EFTA00586427.pdf
ROTHSTEIN DEPOSITION NOTES
From Roy:
Have Rothstein name as many lawyers as possible as knowing about or actively being
involved in the schemes. Start out that he didn't hide it from the lawyers. They knew
something was going on. They knew where the money was coming from. They all
wanted to be part of the rock style practice of law.
Then move to the Epstein cases. He needed details of the cases to use them to sell the
settlements. He needed help to get that from the lawyers on the case. He gave orders to
them. He read the files. He had investigation done. These lawyers had to know something
was up. Don't mention Edwards to begin with. Lead into it with a whole bunch of
questions around the cases. Need him to say Edwards had to be onboard. Edwards was a
smart guy. He had to realize something was up. What emails to him. What questions to
him. What did he tell him about funding the cases. Did he ask where the money was
coming from? Did he want investigation done on Epstein's friends? Did he want big
names to help sell the cases? Flight manifests??
From Marty:
Privilege log - Rothstein on lots of emails with Edwards and lots of others at RRA. This
can show breadth of involvement in case with Brad in middle; a full firm effort without
any concealment of the over the top investigation and objectives. Ask about the use of
ex-FBI agent as lawyer. Rothstein must have authorized open-ended investigation - used
money that came from other frauds. Rothstein knew of surveillance of JE property -
didn't Rothstein tell a potential investor that he had PIs who could electronically
surveillance JE? Run thru list of what R authorized or approved or knew investigators
did to expand case and pressure JE by going after his friends, clients, public figures.
Does anyone have this list or an analysis of what it is we believe/know that Rothstein
knew/should have known/ordered to be done?
From Jeffrey:
Get spin by the questions that will be read by the press. Spend some time (on what
Rothstein knew?). For instance: did you know that no girls ever traveled (on the
plane?); Did you know that the girls were prostitutes (all of them? and lied about their
ages???); Did you suspect that Edwards was having an affair with the girls (I can't ask
that unless we have some basis in fact for doing so-); Do you know how Edwards came
to have these cases? Were these cases what prompted you to hire Edwards? Did you
know that they engaged in illegal entry and used wiretaps? (Was that RRA or the
FEDS?) Cam Holmes was a former tbi agent working for you at the time- why was she
working for you? How did you come to meet her?
Have Scott layout the number of contacts and social interactions between he and
Edwards. Did Scott follow the Epstein cases on q task? Why?
EFTA00586427
EFTA00586428
From Roy:
Have Rothstein name as many lawyers as possible as knowing about or actively being
involved in the schemes. Start out that he didn't hide it from the lawyers. They knew
something was going on. They knew where the money was coming from. They all
wanted to be part of the rock style practice of law.
Then move to the Epstein cases. He needed details of the cases to use them to sell the
settlements. He needed help to get that from the lawyers on the case. He gave orders to
them. He read the files. He had investigation done. These lawyers had to know something
was up. Don't mention Edwards to begin with. Lead into it with a whole bunch of
questions around the cases. Need him to say Edwards had to be onboard. Edwards was a
smart guy. He had to realize something was up. What emails to him. What questions to
him. What did he tell him about funding the cases. Did he ask where the money was
coming from? Did he want investigation done on Epstein's friends? Did he want big
names to help sell the cases? Flight manifests??
From Marty:
Privilege log - Rothstein on lots of emails with Edwards and lots of others at RRA. This
can show breadth of involvement in case with Brad in middle; a full firm effort without
any concealment of the over the top investigation and objectives. Ask about the use of
ex-FBI agent as lawyer. Rothstein must have authorized open-ended investigation - used
money that came from other frauds. Rothstein knew of surveillance of JE property -
didn't Rothstein tell a potential investor that he had PIs who could electronically
surveillance JE? Run thru list of what R authorized or approved or knew investigators
did to expand case and pressure JE by going after his friends, clients, public figures.
Does anyone have this list or an analysis of what it is we believe/know that Rothstein
knew/should have known/ordered to be done?
From Jeffrey:
Get spin by the questions that will be read by the press. Spend some time (on what
Rothstein knew?). For instance: did you know that no girls ever traveled (on the
plane?); Did you know that the girls were prostitutes (all of them? and lied about their
ages???); Did you suspect that Edwards was having an affair with the girls (I can't ask
that unless we have some basis in fact for doing so-); Do you know how Edwards came
to have these cases? Were these cases what prompted you to hire Edwards? Did you
know that they engaged in illegal entry and used wiretaps? (Was that RRA or the
FEDS?) Cam Holmes was a former tbi agent working for you at the time- why was she
working for you? How did you come to meet her?
Have Scott layout the number of contacts and social interactions between he and
Edwards. Did Scott follow the Epstein cases on q task? Why?
EFTA00586427
EFTA00586428