📄 Extracted Text (69,164 words)
1
IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN
AND FOR PALM BEACH COUNTY, FLORIDA
Case No. 502009CA040800XXXXMB
JEFFREY EPSTEIN,
Plaintiff,
vs.
SCOTT ROTHSTEIN, individually;
BRADLEY EDWARDS, individually,
Defendants/Counter-Plaintiffs.
VOLUME I
VIDEOTAPED DEPOSITION
OF
BRADLEY EDWARDS
Taken on Behalf of Plaintiff
Friday, November 10th, 2017
10:02 a.m. - 6:16 p.m.
2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
Examination of the witness taken before
Sonja D. Hall
Palm Beach Reporting Service, Inc.
1665 Palm Beach Lakes Boulevard, Suite 1001
West Palm Beach, FL 33401
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1 APPEARANCES:
2 For Plaintiff:
3 LINK & ROCKENBACH, P.A.
1555 Palm Beach Lakes Boulevard, Suite 301
4 West Palm Beach, FL 33401
By SCOTT J. LINK, ESQUIRE
5 By KARA BERARD ROCKENBACH, ESQUIRE
6 For Plaintiff:
7 ATTERBURY, GOLDBERGER & WEISS, P.A.
250 Australian Ave. South, Suite 1400
8 West Palm Beach, FL 33401
By JACK A. GOLDBERGER, ESQUIRE
9
10 For Plaintiff:
11 DARREN K. INDYKE, PLLC
575 Lexington Avenue
12 New York, NY 10022
By DARREN K. INDYKE, ESQUIRE
13
14 For Defendants/Counter-Plaintiffs:
15 SEARCY, DENNEY, SCAROLA, BARNHART &
SHIPLEY, P.A.
16 2139 Palm Beach Lakes Boulevard
West Palm Beach, FL 33409
17 By JACK SCAROLA, ESQUIRE
By DAVID P. VITALE, JR.
18
19 ALSO PRESENT
20 Visual Evidence, Incorporated
601 N. Dixie Highway, Suite A
21 West Palm Beach, Florida 33401
By Andrew Mazoleny, Videographer
22
Tina Campbell, Paralegal
23
24
25
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1 INDEX
2
3 Videotaped Deposition of BRADLEY EDWARDS Page No.
4
5 Direct Examination by Mr. Link 8
6 Cross-Examination by Mr. Scarola 310
7 Redirect Examination by Mr. Link 325
8 Certificate of Oath 340
9 Certificate of Reporter 341
10 Read & Sign Letter to Witness 342
11
12 PLAINTIFF'S EXHIBIT INDEX
13
14 No. Description Page No
15 1 Affidavit of Jeffrey Epstein 92
16 2 News Article 96
17 3 News Article 100
18 4 News Article 112
19 5 News Articles 145
20 6 Complaint 147
21 7 Complaint and Demand for Jury Trial 171
22 8 Email 178
23 9 Complaint 179
24 10 Answer and Counterclaim 185
25 11 Letter 189
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1 12 RRA Firm Directory 190
2 13 Email 190
3 14 Jane Doe motion 220
4 15 Email 231
5 16 Order 238
6 17 Fourth Amended Counterclaim 239
7 18 Email 259
8 19 Email 264
9 20 Email 267
10 21 Seventh Amended & Supplemental Witness List 268
11 22 Expert Witness Report (Jansen) 284
12 23 Brad Edwards Time 290
13 24 National Crime Victim Bar Association 297
14 25 Brad Edwards' Accolades 300
15
16
17 DEFENDANTS/COUNTER-PLAINTIFFS' EXHIBIT INDEX
18 (No exhibits were marked.)
19
20
21
22
23
24
25
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1 THE VIDEOGRAPHER: This is the 10th day
2 of November 2017. The time is 10:03 a.m.
3 This is the videotaped deposition of
4 Bradley Edwards, Esquire, in the matter of
Epstein versus Rothstein and Edwards.
6 This deposition is taking place at 2139
7 Palm Beach Lakes Boulevard, West Palm Beach
8 33409.
9 My name is Andrew Mazoleny. I am the
10 videographer representing Visual Evidence,
11 Incorporated.
12 Will the attorneys please announce
13 their appearances for the record?
14 MR. LINK: Scott Link on behalf of the
15 plaintiff.
