EFTA00081220.pdf

Case 9:08-cv-80736-KAM Document 291-23 Entered on FLSD Docket 01/21/2015 Page 1 of 6 EXHIBIT 24 EFTA00081220  Case 9:08-cv-80736-KAM Document 291-23 Entered on FLSD Docket 01/21/2015 Page 2 of 6 Page 1 Page 3 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT 1 - - - IN AND FOR PALM BEACH COUNTY, FLORIDA 2 CASE No.502009CA040800XXXXMBAG EXHIBITS 3 - - - JEFFREY EPSTEIN, 4 Plaintiff, NUMBER DESCRIPTION PAGE vs 5 6 Exhibit number 1 Eyeglasses 133 SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS. individually, and 7 L.M., individually, 8 9 Defendants. 10 VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN 11 Wednesday. March 17. 2010 12 10:17 a.m.- 1:27 p.m. 13 14 303 Banyan Boulevard 15 suite 400 West Palm Beach, Florida 33401 16 17 18 Reported By: Sandra W. Townsend, FPR 19 Notary Public, State of Florida 20 West Palm Beach Office Job #1358 21 22 23 24 25 Page 2 Page 4 1 APPEARANCES: 1 PROCEEDINGS 2 On behalfof the Plaintiff 2 3 MICHAEL PIKE, ESQUIRE -— BURMAN CRITrON LUTTIER & COLEMAN, LLP 3 Deposition taken before Sandra W. Townsend, Court 4 303 Banyan Boulevard. Suite 4013 4 Reporter and Notary Public in and for the State of West Palm Beach, Florida 33401 5 Phone: 561.842.2820 5 Florida at Large, in the above cause. 6 6 - -- 7 On behalfof the Defendant Bradley Edwards: 7 8 JACK SCAROLA, ESQUIRE VIDEOGRAPHER: We are now on video record. SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY 8 This is media number one in the videotaped 9 2139 Palm Beach Lakes Boulevard 9 deposition of Jeffrey Epstein in the matter of West Palm Beach, Florida 33409 10 Phone: 561.686.6300 10 Jeffrey Epstein versus Scott Rothstein, Bradley 11 On behalfof the Defendant L.M.: 11 Edwards and L.M. 12 BRADLEY EDWARDS, ESQUIRE FARMER, JAFFE, WEISSING, EDWARDS, FISTOS, 12 Today is Wednesday, March 17. 2010 at 13 & LEHRMAN. P.L. 13 10:17 a.m. 425 North Andrews Avenue 14 We are at the law offices of Burman, 14 Suite 2 Fort Lauderdale, Florida 33301 15 Critton -- Banyan — of Burman, Critton on Banyan 15 Phone: 954.524.2820 16 Boulevard, Suite 400, West Palm Beach, Florida. 16 Also Present: 17 STEVEN JAFFE, ESQUIRE 17 My name is Joe Kozak. I'm the video her. FARMER, JAFFE, WEISSING, EDWARDS, FISTOS, 18 The court reporter is Sandra Townsend from Prose 18 & LEHRMAN. P.L. 19 Court Reporting Agency. 425 North Andres Avenue 19 Suite 2 20 Would Counsel please introduce yourselves and Fort Lauderdale, Florida 33301 21 then the court reporter will swear in the witness. 20 Phone: 954.524.2820 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. 1 (Pages 1 to 4) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically Signed by Sandra Townsend (401.377.676.2895) Electronically Signed by Sandra Townsend (401.377.676.2895) lddctb84-b324.4437-a670.765e29067145 EFTA00081221  Case 9:08-cv-80736-KAM Document 291-23 Entered on FLSD Docket 01/21/2015 Page 3 of 6 Page 89 Page 91 1 Amendment Rights as provided by the U.S. 1 about. The one in which your deposition is being taken 2 Constitution. 2 today. 3 BY MR. SCAROLA: 3 Do you know who brought those persons' names 4 Q. Does a flight log kept for a private jet used 4 into this lawsuit? 5 by you contain the names of celebrities, dignitaries or 5 A. As a reaction, and only as a reaction to total 6 International figures? 6 misbehavior on Mr. Edwards' part, and the Complaint wai 7 A. At least today, sir, I'm going to have to 7 obviously written by my attorneys, sir. 8 respectfully decline to answer based on my Fifth, Sixth 8 Q. So you know that those names are in your 9 and 14th Amendment Right, though I'd like to answer that 9 Complaint, right? 