EFTA01076611.pdf

Page 1 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 PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 iddcfb&Cb324-4437-a670-765e29067145 EFTA01076611 ) EFTA01076612  ay e Page 4 2 3 APPEARANCES: On behalf ofthe Plaintiff MICHAEL PIKE,ESQUIRE 2 PROCEEDINGS I BURMAN CFUTTONLUEIER & COLEMAN, 11? 3 Deposition taken before Sandra W. Townsend, Court 1 303 Banyan Boulevard, Suite 400 4 Reporter and Notary Public in and for the State of West Pailikirda 33401 Phone: 5 Florida at Large, in the above cause. 0 6 On behalf of the Defendant Bradley Edwards: JACK SCAROLA, ESQUIRE 7 VIDDOGRAPHER: We are now on video record. SEARCY, DENNEY, SCAROLA, BARNFIART & SHIPLEY 8 This is media number one in the videotaped 2139 Palm Beach Lakes Boulevard 9 deposition of Jeffrey Epstein in the matter of West ' 33409 10 Photo: 10 Jeffrey Epstein versus Scott Rothstein, Bradley 11. Oat:chaff° the 11 Edwards and M. 12 BRADLEY EDWARDS,I II‘IRE FARMER, JAFFE, WESSINO, EDWARDS, HMS, 12 Today is Wednesday, March 17,2010 at 13 & LEEMAN,Pl. 13 10:17 am. 425 North Andrews Avenue 14 We are at the law offices of Burman, 14 Suite 2 Fon Lt. 33301 15 Critton — Banyan — of Burman, Critton on Banyan 15 Phone: 16 Boulevard, Suite 400, West Palm Beach, Florida. 16 Also Present 17 My name is Joe Kozak. I'm the videographcr. 11 STEVEN JAFFE, ESQUIRE FARMER, JAFFE, WEISER:I, EDWARDS, Ftb ILb 18 The court reporter is Sandra Townsend from Prose 78 & LEHRMAN, P.L. 19 Court Reporting Agency. 425 North Andrews Avenue 19 Suite 2 20 Would Counsel please introduce yourselves and Fon Lit da 33301 21 then the court reporter will swear in the witness. 20 Phcoe: 21 22 MR. SCAROLA: My name is Jack Scarola. I am 22 23 Counsel on behalf of Brad Edwards in his capacity, 23 24 both as Defendant and Counter-Plaintiff in this 24 25 25 action. Mr. Edwards is present with me. Page 3 Page 5 --- 1 MR. PIKE: Michael Pike, on behalf of the 2 EXHIBITS 2 Plaintiff, Jeffrey Epstein. 3 3 MR. EDWARDS: Brad Edwards, on behalf of the 4 Defendant, M. NUMBER DESCRIPTION PAGE 5 Also present Steve Jaffe, on behalf of the 6 Defendant, M., as well. Exhibit number 1 Eyeglasses 133 7 THEREUPON, 8 JEFFREY EPSTEIN, 8 9 having been first duly sworn or affirmed, was examined 9 10 and testified as follows: 10 11 THE WITNESS: Yes, I do. Thank you. 11 12 MR. PIKE: Before we get started, Jack, I just 12 13 wanted to get on the record, I just want to make 13 14 sure that you received this letter that I sent to 14 15 your office yesterday of March 16, 2010. 15 16 MR. SCAROLA: !did receive the letter. 16 17 17 MR. PIKE: Okay. And we're still on for 18 18 Mr. Edwards' deposition, as we sit here today? 19 19 MR. SCAROLA: That's correct. 20 20 MR. PIKE: Okay. Thank you. 21 21 DIRECT EXAMINATION 22 22 BY MR. SCAROLA: 23 23 Q. Please state your full name and your current 24 24 residence address. 25 25 A. My name is Jeffrey Epstein. Pm currently 2 (Pages 2 to 5) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 1ddefb84-b324-4437.4t670.766e29067146 EFTA01076613  Page 6 Page 8 i residing at 358 El BriIto in Palm Beach. 1 your questions here today. However, on advice of 2 Q. How long have you resided at that location, 2 Counsel, I'm going to have to assert my Fifth. Sixth and 3 Mr. Epstein? 3 14th Amendment Right. 4 A. I'm sorry. On advice of Counsel today, I'm 4 Q. Are you a Plaintiff in a lawsuit against Scott 5 6 7 going to take the Fifth, Sixth and 14th Amendment with respect to that question, Mr. Scarola. Q. Have you maintained any other residences over 5 6 7 n I , Rothstein, Bradley J. Edwards and an individual identified by the initials A. Yes, sir, l am. 8 the course of the last five years? 