EFTA01102277.pdf
Epstein Deposition
Questions related to his lawsuit against L.M.
Page 13; Lines 11-21 — answered he was suing L.M. as part of the conspiracy with Rothstein and
Edwards creating fraudulent cases of a sexually charged nature in order to fleece unsuspecting
investors out of millions of dollars
Questions related to what Edwards did wrong that forms the basis of Epstein's suit against him
Page 23; Lines 4-19 — answered that Edwards had used the media to gin up these allegations and
engaged in discovery proceedings that bear no relationship to any case filed against Epstein by
ant of Edwards' clients. Rothstein firm, that Edwards was a part of, was accused of forging a
Federal Judge's name
Page 25; Lines 9-25 — answered Edwards personally engaged with Scott Rothstein and shared 13
boxes of information about Epstein with other attorneys at the firm. He alleged multi-million
dollars in damages to scam local investors. Accused of running a criminal enterprise]
Questions related to Edwards going to the media
Page 26; Lines 6-15 — answered that Edwards went to the Daily News in NY and other local
media and that Edwards' investigator went to California, representing that he was a FBI agent, to
harass people and gather information about Edwards' claims
Page 28; Lines 14-25 — answered the investigator going to California was part of Edwards' plan
to involve people who have nothing to do with the cases in order to go back to the media and gin
up his stories and make false accusations
Page 30; Lines 6-18 — answered Edwards created false stories to local media and press and made
false statements regarding false claims made by his clients so that he and Rothstein could
defraud local investors
Page 33; Lines 1-3 — answered Edwards alleged to the Daily News that third parties had already
been involved in allegations to do with sexual misconduct
Page 34; Lines 7-22 — answered "gin up" means crafted multi-million dollar numbers put on
cases to fleece investors and the allegations were made about Epstein
Questions related to discovery proceedings Edwards engaged in which form the basis of
Epstein's lawsuit
Page 36; Lines10-25 — answered Edwards participated in discovery proceedings of bringing
Epstein's attorneys to various different people that had nothing to do with any of Edwards'
clients or lawsuits; for example Edwards tried to depose Bill Clinton as a means of getting
EFTA01102277
publicity so that he and his firm could steal money from investors. Other various people include
people in California and New York
Questions related to the sharing of the 13 boxes of information as a basis of Epstein's lawsuit
Page 38; Lines 1-22 — answered Edwards shared the information with the partners in his firm and
investors. The boxes contained multiple cases that were fabricated to fleece investors out of their
money
Questions related to what Edwards did with regard to sending an investigator to California which
justifies a legal claim against Edwards
Page 48; Lines 13-25 — answered the use of illegal activities, wire taps, and methods by
Rothstein firm while Edwards had basically been bringing these cases and the investigator
represented himself as an FBI agent
Questions related to Epstein's knowledge about Edwards being involved in an illegal wire tap
Page 49; Lines 24-25; Page 50; Lines1-4 — answered that it has been widely reported in the
newspaper Edwards and his firm were involved in illegal wire taps, eavesdropping, and hiring
former FBI and law enforcement in order to fabricate cases
Page 50; Lines 8-25 — answered he has no personal knowledge of this, but it has been widely
reported, Mr. Sakowitz went to the FBI about it, and U.S. Attorney has accused the firm of RICO
Questions related to Epstein's personal knowledge that Edwards was involved in egregious civil
litigation abuse
Page 52; Lines10-17 — answered it is widely reported in newspaper that Edwards' firm engaged
in wild discovery processes, illegal activities, and illegal eavesdropping to defraud investors
Questions related to the "hardworking and honest lawyers" Edwards wants to vindicate
referenced in the complaint
Page 59; Lines 11-25 — answered he wants to vindicate his attorneys, himself, and other clients
abused by Edwards and the Rothstein firm
Questions related to Rothstein and Edwards being a part of a criminal enterprise
Page 63; Lines 4-25 — answered what he meant in his complaint was that the Rothstein firm and
Edwards were part of a criminal enterprise, the largest in South Florida and part of the lawsuit
should vindicate, set right. Part of the lawsuit will disclose the various techniques of
attorney/client privilege, abuse of discovery, illegal wire taps, forging signatures engaged in by
Edwards and his firm
EFTA01102278
uestion- Have you ever socialized with Tommy Mottola?
Page 90; Lines 10-15 — answered this type of question shows where people have nothing to do
with the case have been brought in by Edwards in an attempt to simply imperil Epstein's
relationship with social friends and serves as an example of why this case has been brought
against Edwards and his firm
Questions related to damages Epstein claims to have suffered as a consequence of any
wrongdoing on the part of Edwards
Page 116; Lines 8-15 — answered the cost of ridiculous litigation, the cost of having attorneys
prepare responses to wildly irrelevant discovery in various locations at a minimum
Page 120; Lines 16-24 — answered apart from money paid to lawyers, the stress and emotional
damage of imperiling Epstein's friendships and business relationships with no relevance
whatsoever to these cases, brought by the firm to harass Epstein's friends and social contacts to
fleece investors out of millions of dollars
Page 126; Lines 1-5 — answered as proportionate to the amount of damages, Epstein believes
Edwards played a vital role. Epstein believes his partners potentially played a role
EFTA01102279
Questions related to his lawsuit against L.M.