16 MS. ROCKENBACH: Kara Rockenbach on
17 behalf of the plaintiff.
18 MR. INDYKE: Darren Indyke on behalf of
19 the plaintiff.
20 MR. GOLDBERGER: Jack Goldberger on
21 behalf of the plaintiff.
22 MS. CAMPBELL: And Tina Campbell
23 parallel on behalf of the plaintiff.
24 MR. SCAROLA: Jack Scarola and David
25 Vitale representing Bradley Edwards, who is
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1 the counter-plaintiff in this action; and
2 for all practical purposes, the plaintiff in
3 the claim against Jeffrey Epstein.
4 THEREUPON,
BRADLEY EDWARDS,
6 being a witness in the notice heretofore
7 filed, and being first duly sworn in the above cause,
8 testified on his oath as follows:
9 THE WITNESS: I do.
10 MR. SCAROLA: Before we begin the
11 substantive questioning, I want to make it
12 clear on the record as a consequence of an
13 exchange of communications that has occurred
14 with opposing counsel, opposing counsel has
15 taken the position that Mr. Edwards is going
16 to be deposed as if he had never been
17 deposed before, that is, opposing counsel
18 recognizes no restrictions on the scope of
19 this deposition.
20 The scope of the deposition was the
21 subject of a lengthy hearing before Judge
22 Hafele that took place on Tuesday,
23 October 3rd, 2017.
24 During the course of that hearing the
25 Court made it very clear that questioning
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1 would be limited to four specific areas
2 identified by the Judge: The filing of a
3 federal lawsuit on behalf of LM, which was
4 based upon facts that also supported the
filing of a state court claim; interaction
6 between Mr. Edwards and Mr. Rothstein and
7 others at Rothstein, Rosenfeldt Adler that
8 would relate to any potential knowledge that
9 Mr. Edwards had or should have had with
10 regard to the conduct of a Ponzi scheme by
11 Mr. Rothstein; the filing of a motion
12 seeking the posting of a $14 million bond
13 and issues relating to damages.
14 We are here for purposes of responding
15 to questions in those specific areas as
16 directed by the Court. It is our intention
17 to allow opposing counsel broad latitude
18 within those four areas. But we will raise
19 appropriate objections to any inquiries that
20 are outside those four areas, unless it can
21 be demonstrated that in some manner I have
22 misread, in spite of careful review, the
23 transcript of that hearing and the ruling of
24 the Court.
25 So my suggestion is, if opposing
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1 counsel continues to take the position that
2 this deposition is going to be conducted as
3 if Mr. Edwards had never been deposed
4 before, that we should at least deal with
those four areas as to which there is
6 agreement for inquiry, then we will worry
7 about whether any inquiry outside those four
8 areas will be allowed. Thank you.
9 MR. LINK: Obviously we disagree and we
10 are ready to proceed.
11 DIRECT EXAMINATION
12 BY MR. LINK:
13 Q Ready, Mr. Edwards?
14 A Ready.
15 Q Are you feeling anxiety today?
16 A Sure.
17 Q Tell me about it. What anxiety do you feel
18 today?
19 A I'm still -- I'm still being accused for
20 committing crimes that I didn't commit, and this case
21 is my only chance to finally set that record straight.
22 Q So tell me about the anxiety, though. What
23 are you feeling? Anxiety is an emotional reaction to
24 something, correct?
25 A Well, for today
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1 Q Yeah.
2 A -- I think that if you sit in this chair and
3 I ask you questions, you would have anxiety as well.
4 Q Okay. So you have anxiety today about my
5 asking you questions. Is that what the anxiety is?
6 A No. It's about getting this case over.
7 Q So you have anxiety about the length of
8 time the case has been pending?
9 A Well, with everyday it's worse. I want the
10 case over, and I want to right the wrong that's been
11 done. So the fact that I have a whole team of lawyers
12 over there -- I don't think Mr. Goldberger does it
13 anymore -- but there's lawyers on that side who
14 continue to falsely claim that I was part of a Ponzi
15 scheme.
16 In fact, Tonja Haddad just did it a month
17 ago.
18 Q So I don't see Tonja or her dad sitting
19 here. Do you?
20 A You are all together. You are all
21 representing --
22 MR. SCAROLA: Excuse me. Pardon me.
23 Would you please allow Mr. Edwards to
24 complete his answer?
