EFTA00611238.pdf

Page 148 Page 150 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL 1 e<INDEX START» CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 2 CASE NO. $02009CA040800XXXXMB AO 3 INDEX Complex Litigation, Fla.R.Civ.Pro. 1201 4 5 JEFFREY EPSTEIN, Plaintiff, 6 EXAMINATION DIRECT CROSS REDIRECT ors- VOLUME110F II 7 CONTINUED EXAMINATION OF BRADLEY J. EDWARDS, ESQUIRE SCOTT ROTHSTELN, 8 BRADLEY J. EDWARDS, BY MR. CRITTON 1S1 individually, and 124. individually, 9 10 Defendants. 11 12 VIDEOTAPED DEPOSITION OF BRADLEY J. EDWARDS, ESQUIRE 13 EXHIBITS 14 Tuesday, March 23, 20010 15 10:00 - 517 p.m 16 EXHIBIT DESCRIPTION PAGE 17 2139 Palm Bach Lakes. Boulevard PLAINTIFFS EX. I ALFREDO RODRIGUEZ 21I West Palm Beach, Florida 33401 18 CRIMINAL COMPLAINT PLAINTIFFS EX. 2 COMPLAINT 239 Reported By: 19 PLAINTIFFS EX. 3 JULY 22, 2009 276 Cynthia Hopkins, RPR, FPR PACSMILE Notary Public, State of Florida 20 Prose Court Reportmg 21 kb No.: 1333 22 23 24 25 Page 149 Page 151 . APPEARANCES: 1 PROCEEDINGS 2 0nd:halfoft& Ptaintilll ROBERT D. CRITTON. JR.. ESQUIRE 2 COLDAAN. LLP 3 THE VIDEOGRAPHER: We're now on the record 4 at 1:54 p.m Volume 2. S 5 CONTINUED DIRECT EXAMINATION 6 BY MR. CAPTION: and 7 Q. Mr. Edwards, when we broke, we were JACK ALAN GOLDBERGER ESQUIRE SS, P A. 8 talking a little bit about, we were talking about 9 9 George Rush and different, many people that you had 10 10 spoken with and you said you had spoken with 11 Mr. Rush approximately five times, correct? 11 12 and 12 A. Contd. 0 On behalfof the Plaine:I 13 Q. With regard to Mr. Rush, did you ever 14 ALAN M. DERSHOW1TZ. ESQUIRE HARVARD LAW SCHOOL. 14 provide him with any documents? 15 15 A. I don't believe so. 16 16 Q. Did you tell Mr. Rush, did you EVER advise 17 17 or did Mr. Rush ever ask you who your clients were, IS JACK SCAROLA. ESQUIRE SEARCY. DENNEY. SCAROIA. 18 I mean not by name but as to how your clients 19 MI Y 19 factored into any of the conversations that you were 10 20 having? 21 A. I don't remember that. 21 22 Q. Do you recall discussing with Mr. Rush 22 ALSO PRESENT: 23 Jcffivy Epstein 23 Ghislaine Maxwell? Or in fact, let me ask it this 24 Joseph Kcal, vsloormiss 24 way: Did you talk with Mr. Rush about Ghislaine Prose Reporting Saviors 15 25 Maxwell in any way? 1 (Pages 148 to 151) PROSE COURT REPORTING AGENCY, INC. Electronically signori by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d394112d.67f24170-9d82-0511f178c2eta EFTA00611238  Page 152 Page 154 1 A. I'm not sure. 1 A. I don't remember that subject coming up in the 2 Q. Why would you -- did any of your clients 2 conversations with Mr. Rush. Had he asked - I, i don't 3 claim or have any of your clients claimed to have 3 remember that conversation. 4 any contact with Ohislaine Maxwell at all? 4 Q. You're not denying it. You are just 5 A. That is something that certainly calls for 5 saying you don't remember it or are you — 6 attorney-client privilege and not something that I ant 6 A. Correct. 7 going to be answering today. 7 Q. - saying it didn't happen? Q. With regard to at least you have attended 8 A. No. I am saying I just don't remember. 9 the deposition of both Jane Doe and o' correct? 9 Q. Did you, did you tell Mr. Rush that 10 A. Yes. 10 Mr. Fruein had transported females on his plane for 11 Q. Okay. And have you heard them reference 11 the purposes of having sex with other individuals? 12 Ghislaine Maxwell during the course of those 12 A. I don't know. 13 depositions? 13 Q. Well, why -- 14 A. No. 14 A. I just don't remember. 15 Q. Would it be a correct statement that none 15 Q. If Mr. Rush would testify that you told 16 of the three of your clients — let's take a look at 16 him that other females had traveled on Mr. Epstein's 17 the two that have testified. Bakof the two that 17 plane and had had sex during the time they were on 18 have testified, Jane Doe and M. have testified 18 the planes„ why would you have had that discussion 19 that they did not ever take, travel with or were 19 with him? 20 transported in any ■ by Mr. Epstein, correct? 20 A. You're asking a hypothetical if i said that, 21 A. No, that is incorrect. 21 why would have i have said that? 22 Q. Okay. Did, who, which? 22 Q. Well, let me rephrase it this way: With 23 A. I believe. 23 Mr. Rush, if i asked you to assume that he would 24 Q. I am sorry? 24 testify that you, you told him about the 25 A. !guess the transcript will speak for itself. 25 transportation, that Mr. Epstein transported other Page 153 Page 155 1 1 don't remember their specific — 1 women on the plane to have sex with them, what 2 Q. is it your belief that Jane Doe ever 2 information did you have that was the basis for that 3 traveled with Mr. Epstein on his plane? 