8 Q. Who is the individual identified ass? 9 A. Though I'd Ilice to answer each and every one 9 A. I believe from depositions that I've read her 10 of your questions here today, with respect to that 10 full name is M. 11 question 15n going to have to assert my Constitutional 11 Q. When and under what circumstances did you 12 Rights as provided by the Sixth, 14th and Sixth -- 12 first meet the individual referenced by the initials 13 Fifth — sorry — Fifth, Sixth and 14th Amendment. 13 14 Q. Does anyone reside with you at the El Milo 14 A. Mr. Scarola, I think you arc awarc these 15 address? 15 questions are simply designed to have me invoke my Fifth 16 A. Again, Mr. Scarola, though Pd like to answer 16 Amendment, Sixth Amendment and 14th Amendment Right in 17 each and every one of your questions here today, at 17 relation to other questions and other cases 18 least with respect to that question, I'm going to have 18 But in response to your question, I'm going to 19 to assert my rights as under the Sixth, Fifth and 14th 19 have to invoke my right not to testify. 20 Amendment. 20 Q. Do you know the individual named ■ 21 And I've been advised by Counsel, though I'd 21 identified by the initials Ini? 22 lute to answer these questions, if I do so, I risk 22 A. Mr. Scarola, at least today -- I would like to 23 losing their representation. 23 answer that question; however, today, on advice of 24 Q. What did your lawyer tell you in that regard? 24 Counsel, I'm going to have to refuse to answer that 25 MR. PIKE: I'm going to instruct you not to 25 question. Page 7 Page 9 1 answer that question. Attomey/client. 1 Q. Have you ever acknowledged in the presence of 2 BY MR. SCAROLA: 2 any other person knowing the individual identified by 3 Q. Well, didn't you just tell me that your lawyer 3 the Initials M.? 4 advised you that ifyou answered questions he wouldn't 4 MR. PIKE: Form. 5 represent you anymore? 5 THE WITNESS: Again? Sony. Can you repeat 6 MR. PIKE: Mat's exactly what he said, 6 the question, sir? 7 Mr. Scarola, and Pm instructing him not to answer 7 BY MR. SCAROLA: 8 the question. 8 Q. Yes, sir. Have you ever acknowledged in the 9 BY MR. SCAROLA: 9 presence of any other person knowing the individual 10 Q. Okay. So I want to know then — I want to 10 identified by the initials M.? 11 know what your lawyer told you about that. 11 MR. PIKE: Perm. Also could invade 12 MR. PIKE: I'm going to instruct you not to 12 attomey/client. 13 answer that question. Attorney/client. 13 11-16 WITNESS: Again, I would like to answer 14 MR. SCAROLA: And it is our contention, 14 that question, but today I'm going to have to 15 obviously, that by making the statement that he has 15 Invoke my Fifth Amendment, Sixth Amendment and l,ttn 16 made, Mr. Epstein has waived any attorney/client 16 Amendment Right. 17 privilege with regard to that matter. 17 BY MR. SCAROLA: 18 MR. PIKE: Your contention, definitely not 18 Q. Have you ever acknowledged in the presence of 19 mine. 19 any person, other than your ownlw,=, having known the 20 BY MR. SCAROLA: 20 individual identified by the initials M.? 21 Q. Mr. Epstein, who else has shared that 21 MR. PIKE: Form. 22 residence with you at any time over the course of the 22 THE WITNESS: Again, I'd late to answer each 23 last five years? 23 and every one ofyour questions here today, 24 A. Again, Mr. Scarola, I'd like to answer that 24 Mr. Scarola; however, on advice ofCounsel, at 25 question, as Pd like to answer each and every one of 25 least today, fm going to have to reflate to answer 3 (Pages 6 to 9) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 lcIdcfb84 .12 24 al4 37-a6 70-76 Se 29067145 EFTA01076614  Page lU Page 12 1 that question. 