IN THE CIRCUIT COURT OF THE

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants. VIDEOTAPE DEPOSITION CONT'D OF BRADLEY EDWARDS VOLUME II OF II PAGES 110 - 250 October 10th, 2013 10:00 A.M. - 2:30 P.M. 401 East Las Olas Blvd., Suite 1400 Fort Lauderdale, FL Stenographically Reported By: WENDY ROBERTS, RPR Notary Public, State of Florida Empire Legal Support, Inc. Fort Lauderdale Office Phone: EFTA01089049 Bradley J. Edwards taken on 10/10/20 I 3 APPEARANCES: ATTORNEY(S) FOR MR. EPSTEIN: TONJA HADDAD COLEMAN, ESQUIRE Tonja Haddad, PA 315 SE 7th St Ste 301 Fort Lauderdale, Florida 333013158 Phone: Fax: E-Mail: FRED HADDAD, ESQUIRE Fred Haddad PA 1 Financial Plz Ste 2612 Fort Lauderdale, Florida 333940061 Phone: Fax: E-Mail: JACK GOLDGERGER, ESQUIRE Atterbury Goldberger ■ Al 250 S Australian Ave Ste 1400 West Palm Beach, Florida 334015015 Phone: Fax: E-Mail: ATTORNEY FOR BRADLEY EDWARDS: WILLIAM KING, ESQUIRE Searcy Denney Scarola ■ Al 2139 Palm Beach Lakes Blvd West Palm Beach, Florida 334096601 Phone: Fax: E-Mail: ALSO PRESENT: JEFF EPSTEIN, PLAINTIFF (telephonically) DEBRA FEIN, LAW CLERK Empire Legal Support. Inc. Page: I I 1 EFTA01089050 Bradley J. Edwards taken on 10/10/2013 INDEX WITNESS: BRADLEY EDWARDS Direct Examination cont'd by MR. HADDAD EXHIBITS Page 114 PLAINTIFF'S: EXHIBITS: Description Page Comp. No. 1 Response to RP#7 Correspondence between BJE and US Government RE Epstein in BJE Possession 66 pages 244 Comp No. 2 E-mail from Russell Adler to Bradley Edwards RE: Oct. 28th depo, sent on 10/14/09 58 pages 244 Empire Legal Support. Inc. Page: 112 EFTA01089051 Bradley J. Edwards taken on 10/10/2013 1 (Continued from Volume I dated May 15th, 2013.) 2 Videotape Deposition taken before Wendy Roberts, 3 Registered Professional Reporter and Notary Public in 4 and for the State of Florida at Large, in the above 5 cause. 6 _ _ _ 7 THE VIDEOGRAPHER: We are now on the video 8 record. Today's date is October 10th, 2013. The 9 time is 10:15 A.M. Would counsel please state 10 their appearances for the record. 11 MR. KING: William King, Searcy Denney Scarola 12 Barnhart & Shipley for Mr. Edwards. 13 MR. GOLDBERGER: All right. Jack Goldberger, 14 Atterbury, Goldberger & Weiss, West Palm Beach, on 15 behalf of Jeffrey Epstein. 16 MR. INDYKE: Darren K. Indyke of Darren K. 17 Indyke, PLLC, on behalf of Jeffrey Epstein. 18 MR. HADDAD: I am Fred Haddad -- Fred Haddad 19 on behalf of Jeff Epstein. 20 MS. COLEMAN: Tonja Haddad Coleman, Tonja 21 Haddad, PA, on behalf of Jeffrey Epstein. 22 MS. FEIN: Debbie Fein of Tonja Haddad, PA, on 23 behalf of Jeffrey Epstein. 24 MR. HADDAD: This is a continuation of the 25 deposition of, I guess it was a couple months ago Empire Legal Support. Inc.. Page: 113 EFTA01089052 Bradley I. Edwards taken on 10/10/2013 1 that we stopped. 2 Thereupon: 3 BRADLEY EDWARDS 4 having been previously duly sworn or affirmed, was examined and testified as follows: 6 DIRECT EXAMINATION (Cont'd) 7 BY MR. HADDAD: 8 Q And Mr. Edwards, since the deposition of last 9 time, I guess some discovery has been provided, correct? 10 A Right. 11 Q All right. And those would be in response to 12 request for production No. 7, I guess, correspondence, 13 and I think that's what that means R4P, correspondence 14 between BJE and U.S. Government regarding Epstein, that 15 was in your possession, correct? 16 A Okay. 17 Q That's what this appears to be. I think that 18 came from Scarola, if I'm not mistaken. Under response 19 to request to produce, or Scarola, Searcy Denney, II al. 20 A Okay. It looks like correspondence between 21 myself and the United States -- 22 Q All right. 23 A -- Attorney's Office. 24 Q All right. And that would comp comprise 25 all of the correspondence that was actually gauged Empire Legal Support, Inc. Page: 114 EFTA01089053 Bradley J. Edwards taken on 10/10/2013 1 between yourself and either, what's his name, , or 2 Miss 3 to call her? 4 5 6 7 , whatever you want A That's my understanding. Q All right. Well, this all came from your files and from your records, correct, e-mails, whatever you call those things where you store e-mail servers or 8 whatever there? 9 10 11 12 A You sent a request, I did whatever searches that I could to come up with all of the documents between us and I turned them over to my attorney who turned them over to you. 13 Q All right. And I don't know if that request 14 contained anything regarding any memorandums of 15 conversations that you might have had, telephonic 16 conversations or in-person conversations. Did any of 17 those exist? 18 A Not to my recollection. 19 Q Okay. So -- 20 A I think that's everything. 21 Q That's what I'm asking, everything that there 22 is, correct? 23 A I believe so. 24 Q All right. And this would take -- some of 25 it's not numeric -- not numerically -- not -- Empire Legal Support. Inc. Page: 115 EFTA01089054 Bradley J. Edwards taken on 10/10/20 I 3 1 A Chronological? 2 Q Chronological, thanks for the word, 3 chronologically presented. But I note the first thing I 4 have is to and it states something about 5 October 9, 2008, regarding some potential false 6 statements the Government made in a sworn declaration 7 with the above -captioned case. That was you writing to 8 them, correct? 9 A What I'm looking at right now appears to be on 10 my letterhead from back then, so I would say yes. 11 Q All right. And whatever it says, it says -- 12 A That's my signature. 13 Q Okay. And that would be the same with all of 14 these? Let me -- let me just go through them. Let me 15 see which ones I'm going to ask. 16 MR. KING: Take your time to look at them 17 MR. HADDAD: Yeah. 18 MR. KING: -- if you think you need to. 19 MR. HADDAD: What do you think, I altered 20 them? 21 MR. KING: No, no, no, no. Because I'll need 22 to take a look at them if you have any questions 23 about -- 24 MR. HADDAD: I understand that. 25 Empire Legal Support. Inc. Page: 1 I6 EFTA01089055 Bradley J. Edwards taken on 10/10/2013 1 BY MR. HADDAD: 2 Q Now, the letter here that I'm looking at on 3 March 15th from Wifredo Ferrer to Paul G. Cassell, and I 4 guess it was turned over by you in this discovery, and 5 that was on March 25th of 2011, I believe, correct? 