25
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1 BY MR. LINK:
2 Q Yes, sir. Go ahead.
3 A You also decided to sign on and represent a
4 serial child molester, so you have adopted that
position.
6 Q Okay. Anything else to add to that?
7 A No.
8 Q So you see the lawyers that are here.
9 Ms. Rockenbach is with my new law firm, Link &
10 Rockenbach, correct?
11 A I got your card the other day. Thank you.
12 Q How did it look?
13 A Pretty good.
14 Q Pretty good? How about really good?
15 A I only looked at one side. Sorry. I will
16 check it out.
17 Q Ms. Rockenbach is with me. You see that.
18 Mr. Goldberger is down at the end of the table,
19 right? And Tina, who is a legal assistant at my
20 firm. Tonja Haddad is not here, is she?
21 A There isn't just a table long enough, I
22 assume. But, no.
23 Q Your lawyer hasn't shared with you -- you
24 haven't seen -- heard that they are withdrawing from
25 the case?
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1 A No.
2 MR. SCAROLA: Excuse me. Has there
3 been a notice of withdrawal? Because I
4 haven't seen it either.
5 MR. LINK: I think we represented it to
6 Judge Hafele on Wednesday with the 8:45 when
7 Kara was in front of them.
8 MR. SCAROLA: I have seen no notice of
9 withdrawal. So as we sit here today, there
10 are a total of, I think, six law firms that
11 are representing Mr. Epstein.
12 BY MR. LINK:
13 Q And one really good one. The one you saw
14 the card on this week, right?
15 Okay. So I want to focus on this anxiety.
16 We all have anxiety in life, right? I wake up every
17 morning with anxiety about something. How my kid's
18 doing in college. Did he get home last night. Is
19 my son going to get a hit today on the baseball
20 team.
21 I want to talk about a different kind of
22 anxiety. The anxiety that you feel in November 2017
23 that relates back to the lawsuit that was filed in
24 December 2009. Can you separate that anxiety that I
25 am talking about?
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1 A Just an anxious feeling to get this over
2 with.
3 Q And you had that anxious feeling every
4 single day from December 2009 through today
5 November 10th, 2017?
6 A The more reminders that I have of the case,
7 and the fact that there still looms this false
8 allegation over my head, that is clearly a trigger.
9 Q You said it looms this false allegation.
10 What is the false allegation looming over your head?
11 A That I was a participant in a Ponzi scheme
12 with one of the individuals that might be the most
13 hated person in South Florida, especially amongst our
14 profession.
15 Q Mr. Rothstein?
16 A Right.
17 Q But why is there an allegation hanging over
18 your head? The case against you was dismissed in
19 2012, correct?
20 MR. SCAROLA: Excuse me. Which case?
21 BY MR. LINK:
22 Q The case against you by Mr. Epstein was
23 dismissed in 2012, was it not?
24 A Right. The case was dismissed.
25 Q Five years ago the case was dismissed,
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1 true?
2 A Yes.
3 Q So what I'm trying to understand is, you
4 said that this was hanging over your head. Since
5 2012 there has not been a pleading that was alive in
6 circuit court from Mr. Epstein directed at you, true?
7 Since 2012?
8 A Has there -- was there a pleading against me
9 since 2012.
10 Q Yes, sir.
11 A The answer to that question is no.
12 Q So 2012, this allegation, that you said was
13 hanging over your head, has been removed, true?
14 A The complaint was dismissed.
15 Q Right. That was the allegation. And that
16 complaint has been dismissed.
17 MR. SCAROLA: Compound.
18 THE WITNESS: You are asking two
19 different things.
20 BY MR. LINK:
21 Q Well, you said --
22 A The allegation was made.
23 Q In 2009.
24 A -- and 9 million people read that allegation.
25 And --
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1 Q We are going to get to all of that.
2 MR. SCAROLA: Excuse me.
3 THE WITNESS: If you don't want me to
4 answer the question, then don't then ask
5 a question, I will answer, and you can shape
6 it however you want.
7 If you want me to give you an answer,
8 I'm willing to sit here and give you a full
9 answer.
10 BY MR. LINK:
11 Q I do. And I asked you if there has been a
12 pleading making those allegations since 2012.
13 A That's not the question that you asked. But
14 is that now the question that you are asking?