10 question. 10 A. Yes, sir. 11 Q. Have you ever had a personal relationship with 11 Q. Okay. So because those names are in your 12 Donald Trump? 12 Complaint, I'm asking you about the people you named. 13 A. What do you mean by "personal relationship," 13 Have you had a social relationship with Tommy 14 sir? 14 Mottola? 15 Q. Have you socialized with him? 15 A. The names in my Complaint are strictly as a 16 A. Yes, sir. 16 reaction to the abusive discovery process by 17 Q. Yes? 17 Mr. Edwards, his partners, Scott Rothstein, who sits in 18 A. Yes, sir. 18 jail, in an attempt to imperil my friendships. 19 Q. Have you ever socialized with Donald Trump in 19 But, yes, I have socialized with Mr. Mottola. 20 the presence of females under the age of 18? 20 Q. Have you ever socialized with Mr. Mottola in 21 A. Though I'd like to answer that question, at 21 the presence of females under the age of 18? 22 least today I'm going to have to assert my Fifth, Sixth 22 MR. PIKE: Form. 23 and 14th Amendment Right, sir. 23 THE WITNESS: At least today, the typical to 24 Q. Have you socialized with Alan Dershowitz? 24 the Edwards contention of bringing cases of a 25 A. Yes, sir. He's my attorney, as well as a 25 malicious nature where his partner sits in jail for Page 90 Page 92 1 friend. 1 this — just this type of behavior, the answer is, 2 Q. Have you ever socialized with Alan Dershowitz 2 today, at least, I must assert my Fifth, Sixth and 3 in the presence of females under the age of 18? 3 14th Amendment Right, though I'd like to answer 4 MR. PIKE: Form. 4 each and every one of your questions, Mr. Scarola. 5 THE WITNESS: Sir, at least here today, I'm 5 BY MR. SCAROLA: 6 going to have to assert my Fifth Amendment, Sixth 6 Q. Have you had a social relationship with David 7 Amendment and 14th Amendment Rights. 7 Copperfield? 8 BY MR. SCAROLA: 8 A. As a reaction to, once again, the abusive 9 Q. Have you ever socialized with Tommy Mottola'. 9 discovery process of bringing in names of people that 10 A. This is the type of questions where people who 10 have absolutely nothing to do with any of Mr. Edwards', 11 have nothing to do with this case whatsoever have been 11 Mr. Rothstein's or their clients' claims, by bringing in 12 brought into the case by Mr. Edwards in an attempt to 12 the names of friends of mine strictly in an attempt to 13 simply imperil my relationships with social friends and 13 stress my relationships, imperil my business 14 serves as an example of why this case has been brought 14 relationships, I'm going to say, yes, I do know 15 against Mr. Edwards and his firm, sir. 15 Mr. Copperfield. 16 MR. PIKE: Form as well. 16 Q. Have you ever socialized with David 17 BY MR. SCAROLA: 17 Copperfield? 18 Q. Well, do you know who brought those persons' 18 A. Again, as -- 19 names into this lawsuit? 19 MR. PIKE: Form. 20 MR. PIKE: Form. 20 THE WITNESS: Sorry. 21 And just to be clear, what Mr. Scarola, I 21 It's a typical Edwards/Rothstein strategy of 22 believe, talking about this lawsuit, Epstein versus 22 trying to involve well-known people in maliciously 23 RRA? 23 fabricated cases in order to fleece investors out 24 BY MR. SCAROLA: 24 of millions of dollars. They brought up names in 25 Q. Yes, sir. that's the lawsuit I'm talking 25 attempts at abuse of discovery process to try and 23 (Pages 89 to 92) (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Sandra Townsend (401.377-676.2895) Electronically signed by Sandra Townsend (401.377.676.2895) lddcfbB4-b324-4437-a670-765e29067145 EFTA00081222  Case 9:08-cv-80736-KAM Document 291-23 Entered on FLSD Docket 01/21/2015 Page 4 of 6 Page 16 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No. 502008CA037319XXXXMB AB B.B., Plaintiff, -VS- JEFFREY EPSTEIN, Defendant. CONTINUED DEPOSITION OF JEFFREY EPSTEIN VOLUME II Thursday, October 8, 2009 10:07 - 1:03 p.m. 250 South Australian Avenue Suite 1400 West Palm Beach,Florida 33401 Reported By: Jeana Ricciuti, RPR, FPR, CLR Notary Public, State of Florida Prose Court Reporting Agency, Inc. