those items listed by you as wrongdoing
17 on the part of Mr. Edwards forming the basis for this
18 lawsuit is that he, quote, counseled his clients to make
19 multi-million dollar claims against you; is that
20 correct?
21 MR. PIKE: Form. Document speaks for itself.
22 THE WITNESS: Doctnnent speaks for itself.
23 BY MR. SCAROLA:
24 Q. I'm not asking about a document. I'm asking
25 you about the list of wrongdoing that you gave us during Page 48
1 A. No. I answered that question, which is, I'd
2 like to know.
3 Q. Yes. But that isn't an answer to my question.
4 My question is: By whom was Mr. Edwards
5 employed at the time that he initiated litigation
6 against you? Do you know the answer to that question?
7 A. I'd have no way of knowing the answer to that
8 question, sir.
9 Q. Among the allegations of wrongdoing against
10 Mr. Edwards which you contend form the basis of this
11 lawsuit is something having to do with sending an
12 investigator to California.
13 Would you tell me, please, more specifically
14 what it is that Mr. Edwards did with regard to sending
15 an investigator to California which you contend
16 justifies a legal claim against Mr. Edwards.
17 MR. PIKE: Form. And also mischaracterizes
18 the witness' testimony.
19 THE WITNESS: Reported widely in the
20 newspapers is the use of illegal activities, wire
21 taps, and me
📷 Images in this document (37 detected; 6 largest described)
AI-generated factual descriptions of embedded images (llava:13b). These are searchable across the corpus.
[Image 1] The image shows a document with text, which appears to be a transcript or a page from a legal or official report. The text is organized into numbered paragraphs, and there are references to names, dates, and locations. The document includes questions and answers, suggesting it might be from a deposition or a court proceeding. The text is dense and formal, typical of legal or official documents. Th
[Image 2] The image shows a document with text, which appears to be a transcript of a conversation or interview. The text is organized into numbered paragraphs, and there are visible names, such as "Mr. Fisk," "Mr. Sanders," and "Mr. Fisk." The document is titled "Transcript of Interview with Mr. Fisk." The text includes statements and questions related to a legal case, with references to "the case against
[Image 3] The image shows a document with text, which appears to be a transcript of a conversation or interview. The document is numbered and includes questions and answers, with the questions on the left and the answers on the right. The text is too small to read in detail, but it seems to be a formal or professional setting, possibly related to legal or medical matters, given the context of the questions
[Image 4] The image shows a document with text, which appears to be a transcript of a conversation or a meeting. The document is numbered and includes sections with headings such as "Page 1," "Page 2," and so on. There are lines of text with names and dates, indicating the participants and the timeline of the conversation. The text is black on a white background, and the document is presented in a landscape
[Image 5] The image shows a document with text, which appears to be a page from a court transcript or a legal document. The text is organized into numbered paragraphs, and there are visible names, dates, and other textual information. The document is titled "UNITED STATES OF AMERICA," and it mentions a defendant named "JOHN DOE." The text includes statements, questions, and responses related to legal procee
[Image 6] The image appears to be a document scan, specifically a page from a court transcript. It contains text that is organized into numbered paragraphs, each with a heading and corresponding questions and answers. The text is dense and formal, typical of legal proceedings. There are no visible names, dates, places, or logos that can be discerned from this image. The document is focused on the content of