15 Q Yes.
16 A Sure. Pleadings have been filed, including
17 by Mr. Epstein's long-time recruiter of girls for him,
18 Ms. Maxwell. She made an allegation -- the same
19 allegation as part of a motion to recuse me as trial
20 counsel in a totally separate case.
21 Q What case was that you just brought up?
22 A versus Maxwell.
23 Q Where was that case pending?
24 A In New York.
25 Q And you were counsel in that case?
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1 A Yes.
2 Q Are you admitted in New York?
3 A I was pro hac.
4 Q Who was the admitted lawyer in New York?
5 A David Boies.
6 Q So you and Mr. Boies worked on that case
7 together?
8 A Yes.
9 Q How did Mr. Boies get involved?
10 A We co-represented , who is
11 also one of Mr. Epstein's victims.
12 Q Okay. Talking about the case you just
13 mentioned to me where you said Ms. Maxwell -- is that
14 right?
15 A Yes.
16 Q -- filed a pleading. Was Mr. Epstein a
17 party in that case?
18 A He had a joint defense agreement with her, so
19 he was -- he was basically advising her behind the
20 scenes. So for lack of a better word, he was basically
21 a party to the case.
22 Q So you have been practicing how many years
23 now? Fifteen?
24 A Yeah.
25 Q And you know what a party to a case is,
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1 right, in a civil lawsuit?
2 A I do.
3 Q Was Mr. Epstein a party in that lawsuit?
4 A A party in the sense was he in the style of
5 case, he was not.
6 Q Do you know what a party is in a lawsuit?
7 A Do you?
8 Q Yes, sir, I do.
9 A Okay. So right before trial we had an
10 argument that I believe was going to go in our favor
11 that we were going to be able to use his --
12 Mr. Epstein's Fifth Amendment invocation against
13 Ms. Maxwell, because of the LiButti factors, and
14 because he was basically a party and interest to the
15 case.
16 Was he in the style of the case? He was
17 not. But because they were so tightly connected as
18 conspirators, his interests were so intertwined with
19 hers, that we were going to be able to use his Fifth
20 Amendment invocation against her, which is a very
21 unusual and atypical situation.
22 Q Sounds like an interesting evidentiary
23 issue.
24 A Agreed.
25 Q In that case, who brought the client to
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1 whom? Did you have the client and you went to
2 Mr. Boies, or did Mr. Boies have it and he came to
3 you?
4 A I represented first.
5 Q What made you go to David Boies?
6 MR. SCAROLA: You don't need to answer
7 that question. We object on the basis of
8 work product.
9 BY MR. LINK:
10 Q Other than work product, was there a reason
11 that you went to Mr. Boies for this what type of
12 case is it, by the way? I'm sorry. The case that
13 you filed.
14 A When David Boies became involved with
15 -- it's a complicated question,
16 because as a client in the case that was brought the
17 defamation case -- she was David Boies' client before
18 mine. In a more general sense, in terms of who
19 represented first, myself or Mr. Boise, I did.
20 I represented her in the Crime Victims' Rights Act
21 case.
22 Q Here in Florida?
23 A Here in Florida.
24 Q Yes, sir.
25 A David and David's firm filed the defamation
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1 action and represented her in the defamation action
2 before bringing me in.
3 Q Who did Ms. Roberts sue in the defamation
4 action?
5 A Ghislaine Maxwell.
6 Q They did not sue Mr. Epstein?
7 A No.
8 Q And they brought you into the case after it
9 was filed to provide assistance?
10 A Correct.
11 Q So David Boies hires you in Florida to help
12 him prosecute the case; is that right?
13 A When you say the case, we are talking the
14 defamation action?
15 Q The defamation case, yeah. Dave Boise's
16 firm --
17 A We are talking multiple cases, so I just want
18 to make sure that we make the question and the answer
19 clear. Yes, defamation case he brought me in.
20 Q So David Boies filed the defamation action
21 and made the decision to co-counsel with you in
22 Florida to help him in New York; is that right?
23 A He made the decision to co-counsel with me.
24 Q In a New York case?
25 A In a New York case.
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1 Q Got it. Okay.
2 In that case, Mr. Boies had represented
3 in a prior proceeding other than a
4 defamation action, or only in the defamation action?