1 invoke my Fifth, Sixth and 14th Amendment Right. 2 BY MR. SCAROLA: 2 Q. Have you ever acknowledged in the presence of 3 Q. Have you ever acknowledged to -- 3 Terri Becker, a court reporter present at a deposition 4 A. Excuse me. 4 taken by Brad Edwards in a — in a case in which the 5 Q. --Bradley- S individual identified by the initials' was a 6 A. Sir, may I suggest that if I say I refuse to 6 Plaintiff that you knew and/or liked — 7 answer, that it means the Fifth, Sixth and 14th or would 7 MR. PiKE: Form. 8 you prefer that I recite it each time? 8 THE WITNESS: Again, -- 9 Q. I would prefer that you answer the questions, 9 BY MR. SCAROLA: 10 that's my preference. But if you're going to assert a 10 Q. 11 privilege, I will assume that if you simply say that you 11 MR. Same objection. 12 are refusing to answer, your refusal to answer will be 12 THE WITNESS: Again, I'm going to have to 13 on the basis of various Constitutional privileges 13 assert my Fifth, Sixth and 14th Amendment Right. 14 against self-incrimination without the necessity of 14 BY MR. SCAROLA: 15 specifying, 15 Q. Have you ever acknowledged in the presence of 16 If your refusal to answer is on the basis of 16 Steve Jaffe that you knew and/or liked a ? 17 any other privilege, it will be necessary for you to 17 A. Again, Mr. Scarola, though I'd I c to answer 18 identify that privilege. 18 each and every one of your questions today, Pm going to 19 A. ThanIcyou. 19 have to, at the advice of Counsel, invoke my Fifth, 20 MR. PIKE: And Pm going to instruct you, too, 20 Sixth and 14th Amendment Right. 21 when you do invoke, invoke the Fifth, Sixth and the 21' Q. Why are you suing.? 22 14th. 22 MR. PIKE: Form. 23 THE WITNESS: Yes. 23 MR. SCAROLA: Let me state for the record that 24 BY MR. SCAROLA: 24 I don't consider a form objection to be a proper 25 Q. Have you ever acknowledged in the presence of 25 objection, unless you specify the defect in the Page 11 Page 13 1 Bradley J. Edwards that you knew the individual 1 form and provide me with an opportunity to correct 2 identified by the initials.? 2 the defect. 3 A. Pm going to have to refuse to answer that 3 MR. PIKE: That's fine. I believe the rules 4 question. 4 provide otherwise. But, nonetheless, i stand on my 5 Q. Have you ever acknowledged in the presence of 5 objection to form. 6 Bradley J. Edwards that you knew.? 6 THE WITNESS: Pm sorry. You have to repeat 7 MR. PIKE: Again, for purposes of the record, 7 the question. I'm instructing you to invoke the Fifth, Sixth and 8 BY MR. SCAROLA: 9 14th, rather than just simply say -- 9 Q. Why are you suingM? 10 THE WITNESS: Okay. 10 MR. PIKE: Fonn. 11 MR. PIKE: —I refuse to answer. I want it 11 11W WITNESS: is part of a conspiracy 12 to be clear for the Court that you have invoked 12 with Scott Rothstein, ley Edwards, creating -- 13 your Fifth, Sixth and 14th. 13 excuse me — creating fraudulent cases of a 14 THE WITNESS: Fine. 14 sexually charged nature in which the U.S. Attorney 15 Then on advice of Counsel, I'm going to have 15 has already charged the firm of Rothstein, a firm 16 to invoice my Fifth, Sixth and 14th Amendment Right. 16 of which Bradley Edwards is a partner, was a 17. BY MR. SCAROLA: 17 partner, with creating, fabricating malicious cases 18 Q. Have you ever acknowledged in Brad Edwards' 18 of a sexual nature, including cases with respect to 19 presence that you liked the individual identified by the 19 me, specifically, in order to fleece unsuspecting 20. initials.? 20 investors in South Florida out of millions of 21 A. Again, Pm going to have to invoke my Fifth, 21 dollars. 