3 claim at that time? 4 MR. SCAROLA: Excuse me, is the question 4 MR. SCAROLA: I am going to object to the 5 limited to the testimony — 5 form of the question. It assumes facts not in 6 MR. CRITTON: Correct. 6 evidence. It has no proper predicate. 7 MR. SCAROLA: — that has been given? 7 BY MR. CRITTON: 8 MR. CRITTON: Correct. 8 Q. Mr. Edwards, did you have Ohislaine 9 THE WITNESS: No. I do not believe she 9 Maxwell served in this case with a subpoena? 10 testified that she traveled with Mr. Epstein on 10 A. Yes. 11 his plane. 11 Q. For what purpose? I mean, obviously to 12 BY MR. CRITTON: 12 take her deposition. 13 All right. And same would be true with 13 A. Exactly, to take her deposition. 14 IE., she did not testify that she traveled with Mr. 14 Q. All right. Do you, is she nei would 15 Epstein on his plane, true? 15 you agree that neither Jane Doe nor M. have 16 A. 1 believe that's true as well. 16 testified to any, that they had any connection 17 Q. Okay. Are you aware of any other 17 whatsoever with Ghislaine Maxwell? 18 infornAgga from any other source that either Jane 18 A. Yes, I would agree. 19 Doe or M. traveled on Mr. Epstein's plane? 19 Q. And what, what was, what is the purpose; 20 A. No. 20 that is, with regard to your three clients and only 21 Q. Did you, did you indicate to — well, let 21 your three clients is they — what connection if 22 me strike that. Did you tell Mr. Rush that none of 22 any, did Ghislaine Maxwell have to those 23 your clients had ever traveled with Mr. Epstein on 23 individuals? 24 his plane or any, on his plane or with him in any 24 MR. SCAROLA: Objection, work-product. 25 fashion, in any other manner? 25 Instruct you to not answer. zatetwe•am, avant-naV.eamtr•-•••••••....T.14.. 2 (Pages 152 to 155) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d-67f2-4170-9d82-0511,178c2ea EFTA00611239  Page 156 Page 158 1 BY MR. CR1TTON: 1 A. I didn't do that. 2 Q. \Vhen you originally started working with 2 Q. You didn't. Did you choose not to do 3 the Rothstein firm, did you have any discussions 3 that? 4 with Mr. Rothstein regarding how your cases would be 4 A. No. 1,1, the statement was made to me by 5 funded; that is, your personal, your personal injury 5 Scott Rothstein that the costs would be reimbursed. And 6 cases and specifically the cases relating to 6 I anticipated that the costs would be reimbursed. I was 7 Mr. Epstein? 7 there for a fairly short period of time and I didn't 8 A. No. 8 know Scott Rothstein personally. So, I didn't go to him 9 Q. Okay. With regard to, prior to taking 9 additionally to tell him something that we already had a 10 your cases to prior to starting at RRA, you were 10 meeting of the minds about. 11 responsible for the funding of your personal injury 11 Q. Well, how much in costs did you have 12 cases or any contingency fee case, correct? 12 outstanding at the time from your cases, including 13 A. Right. 13 the Epstein cases when you went to the firm RRA, in 14 Q. And I assume you had either your own 14 April of '09? 15 personal funds or you had a line of credit or both? 15 A. I don't know the total. 16 A. Right. 16 Q. Was it $1,000? Was it $50,000? Was it 17 Q. And when you came to RRA and you brought 17 $100,000? 18 the cases with you; that is, the personal injury 18 A. More than 100. 19 cases and as well, the Epstein cases, were you 19 Q. And did you have that both from, was it, 20 reimbursed for the costs that you had already 20 the debt, was that comprised of both your own money 21 expended thus far on those cases? 21 and as well as LOC, line of credit money through a 22 A. No. 22 bank? 23 Q. Did you request that you be reimbursed? 23 A. Correct. 24 A. Yes. 24 Q. Was it more than 150? 25 Q. And with, to whom was the request made? 25 A. I'm not sure. Page 157 Page 159 1 A. Directly to Scott Rothstein. 1 Q. Was it someplace between 100 and $200,000 2 Q. Was that at the ten minute meeting that 2 your best estimate? 3 you had? 3 A. That is my best estimate. 4 A. Yes. 4 Q. Did you find that to be a significant 5 Q. At BOVA? 5 amount of money? 6 A. Yes. 6 A. Of course. 7 Q. And what did he say? 7 Q. Okay. And you said you were at RRA for 8 A. No problem. 8 only a short period of time. In fact, you were 9 Q. He said he would reimburse you? 9 there April, May, June, July, August, September, 10 A. Correct. 10 October. You were there seven months, true? 11 Q. And did that, in fact, take place? 11 A. Yes. 12 A. No. 12 Q. Okay. And at no time, even though 13 Q. And how did you attempt to get reimbursed 13 Mr. Rothstein said he would reimburse those funds or 14 for the costs that you had thus far incurred on your 14 the finn would reimburse those funds to you, at no 15 personal injury cases including Mr. Epstein's case 15 time during those seven months which you have 16 when you went, when you started at RRA? 16 described as a short period of time, did you ever 17 A. What do you mean? 17 make a request that you be reimbursed; is that 18 Q. Well, you said that Mr. Rothstein agreed 18 correct? 