6 A It's dated March 15th, 2011. 7 Q Oh, I'm sorry, my glass -- even with glasses, 8 I can't see that well. All right. 9 So that was March 15, 2011. Paul Cassell, I 10 take it, was your co-counsel who was some kind of law 11 professor and judge and all that stuff? 12 A Right. 13 Q All right. And he was co-counsel with you on 14 these cases? 15 A Right. 16 Q Does he still remain co-counsel with you on 17 these cases? 18 A Well, the only case that is remaining is the 19 Crime Victims Rights Act case -- 20 Q Yeah. 21 A -- and yes. 22 Q But that's been -- that's in the 11th Circuit, 23 right, now 24 A Right. 25 Q -- in -- pending stayed or briefing, I don't Empire Legal Support. Inc. Page: 117 EFTA01089056 Bradley J. Edwards taken on 10/10/20 I 3 1 know what, something is out there, correct? 2 A It has been fully briefed. I think oral 3 argument is January, February, but yes. 4 Q All right. And he's still on that case with 5 you, correct? 6 A Yes. 7 Q All right. Would this letter have been 8 sent -- when this letter was sent to Mr. Cassell, would 9 you have received a copy of it contemporaneously? 10 A I can't -- I don't know. 11 Q All right. But somehow it -- 12 A I either got it from Paul -- 13 Q Right. 14 A -- or I got it from them and I don't really 15 remember. Am I copied on it? 16 Q I don't see a CC to you. No. 17 A Okay. 18 Q So you are familiar with this though, it was 19 in your files? 20 A Right, I -- I was involved in the whole 21 process, so, yeah, I'm familiar with it 22 Q Yeah, I understand that but I 23 A Yeah, I'm familiar with it. 24 Q -- I don't want to speculate though. 25 A No. Empire Legal Support. Inc. Page: 1 I8 EFTA01089057 Bradley J. Edwards taken on 10/10/2013 1 Q I want the answer from you. 2 All right. And then on September 29th, 3 2011 -- on September 29th, 2011, there is another letter 4 to the United States Attorney, Mr. Ferrer, and it's a 5 follow-up on Jeffrey Epstein by the same Mr. Cassell, 6 correct? 7 A That's what it appears to be. 8 9 Q All right. There is a carbon copy to and , correct? 10 A Okay. 11 12 13 Q Okay doesn't answer. Yes or no? I need A That's what it appears to be. Q Yeah, but -- yeah, I know. I am just asking 14 you -- 15 A I mean, I didn't send the letter. I'm looking 16 at the same thing you are looking at. 17 Q I know. 18 A Paul signed it and then he copied 19 and 20 Q Do you know how you received a copy of this? 21 A I don't remember right now. 22 Q But it is in your records? 23 A Yes. 24 Q And would you have read it at the time it came 25 in? Empire Legal Support. Inc. Page: 119 EFTA01089058 Bradley J. Edwards taken on 10/10/2013 1 MR. HADDAD: Where is that thing of hers? 2 MR. GOLDBERGER: Chill. Chill. 3 MR. HADDAD: Chill, I always chill. 4 THE WITNESS: What is your question? 5 MR. HADDAD: I don't remember. 6 A I think -- I think it was whether or not I 7 received it at the time that it was sent, and I don't -- 8 I don't know exactly the timing of when I received this 9 letter. But it would have been close in time to when it 10 was sent. I don't know exactly. 11 BY MR. HADDAD: 12 Q So you could -- you all were working these 13 together, correct? 14 A Yeah, right. 15 Q And whatever is in these documents speaks for 16 themselves, correct? 17 A Exactly. 18 Q Would they have engendered by you any 19 follow-up calls to the U.S. Attorney or to anyone in the 20 U.S. Attorney's Office? 21 A No. 22 Q All right. Things such as -- at the same 23 time, this -- Rule 26 disclosures, and Jane 1 -- and 24 Jane Doe 1 and Jane Doe 2, those are your CRVA {SIC} 25 cases, correct? Empire Legal Support. Inc. Page: 120 EFTA01089059 Bradley J. Edwards taken on 10/10/2013 1 A Just tell me what your question is. I'm not 2 sure that-- 3 Q I said CR -- John Doe 1 and 2 your CRVA cases? 4 A Right. 5 Q All right. And then this is the -- 6 A That's the case number for it. 7 Q Okay. And what I'm asking you is, this is a 8 document sent by Farmer, Jaffe, Weissing, Edwards, 9 Fistos, and then what, you emulate Searcy and Denney to 10 have as many names as they do? I guess. Any rate, this 11 is on your letterhead and it's sending the United States 12 Attorney's Office a list of, I guess, discovery; is that 13 correct? 14 A Well, no, I think that we were just complying 15 with the 26(a) witness disclosures in that case. There 16 has always been a -- a -- I don't want to say 17 disagreement because I don't think anybody actually 18 knows whether this case falls under the civil rules of 19 procedure or criminal, but an abundance of caution, if 20 it fell under the civil rules, we felt that those 21 disclosures were necessary. 22 Q All right. But let me ask you this: Was this 23 in response to a request to produce by the Government or 24 was this a voluntary disclosure of what you thought you 25 had as evidence? That is, I mean, was there a civil -- Empire Legal Support. Inc. Page: 121 EFTA01089060 Bradley J. Edwards taken on 10/10/2013 1 2 you know, I'm not that adept at the rules of civil procedure, but I understand that before you respond to 3 something, there is usually a request to produce, 4 request to disclose, interrogatories, something like 5 that. 6 7 8 A Right. Q But you can make a voluntary disclosure at times if you wish to -- to have litigation go forward 9 faster, as it were. I don't know the proper term -- 10 A Right. 11 Q -- they use in civil litigation. 12 A All right, I will tell you a couple things. 