A I am trying get the timing. He represented
6 her in another proceeding. Whether it was a prior
7 proceeding --
8 Q What was the other proceeding? Then we
9 will figure out the chronology.
10 A He represented her as a witness.
11 Q In what case was that?
12 A In a defamation action I filed against Alan
13 Dershowitz.
14 Q You're right. It is completed.
15 So the first action that gets filed is you
16 sued Alan Dershowitz?
17 A Right.
18 Q For defamation?
19 A Right.
20 Q That case has been dismissed, right?
21 A Right.
22 Q In that case was a witness?
23 A She was subpoenaed by Dershowitz to be a
24 witness.
25 Q And she hired David Boies to represent her?
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1 A Correct.
2 Q As a witness?
3 A Right.
4 Q And was she deposed in that case?
5 A She was.
6 Q And Mr. Boies was there to represent her?
7 A Someone from his firm was there to represent
8 her.
9 Q Then as a result of that, he ended up
10 representing -- Mr. Boies ended up representing her
11 in her own defamation case?
12 A Right. I'm not sure that the chronology is
13 exactly that, whether her deposition came first or the
14 defamation action came first. In fact, I think the
15 defamation action was filed before her deposition in
16 the other case, but that's why this just gets a little
17 complicated.
18 Q The chronology is complicated?
19 A Right.
20 Q I got it.
21 Now, is that case still pending, the
22 defamation case?
23 A No.
24 Q That case has been resolved?
25 A Settled in May, I believe, of this year.
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1 Q 2017?
2 A Correct.
3 Q So I want to get back to anxiety. And you
4 understand what I've meant that I have anxiety every
day. Everybody in life has levels of anxiety. You
6 agree with that?
7 A I suppose.
8 Q I had a lot of anxiety when I took the bar
9 exam. You may not have.
10 A In some different form -- I think that's a
11 word that's used that describes a bunch of different
12 feelings.
13 Q Absolutely. I agree.
14 What I'm really trying to understand
15 is I want to compartmentalize this. I'm focused
16 now on 2012, once Mr. Epstein dismissed his claims
17 against you in court. So from that date through
18 today, that cloud is no longer hanging over your
19 head. I would like to understand what your anxiety
20 is that relates to the lawsuit filed in 2009. How
21 it's impacting you on a day-to-day basis.
22 A It's hard for me to answer your question,
23 while along the way I'm disagreeing with the various
24 statements that you're making.
25 Q Tell me what you disagree with, sir.
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1 A You're making a statement the cloud is no
2 longer over my head. That's the basis -- that's the
3 predicate for your ultimate question. That's just not
4 true.
5 Q So as you sit here today, there's a cloud
6 over your head as a result of the 2009 lawsuit that
7 was filed that was dismissed in 2012?
8 A For sure.
9 Q And how does it impact you? What I am
10 trying to understand is, you are going to ask the
11 jury to award money to you based on your level of
12 anxiety, right?
13 That's one of the things you want the jury
14 to do, is to say, I have anxiety and I want to be
15 compensated.
16 A As lawyers, what we have is our reputation.
17 That's what was destroyed.
18 Q We are going to get to reputation.
19 A That's --
20 MR. SCAROLA: Excuse me. Please --
21 MR. LINK: I'm sorry. I apologize.
22 I'm just trying to streamline this. We will
23 get to reputation.
24 MR. SCAROLA: Well, what will
25 streamline it is if you ask a question and
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1 allow Mr. Edwards to complete his answer
2 before you interrupt him.
3 MR. LINK: I got it. Thank you.
4 BY MR. LINK:
5 Q So I want to make sure that I understand --
6 I want you to tell us -- you are asking the jury to
7 award you an amount of money based on your having
8 suffered every day anxiety as a result of the lawsuit
9 that was filed in December 2009. Do I have that
10 right?
11 A Do you have that right? The anxiety is
12 related -- directly related to the harm done to my
13 reputation as a consequence of the filing of this false
14 lawsuit making up that I am a criminal associated with
15 who is known to be a terrible and horrible person. I
16 mean, that is the -- the anxiety is related to that.
17 Q I understand that generally. But I need to
18 know specifically. Let me start by this.
19 How much are you asking the jury to award
20 you for your day-in-and-day-out anxiety from
21 December 2009 through today?
22 A An amount of money that fairly and fully
23 would measure the magnitude of the harm done to my
24 reputation, and any consequential feelings that have
25 resulted or continue to exist because of the damage
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1 done to my reputation.