22 Sixth and 14th Amendment Right, Mr. Scarola. 22 BY MR. SCAROLA: 23 Q. Have you ever acknowledged in Bradley Edwards' 23 Q. What role do you contend =. played in that 24 presence that you liked 24 conspiracy to create fraudulent cases 25 A. Again, Mr. Scarola, fm going to have to 25 A. testimony before she met Mr. Edwards ••• 4 (Pages 10 to 13 (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. MIIIIIIIMIOMI Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 1ddc1b84-b324-4437-a670-765029067145 EFTA01076615  Page 14 Page 16 was dramatically -- sworn testimony to the FBI was 1 according to you, she met Mr. Edwards and changed her 2 dramatically different after she came in contact with 2 testimony, true? 3 Mr. Bradley Edwards, where her testimony then changed to 3 A. Did she change her testimony? Is that — yes, 4 sort ofa hostile and had claims of -- claims never made 4 her testimony was changed. 5 before, never made to anyone before, and allegations 5 Q. My question to you is: Was her testimony 6 that i've read in her Complaint that that had been which you contend was changed true testimony? dramatically different from the ones she had spoken to 7 A. Your question is not a good question. Is it the FBI about, sir. 8 her testimony before or after? 9 Q Is it your contention that as statement to 9 Q. Was the subsequent testimony given by 10 the FBI was true? 10 after she met Mr. Edwards which you contend was 11 MR. PIKE: Form. 11 different from her testimony before the FBI, was the 12 THE WITNESS: Mr. Scarola, unfortunately, 12 subsequent testimony true or false? 13 today with respect to that question, iin going to 13 MR. PIKE Form. 14 have to assert my Fifth, Sixth and 14th Amendment 14 THE WITNESS: Sr, I'm going, at least today, 15 Right. Though I know — I believe you know the 15 Pm going to have to assert my Fifth, Sixth and 16 answer to that question, I can't answer the 16 14th Amendment Right 17 question under advice of Counsel. And hes told me 17 BY MR. SCAROLA: 18 if i chose to do so, I risk losing his 18 Q. Did you ever engage in any sexual conduct with 19 representation. 19 20 BY MR. SCAROLA: 20 . I would like to answer that question, but — 21 Q. What is the basis of your belief that i know 21 Q. You don't need to tell me what you'd like to 22 the answer to the question? 22 do, Mr. Epstein. You just need to do it, please. 23 MR. PIKE: Form. 23 THE WITNESS: Please — 24 THE WITNESS: You — I believe you have seen 24 MR. PIKE Mr. Smola, please let the witness 25 this, because you're supposed to be a decent 25 finish his response. Page 15 Page 17 1 lawyer, youfve read the testimony. I would guess 1 MR. SCAROLA: That's not a response to my 2 you've read the difference in her testimony to the 2 question. 3 FBI versus her testimony after she's met your 3 MR. PIKE: In your mind it may not be a 4 client and his partners, who are currently in jail. 4 response. In a Judge's mind, it may be. We may 5 BY tvfit. SCAROLA: 5 have to certify it to the Court. If such a 6 Q. How does that respond to my question as to 6 procedure even exists, we can take it up with the 7 whether you contend that her testimony to the FBI was Court. But please let the witness finish his 8 true or false? 8 response. 9 MR. PIKE: Form. 9 THE WITNESS: Again, please? 10 THE WITNESS: I don't believe that was your 10 BY MR. SCAROLA: 11 question. Will you repeat? 