13 One is, the only thing that -- that I'm a little uneasy 14 about right now is that we are getting into work product 15 not on this case, we are not on the underlying case, but 16 on the Crime Victim's Rights Act case that is still 17 actively being prosecuted. However, to the extent that 18 I can answer this question, the purpose of this was 19 solely because Judge Marra, I believe, was of the 20 mind-set that this fell into a civil category rather 21 than criminal, and therefore, Rule 26 disclosures would 22 need to be made. And so in hopes that the Government 23 would reciprocate, we provided our witnesses and 24 expected for them to do the same. 25 Q All right, but I understand what you are Empire Legal Support. Inc. Page: 122 EFTA01089061 Bradley J. Edwards taken on 10/10/2013 1 saying there. The simple thing -- my simple question is 2 this. Were you in the litigation status that you needed 3 to produce this or was this a voluntary production for 4 purposes of hoping the Government would respond to you? 5 A We felt it was necessary. 6 Q That's not my question. 7 A I understand that. 8 Q Was this -- okay 9 A I don't know the answer to your question, 10 though. 11 Q You are an attorney, you are fairly bright and 12 we went through that last time, I don't want to have to 13 go through that again, how smart you are. This was -- 14 you're saying here, if you are correct that the civil 15 rules apply, that's , then both sides of the 16 case are obligated to make voluntary initial disclosures 17 under Rule 26(a) . We are writing to make our initial 18 disclosures and ask that you promptly do the same, 19 correct? 20 A We felt it was our obligation. 21 Q I can read what it says here. 22 A Okay. 23 Q We are making our initial disclosures and ask 24 you to do the same, voluntary initial disclosures, okay? 25 A Right. Empire Legal Support. Inc. Page: 123 EFTA01089062 Bradley J. Edwards taken on 10/10/2013 1 Q You felt it was necessary, it wasn't required 2 by rule, by anything, it was a voluntary thing you are 3 doing, as you are say in your own words, correct? 4 A Correct. 5 Q Did you get a response from the Government? 6 A I don't remember. 7 Q Okay. 8 A This is something from March of 2011, I just 9 don't remember. 10 Q You don't remember whether or not the 11 Government provided you a list of their discovery, their 12 evidence, their witnesses or anything, whatever there is 13 in response to Rule 26 that they are required to comply 14 with? 15 A I can tell you they've provided us very 16 little, much less than we wanted. Have they provided us 17 nothing? I don't know that that's true. 18 Q Well, they provided you a letter saying you 19 have no business being in this thing, but besides that, 20 have they done anything in here? 21 A I don't remember that. 22 Q Okay. 23 A The -- the dockets on PACER will speak for 24 itself though, if they've made those disclosures, I 25 think -- Empire Legal Support. Inc. Page: 124 EFTA01089063 Bradley J. Edwards taken on 10/10/2013 1 Q I don't know how to open an e-mail, as you 2 well know. I am asking you a simple question. Do 3 you -- 4 A I'm trying, Fred. 5 Q I understand you are trying, Brad, I 6 appreciate that. We all try. A little harder at my age 7 than yours but we all try. I had to get one age joke in 8 there. 9 All right. Now, correspondence has been going 10 on since 2008 -- 2008 regarding this CRVA, correct? 11 A That's correct. 12 Q My -- excuse me, I don't want to stutter. 13 With everything you produced, I'm at a loss to find 14 anything that was produced while you were with 15 Rothstein; is that correct? 16 A That may be correct. 17 Q I would like you to look through that because 18 I really want to know whether or not anything was 19 produced while you were with -- and Rothstein would be 20 Rothstein, Rothstein and Adler? 21 A Right. 22 Q No, Rothstein from -- 23 MS. COLEMAN: Rosenfeldt. 24 BY MR. HADDAD: 25 Q Rosen -- Rosenfeldt and Adler, your former Empire Legal Support. Inc. Page: 125 EFTA01089064 Bradley J. Edwards taken on 10/10/2013 1 partnership. 2 A Was anything produced between 3 Q Yeah, did you -- a CRVA -- 4 A -- April and October 2009? 5 Q Yeah, when you -- 6 A Right. 7 Q -- were with that firm, was there anything 8 going on between you and the Feds while you were with 9 A Well, what you are asking though is, was 10 anything produced in the Crime Victims' Rights Act 11 while -- between -- 12 Q Okay. Let me put it this way, I mean in the 13 way of pleadings, in the way of pleadings or any type of 14 correspondence with the Federal Government. You were 15 there five months? 16 A Five or six months. 17 Q During those six months, let's give it six 18 months. 19 A Fine. 20 Q Okay. That you were with -- in this building? 21 A Correct. 22 Q The building that Scott built, the house that 23 Scott built. Is that like The House That Ruth Built or 24 something? 25 At any rate, at any time, were there any Empire Legal Support. Inc. Page: 126 EFTA01089065 Bradley J. Edwards taken on 10/10/2013 1 correspondence between the Federal Government and 2 Bradley Edwards' partner, Rothstein, Rothstein and 3 Adler, as the way you signed off -- or Bradley 4 Edwards -- anything? 5 A Come on, come on. You're going to have to go 6 back in the bag and grab a question that I can actually 7 answer. 8 Q Look through all of this and tell me if this 9 is everything you have, if there is one thing during the 10 period of time you were with Rothstein? 11 A In this? 12 Q In -- well, that's everything you own, you 13 said, regarding the -- that -- that request to produce 14 regarding the CRVA, as well as the correspondence. 15 A All right. Correspondence. 16 MR. GOLDBERGER: I think you are one letter 17 away. 18 MR. HADDAD: Oh, what difference does it make, 19 he knew what I was talking about. Crime Rights, 20 Victims, Crime Victim Rights, okay. ASPCA, the 21 same thing. 22 THE REPORTER: Counsel, do you want that on 23 the record? 24 MR. HADDAD: You can type it, I don't care. 25 (Thereupon, a discussion was had off the Empire Legal Support. Inc. Page: 127 EFTA01089066 Bradley J. Edwards taken on 10/10/2013 1 record.) 2 A I don't see anything. 3 BY MR. HADDAD: 4 Q All right. Thank you. 5 MR. GOLDBERGER: Wait, let -- 6 MR. HADDAD: What? 7 MR. GOLDBERGER: I want to make sure the 8 question is answered, Fred, before you jump on the 9 next one. 10 THE WITNESS: I was going to say -- 11 MR. HADDAD: I don't have a next one to jump 12 onto yet. I just dug into a few things here this 13 morning when I got up getting my kid ready for 14 school. I just dog-eared a few things this morning 15 when I woke up, get my kid ready for school. 