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Ricciuti (601-280-428-9381) Electronically signed by Jeana Ricciuti (601-280-428-9381) a41caccd-2433-45cb-b5a2-c08425252f79 EFTA00081223  Case 9:08-cv-80736-KAM Document 291-23 Entered on FLSD Docket 01/21/2015 Page 5 of 6 Page 121 1 respect to the charges brought against you in Palm Beach 2 for having sex with underaged girls and soliciting 3 underaged girls for prostitution? 4 (Interruption in the proceedings.) 5 MR. GOLDBERGER: Thank you. 6 Hey Kathy, it's Jack Goldberger. You're back 7 on. 8 MS. EZELL: Okay, good. Thanks, Jack. 9 MR. GOLDBERGER: Okay. 10 MS. EZELL: I'm putting the mute on. 11 MR. GOLDBERGER: Okay. 12 THE WITNESS: Can you read me the question? 13 MR. KUVIN: Sure. Could you read it back, 14 please? 15 (A portion of the record was read by the 16 reporter.) 17 THE WITNESS: No. 18 BY MR. KUVIN: 19 Q. Isn't it true that you pledged $30 million to 20 Harvard University in 2003, which is shortly before 21 charges were brought against you in Palm Beach? 22 A. I'll answer that question the same way I've 23 answered most of your other questions here today, which 24 is, I fully intend to respond to all relevant questions 25 regarding this lawsuit; however, at the present time, my (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana Riccluti (601-280.428.9381) Electronically signed by Jeana Ricclull (601-280.428.9381) a41caccd-243345cb-b5a2-08425252179 EFTA00081224  Case 9:08-cv-80736-KAM Document 291-23 Entered on FLSD Docket 01/21/2015 Page 6 of 6 Page 122 1 attorneys have counseled me I cannot provide answers to 2 any questions relevant to this lawsuit. I must accept 3 this advice or risk losing my 6th Amendment right to 4 effective representation. Accordingly, I assert my 5 federal constitutional rights as guaranteed by the 5th, 6 6th and 14th Amendment to the US Constitution. 7 Q. And isn't it true also that you have retained 8 Alan Dershowitz to defend you in the criminal charges 9 that were brought against you in Palm Beach? 10 MR. GOLDBERGER: Attorney-client. 11 MR. PIKE: Attorney-client, work product. 12 BY MR. KUVIN: 13 Q. Isn't it also true that Alan Dershowitz works 14 on staff at Harvard University as a professor? I mean, 15 if you know. 16 A. I'm going to answer that question like I've 17 answered most of your other questions here today, which 18 is, I fully intend to respond to all relevant questions 19 regarding this lawsuit; however, at the present time, my 20 attorneys have counseled me I cannot provide answers to 21 any questions that may be relevant to this lawsuit. I 22 must accept this advice or risk losing my 6th Amendment 23 right to effective representation. Accordingly, I 24 assert my federal constitutional rights as guaranteed by 25 the 5th, 6th and 14th Amendment to the US Constitution. (561) 832-7500 PROSE COURT REPORTING AGENCY, INC. (561) 832-7506 Electronically signed by Jeana RicclutI (601-280.428.9381) Electronically signed by Jeana Ricclutl (601-280.428.9381) a4lcaccd-2433-45cb-b5a2-c08425252f79 EFTA00081225