11 Q. Did you engage — ever engage in any sexual 12 BY MR. SCAROLA: 12 conduct with M7 13 Q. Okay. Well, let's let me rephrase the 13 A. I would u e to answer that question; however, 14 question then. 14 today Pm going to have to assert my rights as provided 15 Is it your contention that M.'s statement to 15 by the Fifth, Sixth and 14th Amendment to that question, 16 the FBI was true? 16 sir. 17 A. Sr, on advice ofCounsel, at least today, Pm 17 Q. Have you ever exchanged anything of value with 18 going to have to assert my Fifth, Sixth and 14th 18 19 Amendment ejR tt. 19 MR. PiKE: Form. 20 Q. Was M.'s statement to the FBI false in any 20 THE WITNESS: At least today, I'm going to 21 respect? 21 have to assert my Fifth, Sixth and 14th Amendment 22 A. Sir, at least, again, today, on advice of 22 Right, sir. 23 Counsel, Pm going to have to assert my Fifth, Sixth and 23 BY MR. SCAROLA: 24 14th Amendment Right. 24 Q. Did you ever direct anyone to deliver anything 25 Q. Was .'s subsequent testimony after, 25 of value to .7 5 (Pages 14 to 17) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 ickklb844424443741170466•29067145 EFTA01076616  Page 18 Page MIL PIKE: Form. 1 which is outrageous. THE WITNESS: At least today, I'm going to 2 BY MR. SCAROLA: 3 have to refuse to answer that question based on the 3 Q. How much have you settled claims for? 4 Fifth, Sixth and 14th Amendment 4 MR. PIKE: ism going to instruct you not to 5 BY MR. SCAROLA: 5 answer that question. 6 Q. Do you Imow 6 MR. SCAROLA: And the basis of that A. At least today, sir, 1'm going to have to 7 instruction is? 3 refuse to testify about that question. Based on advice 8 MR. PIKE: Confidential settlement agreements. 9 of Counsel, I'm going to have to assert my Fifth, Sixth 9 to the extent that they exist. And the terms would 10 and 14th Amendment Ri t. 10 be confidential. 11 Q. Di introduce you to M.? 11 BY MR. SCAROLA: 12 A. Sir, nape...tfully, I'd like to answer that 12 Q. Have you settled claims? 13 question today. As I said, I'd like to answer each and 13 A. Yes, l have. 14 every one of your questions. However, on advice of my 14 Q. What is the nature of the claims you settled? 15 Counsel today, inn going to have to assert my Fifth, 15 MR. PIKE: Pm going to instruct you not to 16 Sixth and 14th Amendment Right. 16 answer that question. 17 Q. Did M. suffer any dama ts a consequence of 17 BY MR. SCAROLA: 18 any interaction between you and M.? 18 Q. How many claims have you settled? 19 MR. PIKE: Form. 19 MR. PIKE: IN going to instruct you not to 20 THE WITNESS: Could you repeat the question, 20 answer that question as well. 21 please? 21 MR. SCAROLA: What is the basis for those 22 BY MR. SCAROLA: 22 instructions? 23 Q. Did IN. suffer any damage as a consequence of 23 MR. PIKE: Confidential, as well as there is a 24 any interaction between you and M.? 24 VICTIM'S Right Statute that may — you may be 25 MR. PIKE: Form. 25 tiptoeing into the identity of - Page 19 Page 21 1 THE WITNESS: I'd hie to answer each and 1 MR. SCAROLA: Pm not tiptoeing anywhere. 2 every one of your questions here today, 2 MR. PIKE: Let me finish my objection, 3 Mr. Scarola; however, on advice of Counsel, today, 3 Mr. Scarola. 4 Pm going to have to assert my Fifth, Sixth and 4 You may be tiptoeing into the identity of 5 14th Amendment Right. 5 various alleged victims underneath the Victims 6 BY MR. SCAROLA: 6 Right Statute, as well as ongoing investigations or Your Complaint in this action alleges that 7 past investigations that have remained open with 8 . made claims for damages out of proportion to her the State, as well as the Federal Government. 9 alleged damages. What does that mean? 9 So in that regard, we would have to put the 10 A. It means what it says. 10 State Attorney, as well as the Federal Government 11 Q. I don't understand it. Explain it to me. 11 on notice that you were seeking to potentially back 12 MR. PiKE: To the extent you can answer that 12 door certain identities at this deposition. 