16 A You were going to ask me how to do that? Oh. 17 BY MR. HADDAD: 18 Q I have been doing it for 40-something years. 19 I have here, I forget where they came from, a 20 whole bunch of e-mails you turned over. 21 A Okay. 22 Q Since the last time we met, or since -- yeah, 23 since after that deposition, correct? These are e-mails 24 that were given over in discovery to Miss Coleman, I 25 believe, or somebody, to Mr. Indyke, is that -- huh? Empire Legal Support. Inc. Page: 128 EFTA01089067 Bradley J. Edwards taken on 10/10/2013 1 MR. INDYKE: To Fowler. 2 MR. HADDAD: To Fowler? 3 MR. INDYKE: Yes. 4 MR. HADDAD: Oh, how come we didn't -- okay. 5 A Right, this predates the last deposition. 6 BY MR. HADDAD: 7 Q All right. I -- well, did they ask you about 8 these, I don't think they would have? 9 A They would only be you, and I don't know if 10 you have or not. 11 Q I never saw them before. Well, I mean, you 12 can object. I'm going to ask. I don't see -- I didn't 13 see any questions or answers regarding any e-mails. 14 A I don't remember. 15 MR. KING: At the last deposition? 16 BY MR. HADDAD: 17 Q At the last deposition. In the first 18 deposition, Mr. Scarola didn't last -- let anybody ask 19 anything, so I'm not going to be long with these and 20 rather than go through a whole hearing, I mean, if am 21 out of order, okay, that is not unusual. 22 A What else is new, right? 23 Q That -- that -- yeah, I mean, this is just a 24 simple discovery depo. All I want to do is these, is 25 I've got a stack of Bates stamped things, I guess we Empire Legal Support. Inc. Page: 129 EFTA01089068 Bradley J. Edwards taken on 10/10/2013 1 found or somebody found, I don't know, of -- 2 A If you found them, I turned them over. 3 Q I -- I understand that. I just want 4 A I just don't want the record to make it seem 5 like they were floating around on the street. 6 Q Brad, no one is doubting your bona fides as 7 far as discovery is concerned. When I if I did that, 8 I would say it right out, I don't 9 A I know. 10 Q -- I don't hint around, you know that. All 11 right. 12 Look at -- but these would be dep -- these 13 would be e-mails that were actually during the course of 14 your time actually at -- 15 MS. COLEMAN: Can I mark this as an exhibit? 16 BY MR. HADDAD: 17 Q Rothstein, Rosenfeldt and Adler, I believe. 18 They are all in 2009, from June until -- actually, 19 think the last one is October 29th or 30th. Just look 20 through these, just for purposes -- I am not going to 21 sit here and ask you questions about everything or 22 and many of them, because, you know, they speak for 23 themselves, but I just want to make sure we are accurate 24 in what we have there, and those things would have been 25 things that you would have produced. Empire Legal Support. Inc. Page: 130 EFTA01089069 Bradley J. Edwards taken on 10/10/2013 1 MS. COLEMAN: While he is looking at that, 2 just so the video is clear, the request to produce 3 regarding the Government exhibits, I have attached 4 as Exhibit 1 to the deposition that he just went 5 over and those will be Exhibit 2. 6 MR. HADDAD: Oh, okay. I don't know how to do 7 that. 8 MR. GOLDBERGER: Yes. Yes, that's what we 9 want to do. 10 MS. COLEMAN: I'm the token civil lawyer in 11 the room. I thought I would just throw that out 12 there. 13 MR. HADDAD: Token woman in the room too. 14 MR. KING: So the Rule 26 disclosures to the 15 Government will be Exhibit 1; is that right? 16 MR. GOLDBERGER: Yes. 17 MS. COLEMAN: No, no -- 18 MR. GOLDBERGER: It will be part of it. 19 MS. COLEMAN: -- those -- those were 20 provided those -- the Exhibit 1 is responsive to 21 Request No. 7 on the Schedule A, to which 22 Mr. Edwards objected prior to the last deposition. 23 So they were responsive. 24 MR. KING: All I want to know is what is being 25 marked as Exhibit 1. Empire Legal Support. Inc. Page: 131 EFTA01089070 Bradley J. Edwards taken on 10/10/2013 1 MS. COLEMAN: It's all -- that's it. 2 MR. KING: This document -- 3 MR. GOLDBERGER: Your resp -- Edwards' 4 response. 5 MR. KING: Got it. 6 MS. COLEMAN: This is off the record. 7 (Thereupon, a discussion was had off the 8 record.) 9 A You want me to read through these? 10 BY MR. HADDAD: 11 Q Just look at them and see -- you know, you 12 don't have to read every word of -- word of them, I'm 13 not going to -- if I have one I'm going to ask you 14 something about, I will tell you. I am not here to try 15 to trick you yet. 16 (Thereupon, a discussion was had off the 17 record.) 18 THE VIDEOGRAPHER: The time is 10:36 A.M. We 19 are now coming off the video record. 20 (Thereupon, a discussion was had off the 21 record.) 22 THE VIDEOGRAPHER: The time is 10:40 A.M. We 23 are now back on the video record. 24 BY MR. HADDAD: 25 Q All right. So did you have the ability in the Empire Legal Support. Inc. Page: 132 EFTA01089071 Bradley J. Edwards taken on 10/10/2013 1 last couple of minutes to read through these e-mails, 2 correct? 3 A Yeah. 4 Q Do you recognize them? 5 A Some of them. 6 Q And some of them you do not recognize? 7 A Well, some of them, I'm on the e-mail -- 8 Q Right. 9 A -- some of them I'm not, so I do not recognize 10 the e-mail. 11 Q All right. The ones that you are not on, 12 obviously, you don't know if you've seen them before? 13 A Correct. 14 Q Okay. Do you know whether or not you saw them 15 at the time they were produced? 16 A Definitely not. I don't normally see them. 17 Q Oh, excuse me, produced for discovery. Did 18 you review these before they were produced in response 19 to discovery demand by, who is it, Greenberg? 20 MR. INDYKE: It was Fowler, I believe. 21 A Fowler White maybe. 22 MR. HADDAD: Oh, Fowler White. 23 MR. INDYKE: On demand by Fowler, yes. 24 MR. HADDAD: Yeah. 25 A I re -- I reviewed what I think was 25,000 Empire Legal Support. Inc. Page: 133 EFTA01089072 Bradley J. Edwards taken on 10/10/2013 1 page -- pieces of paper, so I -- at some point in time, 2 I think I have probably seen them. 3 BY MR. HADDAD: 4 Q Well, let -- let me just take one of these and 5 obviously who's Bill -- William J. Berger? 