2 Q How much are you asking for, sir, as it
3 relates to anxiety?
4 A I just explained to you.
5 Q There's not a dollar figure?
6 A What six people believe will measure the
7 magnitude of the harm that was done. If we want to
8 talk about the harm that was done, and then me tell you
9 how I would measure the magnitude of that damage, I
10 will try to walk you through that.
11 Q That would be great. But let's start here.
12 I want you to start with telling me has the anxiety
13 from 2009 through today increased or decreased?
14 A Until -- until the truth is known and this
15 case is behind me, it's the same.
16 Q So the anxiety level you have been burdened
17 with every single day since December of 2009 hasn't
18 changed in a positive or negative way?
19 A Well, there's no scale for anxiety. You know
20 this. Like you said, you have anxiety every single
21 day. It's not like you wake up and there's an anxiety
22 meter.
23 Now, when I was first served with the
24 lawsuit and people were asking about it and people
25 were talking about it all the time as, Hey, look,
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1 so-and-so is also saying this lawsuit was filed.
2 There's these big-time lawyers that are behind it
3 pushing this. People are now believing that you're
4 part of this.
5 Now, when you're hearing that all of the
6 time and you're having to deal with that on a
7 day-to-day basis, then your anxiety level, to use
8 your word, is -- I wouldn't say higher, but it's
9 aggravated on a more consistent basis.
10 Q So --
11 A These days I hear it less.
12 Q So from 2009 through today, what other
13 events have happened, other than the December 2009
14 Epstein lawsuit against you, that have caused you
15 anxiety? Anything?
16 A Nothing that comes to mind.
17 Q Any mortgage foreclosure actions against
18 you during that time period?
19 A Did I have a foreclosure action? I think I
20 did, but not one that caused me anxiety.
21 Q So having your house sold at sale didn't
22 cause you any anxiety?
23 A No.
24 Q Ever get sued for not paying a credit card
25 after 2009?
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1 A Could you show me something to refresh my
2 recollection? I don't remember that.
3 Q Being sued for not paying a credit card,
4 would that cause you anxiety?
5 A No. I don't remember it, so it doesn't.
6 Q Any other lawsuits filed against you for
7 not paying your debts, for money that you owed to
8 people or banks?
9 A Talking about since 2009?
10 Q Yes, sir.
11 A Do you have anything that could refresh my
12 recollection on this? Not that I recall.
13 Q As you sit here, you don't remember being a
14 defendant in a civil lawsuit where any entity has
15 claimed you did not pay them money that you owed
16 them?
17 A Ever in my life?
18 Q No. Since 2009, sir.
19 A I had an action that resulted from a line of
20 credit that I had prior to going to RRA, that I was
21 told when I went to RRA was going to be paid, and it
22 wasn't. And I resolved that at some point in time
23 after suit was filed.
24 Yeah, I believe that suit was filed and
25 then I resolved the case. It's not something that
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1 caused me anxiety.
2 Q So the three lawsuits that we just
3 discussed where you were sued for not paying your
4 debts back, that didn't cause you any anxiety; is
5 that right?
6 A Right. There was never a time where I wasn't
7 going to pay my debt, so it didn't cause me anxiety.
8 Q Well, your house was sold at a foreclosure
9 sale, wasn't it?
10 A The answer to your question is yes.
11 Q That didn't cause any anxiety?
12 A No. The circumstances of that did not cause
13 me anxiety.
14 Q And you said that Mr. Rothstein promised to
15 pay off your $200,000 credit line that you took out
16 in order to start your sole practice as a lawyer; is
17 that right?
18 A He promised to pay the credit line over the
19 time that I was employed at RRA at some point. I don't
20 remember it being $200,000. You are just throwing
21 these facts into the question that I don't recall.
22 Q So how much money did you borrow in order
23 to start your sole practice law firm?
24 A I don't remember that.
25 Q Did Mr. Rothstein promise you during the
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1 time that you were interviewing that he would make
2 the monthly payments or he would pay whatever that
3 amount was off?
4 A My meeting with him was about 10 minutes.
And what he said was, do you have a line of credit?