13 question without disclosing my conversations with 13 BY MR. SCAROLA: 14 you or Mr. Critton's conversations with you, as 14 Q. Other than having allegedly given different 15 well as my work product, you can answer the 15 testimony before she met Mr. Edwards then given after 16 question. 16 she met Mr. Edwards, did S do anything else that 17 THE WITNESS: I believe that as part of the 17 forms the basis for your claim against her? 18 scheme to defraud investors in South Florida out of 18 MR. PUCE: Form. Asked and answered. 19 millions of dollars, claims of outrageous sums of 19 THE WITNESS: I'd like to answer that 20 money were made on behalf of alleged victims across 20 question, as well as every one of your questions 21 the board. And the only way — in fact, Scott 21 with respect to M. here today; however, on advice 22 Rothstein sits in jail. And what I've read in the 22 of Counsel, at least today, Mr. Scarola, Pm going 23 paper, claims that I've settled cases for 23 to have to assert my Sixth Amendment, Fifth 24 S200-million, which is totally not true. 24 A•essIntent and 14th Amendment Right. 25 She has made claims of serious sum of money, 25 BY MR. SCAROLA: 6 (Pages 18 to 21) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401M Electronically signed by Sandra Townsend (401 tddctb84•b324-4437-a670.765o29067145 EFTA01076617  Page 22 Page 24 1 Q. Did fail to do anything that she had an 1 MR. PIKE: Mr. Scarola, that's the second time 2 obligation, duty or responsibility to do 2 that I'm going to ask you not to interrupt the 3 MR. PIKE: Form. 3 witness when he's giving a response. He is giving 4 BY MR. SCAROLA: 4 a response. When he finishes his response, you can 5 Q. — that forms the basis for your claim against 5 go on with your next question or you can — you can her? 6 elicit any sort of information you intend to elicit 7 MR. PIKE: I apologize. Form. 7 from the witness. 8 THE WITNESS: Again? I'm sorry. Has she 8 MR. SCAROLA: He's being unresponsive. 9 failed to do? Can you repeat? 9 MR. PIKE: No, that's your contention. 10 BY MR. SCAROLA: 10 MR. SCAROLA: No, that's a fact. 11 Q. Yes, sir. Lawsuits are generally based, civil 11 MR. PIKE: And you can take it up with a 12 lawsuits are generally based on a claim that someone has 12 Judge. And if we want to continue going back and 13 done something that they shouldn't have done or failed 13 forth and bantering, not allowing the witness to 14 to do something that they should have done. 14 answer the question — we're here for you today, 15 I asked you whether did anything that she 15 for you to ask the questions and for you to get 16 shouldn't have done and you asserted a Fifth Amendment 16 answers. But if you continue to banter with the 17 privilege in refusing to answer that question. 17 witness and interrupt the witness, I will adjourn 18 I'm now attempting to find out whether ■. 18 the deposition. This is not proper and we 19 failed to do something that she should have done that 19 certainly can take it up with the Judge. So that's 20 forms the basis of your claims against her. 20 the second warning, Mr. Scarola. Please — 21 DidM. do anything that she should have done 21 MR. SCAROLA: How many do I get? 22 that forms the basis of your claims against her? 22 MR. PIKE: Inn not sure yet today. 23 MR. PIKE: Form. 23 MR. SCAROLA: Okay. 24 THE WITNESS: On advice ofCounsel, at least 24 MR. PIKE: Okay? 25 today, Mr. Scarola, Pm going to have to refuse to 25 MR. SCAROLA: Good. Then let's move on. Page 23 Page 25 1 answer that question based on my Fifth Amendment, 1 MR. PIKE: But I can tell you one thing: On a 2 Sixth Amendment and 14th Amendment Right. 