Page 13; Lines 11-21 — answered he was suing L.M. as part of the conspiracy with Rothstein and
Edwards creating fraudulent cases of a sexually charged nature in order to fleece unsuspecting
investors out of millions of dollars
Questions related to what Edwards did wrong that forms the basis of Epstein's suit against him
Page 23; Lines 4-19 — answered that Edwards had used the media to gin up these allegations and
engaged in discovery proceedings that bear no relationship to any case filed against Epstein by
ant of Edwards' clients. Rothstein firm, that Edwards was a part of, was accused of forging a
Federal Judge's name
Page 25; Lines 9-25 — answered Edwards personally engaged with Scott Rothstein and shared 13
boxes of information about Epstein with other attorneys at the firm. He alleged multi-million
dollars in damages to scam local investors. Accused of running a criminal enterprise]
Questions related to Edwards going to the media
Page 26; Lines 6-15 — answered that Edwards went to the Daily News in NY and other local
media and that Edwards' investigator went to California, representing that he was a FBI agent, to
harass people and gather information about Edwards' claims
Page 28; Lines 14-25 — answered the investigator going to California was part of Edwards' plan
to involve people who have nothing to do with the cases in order to go back to the media and gin
up his stories and make false accusations
Page 30; Lines 6-18 — answered Edwards created false stories to local media and press and made
false statements regarding false claims made by his clients so that he and Rothstein could
defraud local investors
Page 33; Lines 1-3 — answered Edwards alleged to the Daily News that third parties had already
been involved in allegations to do with sexual misconduct
Page 34; Lines 7-22 — answered "gin up" means crafted multi-million dollar numbers put on
cases to fleece investors and the allegations were made about Epstein
Questions related to discovery proceedings Edwards engaged in which form the basis of
Epstein's lawsuit
Page 36; Lines10-25 — answered Edwards participated in discovery proceedings of bringing
Epstein's attorneys to various different people that had nothing to do with any of Edwards'
clients or lawsuits; for example Edwards tried to depose Bill Clinton as a means of getting
EFTA01102277
publicity so that he and his firm could steal money from investors. Other various people include
people in California and New York
Questions related to the sharing of the 13 boxes of information as a basis of Epstein's lawsuit
Page 38; Lines 1-22 — answered Edwards shared the information with the partners in his firm and
investors. The boxes contained multiple cases that were fabricated to fleece investors out of their
money
Questions related to what Edwards did with regard to sending an investigator to California which
justifies a legal claim against Edwards
Page 48; Lines 13-25 — answered the use of illegal activities, wire taps, and methods by
Rothstein firm while Edwards had basically been bringing these cases and the investigator
represented himself as an FBI agent
Questions related to Epstein's knowledge about Edwards being involved in an illegal wire tap
Page 49; Lines 24-25; Page 50; Lines1-4 — answered that it has been widely reported in the
newspaper Edwards and his firm were involved in illegal wire taps, eavesdropping, and hiring
former FBI and law enforcement in order to fabricate cases
Page 50; Lines 8-25 — answered he has no personal knowledge of this, but it has been widely
reported, Mr. Sakowitz went to the FBI about it, and U.S. Attorney has accused the firm of RICO
Questions related to Epstein's personal knowledge that Edwards was involved in egregious civil
litigation abuse
Page 52; Lines10-17 — answered it is widely reported in newspaper that Edwards' firm engaged
in wild discovery processes, illegal activities, and illegal eavesdropping to defraud investors
Questions related to the "hardworking and honest lawyers" Edwards wants to vindicate
referenced in the complaint
Page 59; Lines 11-25 — answered he wants to vindicate his attorneys, himself, and other clients
abused by Edwards and the Rothstein firm
Questions related to Rothstein and Edwards being a part of a criminal enterprise
Page 63; Lines 4-25 — answered what he meant in his complaint was that the Rothstein firm and
Edwards were part of a criminal enterprise, the largest in South Florida and part of the lawsuit
should vindicate, set right. Part of the lawsuit will disclose the various techniques of
attorney/client privilege, abuse of discovery, illegal wire taps, forging signatures engaged in by
Edwards and his firm
EFTA01102278
uestion- Have you ever socialized with Tommy Mottola?
Page 90; Lines 10-15 — answered this type of question shows where people have nothing to do
with the case have been brought in by Edwards in an attempt to simply imperil Epstein's
relationship with social friends and serves as an example of why this case has been brought
against Edwards and his firm
Questions related to damages Epstein claims to have suffered as a consequence of any
wrongdoing on the part of Edwards
Page 116; Lines 8-15 — answered the cost of ridiculous litigation, the cost of having attorneys
prepare responses to wildly irrelevant discovery in various locations at a minimum
Page 120; Lines 16-24 — answered apart from money paid to lawyers, the stress and emotional
damage of imperiling Epstein's friendships and business relationships with no relevance
whatsoever to these cases, brought by the firm to harass Epstein's friends and social contacts to
fleece investors out of millions of dollars
Page 126; Lines 1-5 — answered as proportionate to the amount of damages, Epstein believes
Edwards played a vital role. Epstein believes his partners potentially played a role
EFTA01102279