EFTA01089049.pdf
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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 â– 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 â– 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
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INDEX
WITNESS: Page
BRADLEY EDWARDS
Direct Examination cont'd by MR. HADDAD 114
EXHIBITS
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
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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
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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
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1 between yourself and either, what's his name, , or
2 Miss , whatever you want
3 to call her?
4 A That's my understanding.
5 Q All right. Well, this all came from your
6 files and from your records, correct, e-mails, whatever
7 you call those things where you store e-mail servers or
8 whatever there?
9 A You sent a request, I did whatever searches
10 that I could to come up with all of the documents
11 between us and I turned them over to my attorney who
12 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 --
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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
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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
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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.
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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 Q All right. There is a carbon copy to
9 and , correct?
10 A Okay.
11 Q Okay doesn't answer. Yes or no? I need
12 A That's what it appears to be.
13 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?
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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?
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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 --
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1 you know, I'm not that adept at the rules of civil
2 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 A Right.
7 Q But you can make a voluntary disclosure at
8 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
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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.
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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 --
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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
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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
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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
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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?
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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
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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.
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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.
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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
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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
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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
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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
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1 have your own separate Brad Edwards PA trust account?
2 A No. No.
3 Q The only trust account you would have had was
4 the RRA trust account, right?
5 A I didn't have an RRA trust account.
6 Q The trust account that was in existence for
7 when you were with RRA would have been the RRA trust
8 account, right?
9 A I don't know, I was never --
10 Q Well --
11 A -- part of any trust account.
12 Q Well, if you received a check and it was
13 directed that you should put this into a trust account,
14 where would you put it?
15 A I didn't do any of those things. Here's what
16 happened. All of the law firms, it was myself, Bob
17 Josefsberg, Jack Scarola, and Sid Garcia, Ted Leopold,
18 I'm missing -- Adam Horowitz or Jeff Herman or somebody,
19 everybody agreed or forensic accountants.
20 Q Okay.
21 And sent checks to the firm. I never
22 Q To your firm?
23 A -- asked for the firm. To RRA.
24 Q Yeah.
25 A I never actually saw any of the checks, so the
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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,
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:
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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 â– 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 â– 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
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INDEX
WITNESS: Page
BRADLEY EDWARDS
Direct Examination cont'd by MR. HADDAD 114
EXHIBITS
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
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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
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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
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1 between yourself and either, what's his name, , or
2 Miss , whatever you want
3 to call her?
4 A That's my understanding.
5 Q All right. Well, this all came from your
6 files and from your records, correct, e-mails, whatever
7 you call those things where you store e-mail servers or
8 whatever there?
9 A You sent a request, I did whatever searches
10 that I could to come up with all of the documents
11 between us and I turned them over to my attorney who
12 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 --
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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
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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
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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.
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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 Q All right. There is a carbon copy to
9 and , correct?
10 A Okay.
11 Q Okay doesn't answer. Yes or no? I need
12 A That's what it appears to be.
13 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?
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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?
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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 --
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1 you know, I'm not that adept at the rules of civil
2 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 A Right.
7 Q But you can make a voluntary disclosure at
8 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
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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.
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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 --
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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
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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
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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
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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?
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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
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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.
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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.
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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
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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
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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
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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
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1 have your own separate Brad Edwards PA trust account?
2 A No. No.
3 Q The only trust account you would have had was
4 the RRA trust account, right?
5 A I didn't have an RRA trust account.
6 Q The trust account that was in existence for
7 when you were with RRA would have been the RRA trust
8 account, right?
9 A I don't know, I was never --
10 Q Well --
11 A -- part of any trust account.
12 Q Well, if you received a check and it was
13 directed that you should put this into a trust account,
14 where would you put it?
15 A I didn't do any of those things. Here's what
16 happened. All of the law firms, it was myself, Bob
17 Josefsberg, Jack Scarola, and Sid Garcia, Ted Leopold,
18 I'm missing -- Adam Horowitz or Jeff Herman or somebody,
19 everybody agreed or forensic accountants.
20 Q Okay.
21 And sent checks to the firm. I never
22 Q To your firm?
23 A -- asked for the firm. To RRA.
24 Q Yeah.
25 A I never actually saw any of the checks, so the
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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,