6 Don't worry about it. It will be paid off at some
7 point in time that you are at this firm. We are going
8 to treat you fairly. That was it. There was no
9 specifics about it. Nobody laid out the credit line.
10 It wasn't that kind of meeting.
11 Q I got it.
12 Did you ever ask Mr. Rothstein to pay it
13 off during the time that you were employed by him?
14 A No. I hardly talked to the guy.
15 Q My question wasn't whether you talked to
16 him. It was whether you ever asked him to fulfill
17 A In order to ask somebody you have to talk to
18 them.
19 MR. SCAROLA: Excuse me. Doesn't
20 asking involve talking?
21 MR. LINK: You can do it by email or
22 letter. Lots of different ways,
23 Mr. Scarola.
24 BY MR. LINK:
25 Q But did you, in any form of communication,
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1 ask Mr. Rothstein to fulfill his promise to you -- as
2 an inducement to become an employee there -- that he
3 would pay off whatever line of credit you had?
4 A No.
Q No. You did not?
6 A Right. I answered the question. No.
7 Q I just didn't hear you.
8 A Still no.
9 Q Were there any other financial incentives,
10 other than paying off the line of credit, in the 10
11 minutes you spent with Mr. Rothstein, that made you
12 decide that's the place you wanted to work?
13 A No.
14 Q Anything else since 2009 through today that
15 has caused anxiety, other than the fact that
16 Mr. Epstein filed his claim in December?
17 A I think I told you. That word encompasses so
18 many different feelings. Like you said, we all feel
19 anxiety to some degree every single day.
20 I mean, I try cases. I'm a trial lawyer,
21 so there's anxiety. There's healthy anxiety.
22 There's unhealthy anxiety. Do things cause anxiety?
23 Everything causes some form of anxiety.
24 Q So you get anxious before you try a case?
25 A Sure.
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1 Q You have anxiety?
2 A For sure.
3 Q Have you communicated to any of the folks
4 you've represented since 2009 that you are suffering
5 from a high level of anxiety, an anxiety that should
6 be compensated by a jury in describing for them
7 whether you were fit to represent them?
8 MR. SCAROLA: Objection.
9 Attorney-client privilege. Don't answer
10 that question.
11 BY MR. LINK:
12 Q Have you not retained -- have you not been
13 retained by any client since 2009 as a result of this
14 compensable level of anxiety that you suffer every
15 day?
16 A Explain your question a little better.
17 Q Are there any clients that you wanted to be
18 your client that said, I'm not going to hire you,
19 Mr. Edwards, because I can see you're manifesting
20 some level of anxiety, that's not just a typical
21 anxiety that we all go through, it's a heightened
22 level, it's a compensable level, as a result of
23 Mr. Epstein's lawsuit?
24 A No.
25 Q Any clients fire you as a result of this
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1 heightened level of anxiety?
2 A No.
3 Q Have you made more money collectively each
4 year from January 2010 forward to today than you did
5 January 2010 back to when you started practicing law?
6 You are staring at your lawyer. You want
7 an objection.
8 A I will answer the question if he wants me to
9 answer the question.
10 MR. SCAROLA: You can answer that
11 question.
12 BY MR. LINK:
13 Q I'm asking big picture.
14 A All right. Can you repeat the question?
15 Q Let me do it again. It will probably be
16 easier. The good news is, I never remember what just
17 came out of my mouth.
18 Here is the point. I want to look at this
19 injury to your reputation and your embarrassment and
20 all of these other things you are asking the jury to
21 award money to you for, right? That's what you're
22 asking the jury to do, to compensate you for the
23 impact that the Epstein lawsuit had on your ability
24 to practice law. True?
25 MR. SCAROLA: No.
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1 THE WITNESS: I can't tell if you're
2 talking or asking a question.
3 MR. SCAROLA: There is no claim in this
4 case for either lost earnings or diminished
5 earning capacity. That's been made clear on
6 the record previously.
7 MR. LINK: I understand that, and
8 that's not -- let me back up. That's a good
9 point. Mr. Scarola, thank you for helping
10 me with that. I appreciate it.
11 BY MR. LINK:
12 Q Is the reputation that was injured Bradley
13 Edwards as an individual, or Bradley Edwards as a
14 licensed practicing lawyer?
15 A Both.
16 MR. SCAROLA: Excuse me. I'm going to
17 object to the form of the question. It
18 attempts to draw a distinction that makes no
19 sense to me.