6 A He was an attorney at RRA, formerly a judge in 7 Palm Beach County. 8 Q All right. Who's Pat Carter? 9 A I don't know who Pat Carter is. 10 Q Who's Brad Edwards? 11 A That's me. 12 Q Who's Grace Torres? 13 A I don't know. 14 Q Who's Jackie Johnson? 15 A She was a secretary at -- 16 Q For whom? 17 A RRA. 18 Q Any particular, a floater or whatever they 19 call those? 20 A She was mine for some period of time, a short 21 period of time, and maybe somebody else's, I don't 22 remember. 23 Q All right. And this one I'm looking at, 24 Berger, is Pat -- just checking, it looks like it should 25 go to Brad Edwards -- oh, go to Brad Edwards. Brad, see Empire Legal Support. Inc. Page: 134 EFTA01089073 Bradley J. Edwards taken on 10/10/2013 1 the attached check from Searcy, they should go into 2 trust account, you should keep your own running account 3 of checks in and out. 4 A It is an e-mail from Bill Berger to Pat 5 Carter, who, by this, I would say the e-mail is at RRA, 6 so it is probably his secretary. 7 Q All right. 8 A That is what I would assume. 9 Q Okay. But it's saying it would go to you, 10 Brad Edwards is you, this and any other others like it 11 should go to Brad Edwards. And then it says Brad. So 12 see, it says to Brad Edwards -- 13 A Right. 14 Q -- also. Brad, see attached check from 15 Searcy. 16 A Right. 17 Q They should go into trust account. 18 A Right. 19 Q The trust account that they were going into -- 20 this is dated October 26, 2009. The trust account they 21 are going into, I suppose, is RBA's trust account; would 22 that be correct? 23 A I don't know. 24 Q Well, it's -- they are telling you to put 25 stuff into a trust account. The only trust -- did you Empire Legal Support. Inc.. Page: 135 EFTA01089074 Bradley J. Edwards taken on 10/10/2013 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 have your own separate Brad Edwards PA trust account? A No. No. Q The only trust account you would have had was the RRA trust account, right? A I didn't have an RRA trust account. Q The trust account that was in existence for when you were with RRA would have been the RRA trust account, right? A I don't know, I was never -- Q Well -- A -- part of any trust account. Q Well, if you received a check and it was directed that you should put this into a trust account, where would you put it? A I didn't do any of those things. Here's what happened. All of the law firms, it was myself, Bob Josefsberg, Jack Scarola, and Sid Garcia, Ted Leopold, I'm missing -- Adam Horowitz or Jeff Herman or somebody, everybody Q agreed or forensic accountants. Okay. And sent checks to the firm. I never Q To your firm? A -- asked for the firm. To RRA. Q Yeah. A I never actually saw any of the checks, so the Empire Legal Support. Inc. Page: 136 EFTA01089075 Bradley J. Edwards taken on 10/10/2013 1 checks all came to one place. Somebody took possession 2 of those checks and made sure that it was, you know, all 3 pulled together for this purpose. 4 Q Okay, let me just -- let me 5 A It was not me though. 6 Q That's me. Okay. It says here, they -- these 7 should go into a trust account. That's the direction to 8 you. 9 A I know. 10 Q I'm just asking, you know, I'm just asking 11 what it says, simple English, these should go into the 12 trust account. Did you do anything in response to that 13 ques -- that directive? 14 A No. 15 Q Was he some kind of superior to you, this guy, 16 Berger? 17 A Not necessarily, I mean. 18 Q Well, was he in the litigation division you 19 were in or was he helping run stuff? He is a judge, he 20 probably can't do too much. 21 A He wasn't actually in this office. He worked 22 out of the Boca office. 23 Q Oh, you guys have a Boca office too? 24 A I think it was only him in it. 25 Q Okay. All right. You should keep your own Empire Legal Support. Inc. Page: 137 EFTA01089076 Bradley J. Edwards taken on 10/10/2013 1 running account of all checks in and out, that's a 2 directive to you from Berger. Did you keep a running 3 account of all checks in and out? 4 A No, and I didn't take directions from Berger, 5 so the fact that he is sending me one is totally 6 meaningless to me. 7 Q Did you ever respond to why is this numbered 8 different than the ones I have seen before and what does 9 it mean, why is it there? 10 A I know the answer to that question, but this 11 is -- 12 Q Well, good, then tell me. 13 A -- but this is just him -- this is just 14 evidence that he was kind of oblivious. What everybody 15 agreed to was, let's say that I represented three people 16 and Horowitz represented 10 and Bob Josefsberg 17 represented 20, the amount that you paid for the 18 forensic accountants would be pro rata based on the 19 number of clients that you represent. So if Searcy 20 Denney represented one or two, their amount would be 21 smaller than somebody who represented 10 clients. And 22 so that's what I'm -- that's why I know what Bill is 23 talking about. Why he doesn't know the answer to that 24 just means he is oblivious to how the formula was 25 working with -- amongst the various plaintiff firms that Empire Legal Support. Inc.. Page: 138 EFTA01089077 Bradley J. Edwards taken on 10/10/2013 1 were prosecuting the case against Jeffrey Epstein. 2 Q And all of the money was being put into, 3 without doubt, RRA? 4 A I don't know. I don't know if it was being 5 6 7 8 9 put into RRA or anything. All of the money came in -- Q All right. Well, let me put it very simply. Let's say that you were working with all these guys, Josefsberg and the rest of these guys A That's true. 10 Q -- trying to come up with $5,000 to pay the 11 forensic accountant. 12 A Yeah. 13 Q It came out of your trust account, correct? 14 A I don't know. 15 Q You don't know? Who manned the trust account, 16 who did all the -- who took all the monies out of that? 17 A I don't know. 18 Q You don't know anything about trust accounts? 