2 professional nature, just because you are BY MR. SCAROLA: 3 interrupting the witness and bantering with me, I 4 Q. Did Brad Edwards do anything that he shouldn't 4 will adjourn the deposition. have done that forms the basis of your lawsuit against 5 BY MR. SCAROLA: 6 him? 6 Q. Besides having gone to the media in an attempt MR. PIKE: Form. 7 to, quote, gin up, unquote, these allegations and 8 THE WITNESS: Yes, many things. 8 engaged in what you contend to be irrelevant discovery 9 BY MR. SCAROLA: 9 proceedings, what else did Mr. Edwards, personally, do 10 Q. List them forme, please. 10 that forms the basis for this lawsuit? 11 A. He has — he has gone to the media out of, I 11 A. Mr. Edwards, personally, engaged with his 12 believe, in an attempt to gin up these allegations. Ho 12 partners, Scott Rothstein, who sits in a Federal jail 13 has contacted the media. He has used the media for his 13 cell, potentially for the rest ofhis life, he shared 14 own purposes. He has brought discovery — he has 14 information, what I've been told and — excuse me — 15 engaged in discovery proceedings that bear no 15 what I've read in the newspapers, 13 boxes of 16 relationship to any case filed against me by any ofhis 16 information that had my name on it, with other attorneys 17 clients. 17 at his fum 18 His firm, which he's the partner of, has been 18 Ho counseled his clients to maintain a 19 accused of forging a Federal Judge's signature. 19 position alleging multi-million dollar damages in order 20 Q. I want to know what Mr. Edwards — 20 for them to scam local investors out ofmillions of 21 MR. PIKE: One second. 21 dollars. 22 THE WITNESS: Excuse me. I'm answering. 22 He and his — many ofhis other partners 23 BY MR. SCAROLA: 23 already under investigation by the FBI and the U.S. 24 Q. I %nut to know what Mr. Edwards did. I'm not 24 Attorney have been accused by the U.S. Attorney of 25 asking you about allegations concerning his law firm. 25 running a criminal enterprise. 7 (Pages 22 to 25) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 1ddcfb84-b3244437-a670-765e29067145 EFTA01076618  Page 26 Page 28 1 Q. Anything else? 1 Q. Do you understand the question you're supposed 2 MR. PIKE: Form. 2 to be answering, Mr. Epstein? 3 THE WITNESS: Not I can think of at the 3 MR. PIKE: And Fm going to instruct you not 4 moment. 4 to answer that question right now because as your 5 BY MR. SCAROLA: 5 Counsel I cannot let you answer that question until 6 Q. Okay. What media did Mr. Edwards go to? 6 I understand what question is on the table. 7 A. I am aware of at least the Daily News in New 7 There's been a lot of bantering back and 8 York City. 8 forth, so, Mr. Scarola, if you would respectfully 9 I have been told by other people that there 9 repeat the question and then you may be able to ask 10 were other media, local media. 10 him whether or not he understands the question. 11 I've been told that the -- his investigator 11 But I cannot allow him to answer a question that I 12 was sent to California to harass people representing 12 don't understand is on the table. 13 his — Brad Edwards' investigator -- representing 13 BY MR. SCAROLA: 14 fictitiously, fraudulently that he was a FBI agent to 14 Q. What does an investigator going to California 15 try to gather information for Mr. Edwards' claims. 15 have to do with Mr. Edwards allegedly going to the media 16 Q. Does that have something to do with going to 16 in an attempt to, quote, gin up, unquote, these 17 the media? 17 allegations? 