20 BY MR. LINK:
21 Q We all have a reputation as a person in our
22 community, just as a father, as a husband, right? In
23 our regular community we have a reputation, right?
24 A Okay.
25 Q Do you?
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1 A Do I have a reputation?
2 Q Yes, sir.
3 A Everybody has a reputation.
4 Q Right. Then we have -- separate from that,
we have a reputation. If we're lawyers, we have a
6 reputation with judges. We have a reputation with
7 opposing counsel. We have a reputation with our
8 co-counsel. And we have what I will call a
9 professional reputation. And we spend a lot of time
10 and effort protecting our professional reputation.
11 You agree with that statement?
12 A Yes.
13 Q What I'm trying to understand is, was it
14 your are you seeking compensation from the jury
15 for the filing of that complaint based on harm to
16 your reputation in your professional capacity as a
17 lawyer or in your personal capacity as a husband?
18 MR. SCAROLA: And I object to the form
19 of the question, because it leaves out the
20 obvious third alterative, which is both.
21 BY MR. LINK:
22 Q You can answer my question.
23 A Both. I answered the question the first time
24 both.
25 Q Can you separate for me -- and tell me from
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1 a compensatory standpoint money the jury should award
2 to you, what has happened to your reputation from a
3 personal standpoint? Give me an example.
4 Do you have friends that will no longer
5 talk to you since the filing of the complaint by
6 Mr. Epstein?
7 A Do I have friends who don't talk to me
8 because of that?
9 Q Yeah. Do you have friends that --
10 A You are talking about the people who knew me?
11 The people who knew me?
12 Q Yeah.
13 A No.
14 Q So in November of 2009, before the lawsuit
15 was filed, I assumed you had friends, right?
16 A Right.
17 Q Do you still have those same friends today
18 for the most part?
19 A I still have friends today.
20 Q Did anybody come up to you and say, Listen,
21 Brad, you know, I used to like you and I used to like
22 being your friend. You were a swell guy to hang out
23 with, but geez, I see Epstein filed this claim
24 against you and I don't want to be your friend
25 anymore?
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1 A Are you talking now about lawyers or are you
2 talking about --
3 Q No, personal.
4 A People who are nonlawyers.
Q Nonlawyers. Because you said both.
6 A I'm just trying to get a category so I
7 understand the question. So have nonlawyers come up to
8 me and say I will no longer be your friend because of
9 the lawsuit?
10 Q Yeah.
11 A No.
12 Q Do you go to a church?
13 A Not regularly.
14 Q Did you go to a church in 2009?
15 A Periodically. But nobody has come up to me
16 at church and said I'm not going to be your friend
17 anymore or associate with you because of this lawsuit.
18 The people who know me don't do this.
19 Q So from a personal standpoint anyone who
20 knew you, your reputation really didn't take a hit as
21 a result of Epstein filing his lawsuit in
22 December 2009.
23 A The lawsuit is not about -- about
24 reputational damage that was caused to me by the people
25 who know me well. The people who know me well know
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1 that those things are not true.
2 The lawyers I practice with know that
3 those things are not true. It's the rest of the
4 world that --
Q Oh, okay.
6 A Your reputation is made up of what society
7 thinks of you. The people who don't know me and only
8 got a snapshot of this person -- is Rothstein's
9 co-conspirator in a Ponzi scheme and continue to spread
10 that message from that point in time forward, whether
11 it's 9 million people or 100 million people, my
12 reputation right there suffered damages that, unless
13 and until a jury returns a verdict in my favor, can't
14 be undone.
15 Q So these are the nameless, faceless folks
16 that you don't know, that you have never met, never
17 had conversations with, never interacted with, who
18 are -- that have impacted your reputation.
19 A Your question is way too extreme.
20 Q So you told me it's anyone who knows you,
21 knows for sure that there's nothing
22 A I didn't tell you that.
23 Q You didn't?
24 A No. Who knows me well.
25 Q They have to know you well, right?
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1 A Can I just finish my answer?
2 Q Sure.
3 A I let you finish every question. You refuse
4 to let me finish
ℹ️ Document Details
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879da1ab2e6ebc1f583a7f597d7877147571e20f4d4e832f689a7d7173a6b0ee
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EFTA00800508
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