19 A I am assuming now what everybody knows, 20 including yourself, is that Scott Rothstein is the only 21 person that ran a trust account. 22 Q All right. 23 MR. HADDAD: I'm so glad you can anticipate 24 everything that I'm going to ask in a few minutes. 25 Sorry. Empire Legal Support. Inc. Page: 139 EFTA01089078 Bradley J. Edwards taken on 10/10/2013 1 BY MR. HADDAD: 2 Q All right. Now, this is on October 26, 2009, 3 this is probably the last days you had trust accounts, 4 so you don't know what what was told to Berger to 5 talk about these trust accounts, correct? 6 A Correct. 7 Q You don't know whether or not he was in 8 contact with Rothstein and whether Rothstein, who was 9 always looking for money was looking for money into the 10 trust accounts? 11 A I have no idea. 12 Q All right. You don't know whether or not 13 Josefsberg, Scarola or Searcy Denney or any of these 14 other lawyers, Herman or any of them had money in the 15 Scott Rothstein RRA trust account that was lost? 16 A I don't -- I don't know, but in -- in -- I do 17 believe that they sent the checks. Now, what happened 18 with the checks and who accumulated the checks and where 19 the checks went to fund the forensic accounting project, 20 to determine what to do from that aspect against Jeffrey 21 Epstein, I really -- I have no idea. 22 Q So the forens -- 23 A I didn't accept the checks, personally. 24 Q All right. The forensic accountants were 25 going to be for what, because you were not in civ -- Empire Legal Support. Inc. Page: 140 EFTA01089079 Bradley J. Edwards taken on 10/10/2013 1 were you in civil litigation, you were trying to plan a 2 depo, I guess, and have forensic account determine the 3 net worth of Epstein? 4 A No, the idea was that it was the cumulative 5 belief of the plaintiff attorneys that Mr. Epstein was, 6 at that point in time, nearly dead in the water as it -- 7 in respect to liability, and that the damages was going 8 to be extraordinary and that his only real defense 9 remaining was probably to use his experience in finances 10 to ship money offshore, hide money. And so the forensic 11 accountants were going to try to determine where he was 12 shipping money and hiding money. 13 Q Through what vehicle? 14 A I don't know. I'm not a 15 Q Well, forensic accountants don't have any 16 ability to get anything unless they are presented 17 documentation and that be would the lawyer's job to 18 present the documentation, what documentation and what 19 method of production, as this was in October of 2009, 20 when you are imploding, were you guys planning on using, 21 do you know? 22 A No, they didn't tell me. 23 Q All right. Did -- 24 A It was only an idea between myself, Jack 25 Scarola and Bob Josefsberg, and here, let's hire Empire Legal Support. Inc. Page: 141 EFTA01089080 Bradley J. Edwards taken on 10/10/2013 1 2 forensic account and see what they come up with. Q Okay, wait, wait, let me see if I understand 3 this. You are telling me that as you're planning all 4 these things, Scarola was involved in the conversations 5 6 7 8 on how to obtain these things? A Of course. Q Your lawyer? I'm just asking the question -- A All of the lawyers that were prosecuting cases 9 against Jeffrey Epstein, we were all involved in all of 10 these decisions, yes. 11 Q I understand, I just have to make it clear for 12 the record. Josefsberg was involved? 13 A Yeah, of course. 14 Q All right. As as how you are going to do 15 this, right? 16 A Of course. 17 Q And he was your co-counsel and -- with 18 codefendants -- co-plaintiffs, Scarola, as well as 19 Josefsberg and others, correct? 20 A Right. 21 Q And you were pooling your thoughts, your 22 abilities and your monies? 23 A Right. 24 Q To go after these cases? Okay. 25 A Exactly. Empire Legal Support. Inc. Page: 142 EFTA01089081 Bradley J. Edwards taken on 10/10/2013 1 Q All right. Now, Bradley Edward, from Bradley 2 Edwards to Jackie Johnson, October 22nd, 2009, please 3 look at the following schedules, see if you can book a 4 conference room for many to attend as the following 5 group of people for tomorrow, 10 days before, eight 6 days -- well, not -- eight days before you guys fell 7 apart. Please look at the following schedules and see 8 if you can book a conference room for as many -- for as 9 many as can attend from the following group of people 10 for tomorrow: Jenne, Adler, Berger, Stone, Wheeler, 11 Holmes, Bruschel {SIC}, Fi Fiston and Jaffe. Do you 12 know what that's about? Do you know why you were having 13 a conference? Obviously, from the names, it had 14 something to do with Epstein, I would imagine? 15 A Yeah, the subject is Epstein meeting. 16 Q Yeah. Do you know? 17 A We would -- we would frequently have meetings 18 on cases, including this one, to brainstorm about what 19 to do with the various issues that were going on in the 20 case. 21 Q Well, you had no other -- did you have other 22 cases while you were at RRA, besides these? I'm not 23 saying that pejoratively, I mean did you have other 24 cases? 25 A Yeah, of course I did. Empire Legal Support. Inc. Page: 143 EFTA01089082 Bradley J. Edwards taken on 10/10/2013 1 Q All right. 2 A I brought with me many cases. 3 Q I didn't -- okay, I didn't know that. Nobody 4 asked you anything about other cases pretty much, they 5 only asked you about this case. You had other cases you 6 were working on? 7 A Right. 8 Q Did you settle any while you were there? 9 A I don't remember. 10 Q Okay. 11 MR. HADDAD: Yes? 12 MR. GOLDBERGER: I just -- 13 BY MR. HADDAD: 14 Q There was one I wanted to ask you about -- you 15 know, there was one I really wanted to ask you about 16 and, of course, I'm sure I lost it. Okay. Can I have 17 one second since I haven't taken a second? I should 18 have had it dog-eared but-.-.-. 19 When was it that you first met with Josefsberg 20 and -- and Scarola and all those about pooling your 21 resources, was that before you went with RRA? I'm not 22 getting into any conversations you had, I don't want to 23 violate your -- 24 A I don't remember the exact timing. 