18 MR. PIKE: Form. 18 MR. PIKE: Please answer the question. 19 THE WITNESS: I've answered your question. 19 THE WITNESS: Good. It's part of Mr. Edwards' 20 BY MR. SCAROLA: 20 scheme to involve people who have nothing to do 21 Q. Does the investigator going to California to 21 with any of his cases in order to, in fact, go back 22 do something have something to do with the media? 22 to the media and gin up his stories and make false 23 A. I believe I've also told that you that he's 23 allegations of people that have sexually charged 24 gone to the Daily News, sir, is that coned? 24 nature cases in order to attempt to fleece 25 MR. PIKE: Form. Mischaracterizes the 25 investors, local investors out of millions of Page 27 Page 29 1 witness' testimony as well. 1 dollars. 2 BY MR. SCAROLA: 2 His firm has been accused by the U.S. Attorney 3 Q. Do you understand the question that you're 3 of manipulating the media, by hiring investigators, 4 supposed to be answering? 4 by illegal wire taps, by illegal methods of S MR. PIKE: Well, let's go ahead and repeat it. 5 eavesdropping in order to go to the media and 6 MR. SCAROLA: No, let's get an — let's get an 6 generate cases. 7 answer to that question. 7 BY MR. SCAROLA: a BY MR. SCAROLA: 8 Q. When did Mr. Edwards go to the Daily News? 9 Q. Do you understand the question you're supposed 9 A. I don't know. 10 to be answering? 10 Q. How did he go to the Daily News? 11 A. When - 11 A. I don't know. 12 MR. PIKE: I'm confused. Wait one second. 12 Q. What did he say to the Daily News? 13 THE WITNESS: Sony. 13 A. I believe Mr. Edwards knows that. I don't 14 MR. PIKE: I'm confused as to what question is 14 know exactly what he said. 15 on the table. 15 Q. What is the source of your information that he 16 MR. SCAROLA: And when your deposition is 16 went to the Daily News at all, ever? 17 being taken, your confusion is relevant and 17 MR PIKE: To the extent you can answer that 18 material. 18 question without violating any attorney/client 19 MR. PIKE: Right. And it's — 19 privileges, you can answer the questions. 20 MR. SCAROLA: When Mr. Edwards' — excuse 20 THE WITNESS: It's attorney/client 21 me — when Mr. Epstein's deposition is being taken, 21 BY MR. SCAROLA: 22 I'm concerned with whether he understands the 22 Q. You said you were told by other people that he 23 question being asked. 23 went to other media representatives? 24 MR. PIKE: Right. So... 24 A. Yes, sir. 25 BY MR. SCAROLA: 25 Q. Who are the other people that told you that? A......e..14A4, 8 (Pages 26 to 29) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Sandra Townsend (401 Electronically signed by Sandra Townsend (401 1datb84-b324.4437-8670-765e29067146 EFTA01076619  Page 30 Page 32 1 A. I don't recall at the moment- 1 themselves or were these anonymous callers? 2 Q. What did these other people who you don't 2 MR. PIKE: Form. 1 3 remember tell you Mr. Edwards did with respect to other 3 THE WTINESS: Sitting here today, Mr. Scarola, 4 media representatives besides the Daily News? 4 I don't recall with specificity. S A. Again, the question again? 5 BY MR. SCAROLA: 6 Q. What did these other people tell you 6 Q. What specifically did Mr. Edwards allegedly 7 Mr. Edwards did with respect to going to other media? 7 communicate to the Daily News to, quote, gin up these 8 MR. PIKE: Form. 8 allegations, unquote? 9 THE WITNESS: Mr. Edwards went to the media to 9 A. The newspapers have quoted Mr. Edwards -- not 10 gin up his cases in order that the Rothstein firm 10 quoted Mr. — newspapers have made allegations referred 11 could generate profits, falsely taking in 11 to as Mr. Edwards' statements. 12 investors, creating false stories