25 Q -- you are going to assert anyhow so. Empire Legal Support. Inc. Page: 144 EFTA01089083 Bradley J. Edwards taken on 10/10/2013 1 What did -- well, do you recall if you ever 2 met with -- I mean, Josefsberg is easy to remember, did 3 you meet with him? Did you meet with him prior to going 4 with Rothstein? 5 A Yes. 6 Q Okay. And it was about those cases? 7 A It was about those cases. I don't know if it 8 was about the finances aspect. 9 Q All right. No, just about the cases, I am not 10 going to ask you 11 A Oh, yeah, we 12 Q All right. 13 A -- we were meeting as a group once or twice a 14 month from 2008 on. 15 Q All right. 16 A Through the end. 17 Q And excuse my ignorance, but in criminal law, 18 when we do things like that we have what we call joint 19 defense agreements, we share stuff, we share expenses, 20 we make sure no one stabs each other in the back, 21 which -- II cetera. It's not even worth the paper it's 22 written on half the time. Did you have any sort of 23 joint agreement with these lawyers, a shared 24 responsibility agreement, a shared agreement, a written 25 agreement of any kind, without going into anything that Empire Legal Support. Inc.. Page: 145 EFTA01089084 Bradley J. Edwards taken on 10/10/2013 1 it says, I don't want to invade any privilege here, did 2 you have any written agreements with these lawyers? 3 MR. KING: Hold on one second. Let's take a 4 break, discuss privilege. 5 MR. HADDAD: Five minutes, so I can look for 6 what I'm trying to find. 7 MR. KING: Okay, that's fine. 8 MR. HADDAD: I've got the bomb question. Oh, 9 no, I don't, but I'm trying to find one. 10 THE VIDEOGRAPHER: The time is 10:52 A.M. We 11 are now coming off the video record. 12 (Thereupon, a discussion was had off the 13 record.) 14 THE VIDEOGRAPHER: The time is 11:00 A.M. We 15 are now back on the video record. 16 MR. HADDAD: All right. 17 MR. KING: Let me -- 18 MR. HADDAD: Yeah. 19 MR. KING: -- assert an objection as to this 20 line of questioning. If you are going off of it, 21 great, but any further communications or 22 conversations relating to communications that 23 Mr. Edwards had with the other lawyers, there are 24 motions that were pending and may have been 25 granted, I don't know, by at least two lawyers to Empire Legal Support. Inc.. Page: 146 EFTA01089085 Bradley J. Edwards taken on 10/10/2013 1 preclude any disclosure of work product information 2 that they would have a right to assert. And so 3 we're -- in honor of that, of those motions or the 4 order, if it was entered, and I apologize for not 5 knowing that, we would -- we would object to any 6 questions relating to communications that occurred 7 that would fall within a work product doctrine that 8 would be owned by those other lawyers. 9 MR. HADDAD: I -- I -- I don't think that's 10 what I was doing. In fact, I thought I made it 11 specifically clear I am not trying to invade any 12 privilege. I just asked whether or not there was a 13 written -- an agreement among the lawyers, and I 14 don't think that would be privileged. Shared 15 information among the lawyers would not be -- I 16 mean, I'm not going to put you in bad position 17 because not -- you're -- you're not the lawyer that 18 should -- that, like I said, should have been here, 19 but you are not the lawyer that is more familiar 20 with this, so I don't want to put -- my usual 21 expression would be something else, so I will just 22 leave it there and we will take it up with the 23 Judge, okay. 24 MR. KING: Very good. 25 MR. HADDAD: Because I just want to know if Empire Legal Support. Inc.. Page: 147 EFTA01089086 Bradley J. Edwards taken on 10/10/2013 1 2 there's a written -- like -- just like the lawyers have a -- a -- what do we call that, a joint 3 defense agreement. Whether it's a plaintiff's 4 5 6 agreement -- a sharing you can assert -- you objected, I will leave it at that. I don't want to -- as I said, I don't want to cause any -- 7 MR. GOLDBERGER: Just identify the specific 8 question you are asking that Mr. King is telling 9 his client not to answer. 10 MR. HADDAD: Specifically, I already asked 11 him, whether or not there was any specific 12 agreement among the lawyers to share information 13 and share expenses, because we already know they're 14 sharing checks into a pooled account, which -- 15 which already gave us the answer to that when there 16 was a joint agreement about sharing information and 17 work -- and workload and so forth, without ever 18 discussing what -- what their work product was. I 19 mean, the end result was to sue Epstein and get as 20 much money as we can, we know that. But as to any 21 other thing, I just want to know whether they had a 22 formalized agreement saying that we will e-mail 23 each other on some secret e-mail account, or what 24 do you call that thing in the sky that Adler said 25 he invented, Qtask, any of that stuff, that's what Empire Legal Support. Inc. Page: 148 EFTA01089087 Bradley J. Edwards taken on 10/10/2013 1 the question is. I will respect your objection and 2 I think it's a fair objection, particularly since 3 you weren't, you know, the attorney handling all of 4 this and we will take it up at another time. 5 If I can proceed? 6 A Go ahead. 7 8 9 BY MR. HADDAD: Q Okay. Thank you. I got this in a list of e-mails and this is from Debra Villegas. I don't have 10 her prison number right now, but it's to Scott 11 Rothstein. At any rate, Ken Jenne advised that we need 12 these documents for depo as early as next week, are you 13 familiar with that e-mail? 14 A No. 15 Q Okay. And you have no idea why Beth would be 16 looking for financial documents, police reports, arrest 17 reports, call logs, all information of a -- a copy of 18 Epstein's counsels' client list, all the rest of that 19 stuff? 20 A You said Beth did what? 21 Q No, it's Debra Villegas to Scott Rothstein, 22 forward inventory, Ken Jenne. Ken Jenne was the guy 23 that was in your meeting that you called with all those 24 guys that I showed you the -- the thing before, 25 remember, Berger wanted to have you, Adler, I think one Empire Legal Support. Inc.. Page: 149 EFTA01089088 Bradley J. Edwards taken on 10/10/2013 1 of those-.-.-. 2 A We are going to mark this, right, so it's 3 accurately -- 4 Q Everything is going to be there, of course. 5 A All right. So there is an e-mail from Lee 6 Caplan, I don't know who that is, to several other 7 people that does not include me. 8 Q Umm-hmm, I am just asking you if you saw it 9 before? 10 A I don't remember ever seeing this but it has a 11 Bates stamp number, which means that we turned it over. 12 So going through 26,000 pieces of paper, I must have 13 seen it at some point in time during this case, well 14 of -- you know, sometime in 2011, I would guess. I 15 don't remember seeing it. 16 Q The date of the e-mail, I'm going to get to it 17 in a minute, but that date of that e-mail is 18 October 30th, the day before Scott got the G5 and left, 19 correct? 20 MS. COLEMAN: You say it well. 21 A October 30th, 2009. 22 BY MR. HADDAD: 23 Q All right. All right, now this one I like, 24 because this is something, like me, Brad Edwards to Ken 25 Jenne, August 19th, 2009, the paperless world really Empire Legal Support. Inc. Page: 150 EFTA01089089 Bradley J. Edwards taken on 10/10/2013 1 scares me in this case. This is about Edwards, isn't 2 it? 3 A That's me. 4 Q There is so much pape -- not Edwards, I -- I'm confusing you guys now, Epstein. There is so much paper and so many motions and dates and times of everything, so important, so many motions, I think we need an 5 6 7 8 organized paper file in this case. That's you talking 9 about Epstein's case, correct? 10 A It sounds like it, yes. 11 Q Okay. And organized paper file would mean 12 like a war room, I think, in fact, you have an e-mail 13 where you asked for a war room. 14 A Right in there. 15 Q Is it in this one? It said war room there? 16 Oh, yeah. I just thought I was -- great memory, sorry. 17 Okay. 18 So on October 19th, Ken Jenne to Epstein. 19 Subject: Epstein. To Ken from Bradley J. Edwards. I 20 know you are aware of the urgency, and Russell and I 21 have discussed the various necessary witnesses in the 22 case and the urgent need to speak them. We have a 23 discovery deadline coming up and four crucial witnesses 24 are in California. And you are talking about Fiston 25 going out there. That's in relation to what coming up, Empire Legal Support. Inc. Page: 151 EFTA01089090 Bradley J. Edwards taken on 10/10/2013 1 2 3 4 5 6 7 8 9 discovery deadline in the cases that you had before you settled them, if you -- A Uh, from memory -- Q Yeah, I'm not -- A -- the case was a -- the Jane Doe v. Epstein case was initially set for trial in November of 2009, so I think the discovery deadline was coming up and we had some more witnesses to talk to before that. Q All right. Who's Pat Diaz? 10 A He's an investigator. 11 Q Okay. Let me -- let me -- yeah, this one, 12 probably just because it intrigued me, is from Bill 13 Berger to Edwards, Adler, Jaffe, Weissing, Farmer, 14 May 19th, 2000. It was mostly your partners now. You 15 are invited to attend our three P.M. conference room, 22 16 floor conference room, interview of Amy Swan, a 17 psychologist, who you are considering as a damage expert 18 in Epstein cases. Even if you are not working on the 19 case, if you can attend, I would appreciate your input. 20 What -- what -- what was she, like a child psychologist 21 or something? 22 A Right. 23 Q Is she here in Broward? 24 A I don't remember. 25 Q Okay. Empire Legal Support. Inc. Page: 152 EFTA01089091 Bradley J. Edwards taken on 10/10/2013 1 A Local though, tri-county, I don't remember. 2 Q All right. And that was for purposes of 3 potential witness in your cases if you went to trial, 4 correct? 5 A Correct. 6 Q Okay. And would Edward -- but the rest of 7 your partners were invited, your present partners were 8 invited, do you know why they were invited? 9 A No. 10 Q Okay. Did they actually have work on-.-.-. 11 A Not at all. 12 Q Okay. 13 A I will finish the question first. Work on 14 Epstein's case 15 Q That's okay, we both know what we are talking 16 about. 17 How come you turned over Scott's schedule for 18 the July 26 call from Governor Barbour, lunch with David 19 Shope, Alonzo Mourning charity breakfast? 20 A I didn't have access to my e-mails. These 21 e-mails were turned over to me by the trustees. 22 Q Okay. 23 A When they were turned over to me, I turned 24 them over to you. 25 Q And let me ask, Epstein conference 3:30, Brad Empire Legal Support. Inc. Page: 153 EFTA01089092 Bradley J. Edwards taken on 10/10/2013 1 Edwards, Steve Jaffe, Ken Jenne. 2 A Until these were turned over to me by the 3 trustee, I had never seen them before. 4 Q Oh, so you don't know, okay. 5 A I have no idea. 6 Q I guess Scott's not on the charity board for 7 Alonzo Mourning anymore? 8 A I would hope not. 9 Q Did you get to go to Mo's Dinner Event at The 10 Palms Grill? 11 A Did not. 12 Q Do you know who Mo is? 13 A Do not. 14 Q The cigar guy, that gave all the cigars for 15 all the charities? 16 A No. 17 Q Okay. Do you know who Micki Cummings is that 18 he was interviewing for the second time? 19 A No. 20 Q The divorce lawyer who tried to become a 21 judge? 22 A Michele Cummings? 23 Q You don't keep up with divorce lawyers? 24 A I try not to. I know you do. 25 Q That's for sure. Nice. Touché. Empire Legal Support. Inc. Page: 154 EFTA01089093 Bradley J. Edwards taken on 10/10/2013 1 I assu -- is this one on your Web site or is 2 this just here, "Florida Lawyer Ruffles Feathers in High 3 Society With His Pesky Subpoenas," did you post that 4 one? 5 A I don't think so. 6 Q You should, it's a pretty good article for 7 you. Okay -- 8 9 10 11 12 13 A Send it to me again and I will post it. Q All right. I -- I think -- I don't know if I have any more of these on these e-mails, but -- but at some point or another, these all -- were either recognized by you, came -- or were produced by you, correct? 14 A They came to me by -- from the trustee, 15 sometime -- 16 Q Yeah. 17 A -- in 2011 and then I forwarded them on to you 18 guys. 19 Q All right. 20 Were you dep