19 in the ten minute conversation that RRA would 19 A. I never made a, well, I don't know the process 20 reimburse those costs? 20 for getting reimbursed, but I never made a formal 21 A. Correct. 21 request. I said it to, at least to Russell Adler on 22 Q. You go to RRA in April of '09, and I 22 several occasions. And it was always told to me, don't 23 assume you had to ask someone and say, look, Iliad a 23 worry about it; the firm is growing; there is a lot of 24 conversation with Scott Rothstein. He said he would 24 things to deal with right now; he operates under the 25 _ reimburse fr. costs. system of fairness; you will get reimbursed agassems.w 3 (Pages 156 to 159) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins 2d39412d47f2-4170-9082-0511ff76c2ea EFTA00611240  Page 160 Page 162 1 And obviously nobody expected the ending 1 A. Well, you've thrown a lot of things in there. 2 'to the law firm that ultimately occurred. 2 navel expenses come beck with your receipts, hand them 3 Q. With regard to the case, !assume you 3 over to, I would hand them over to my secretary. And 4 settled a couple of personal injury cases during the 4 she would get them to the appropriate place in the 5 seven months you were there, yes? 5 machine known as Rothstein Rosenfeldt Adler. And in my 6 A. Yes, you assume that. 6 next — and I would get a check, l believe. 7 Q. That's correct? Let me ask the question. 7 Q. All right. How about depositions, I mean 8 Did you settle any contingency fee cases during the 8 during the time that we, we took depositions from 9 sevens months that you were at the RRA firm? 9 the time you were at RRA, transcripts were ordered 10 A. Yes. 10 of depositions. They were expedited of various 11 Q. And when you settled those cases did you, 11 hearings. You took trips. You took a trip to New 12 and they closed, they were settled through, did you 12 York to take the deposition of Mark Epstein, 13 have any control of the trust account? 13 correct; all those things occurred? 14 A. No. 14 A. Yes, all of those things occurred. 15 Q. Okay. Settlement monies come in on a 15 Q. So, when you would get a bill in for the 1.6 personal injury case What did you do with the 16 trip for to go up and see Mark Epstein. or to take 17 money once the, once the client had endorsed the 17 Mark Epstein's deposition, you had travel costs 18 check? 18 associated with that and you had plane fare, 19 A. i, I didn't personally do anything with the 19 taxicab, hotel, whatever else you had, correct? 20 money. It was not handled by me. 20 A. I had costs associated with that 21 Q. Okay. Were you there- 21 Q. All right. And when you met with Mr. 22 A. That's why I'm confused. Did i settle the 22 Rothstein initially, what was your understanding or 23 case? I mean, Rothstein Rosenfeldt Adler firm settled 23 did you have an understanding as to how costs would 24 personal injury cases while I was there. There were no 24 be handled; that is, how they would be paid on cases 25 eases that were solely my cases. They were firm cases. 25 that you brought to the firm? Page 161 Page 163 1 Q. Let me rephrase the question. You 1 A. It was unspoken but I had some understanding 2 brought, you brought cases to the firm, correct? 2 just based on logic. 3 A. That is correct. 3 Q. Separate and apart from logic, did anybody 4 Q. Of any of the cases that you brought, did 4 tell you that you had; that is, that RRA would pay S you settle those cases? 5 all of the costs associated with prosecution of the 6 A. No. 6 Epstein cases? 7 Q. Okay. So, you never had an instance — so 7 A. Did anybody tell me? No. 8 there was never a set of circumstances where you 8 Q. Okay. Were you ever required to draw 9 would have been reimbursed for costs as a result of 9 against either your personal funds or your personal 10 a settlement? 10 LOC after you started with RRA to fund the Epstein 11 A. That's correct. 11 cases? 12 Q. All right. And, and so during the seven 12 A. I don't know how to answer your question, 13 months that you were there, you were never 13 Mr. Critton, because if I were to go out of town and 14 reimbursed a nickel of the one to $200,000 that you 14 purchase a plane ticket, yeah, I would purchase that 16 had outstanding in costs? 15 personally and then I would be reimbursed. If I ordered 16 A. That is correct. 16 a deposition transcript, which is a totally different 17 Q. All right. With regard to the costs that 17 category, that gets billed to the firm. I never see the 18 were to be incurred for prosecuting the cases, 18 bill or anything else. So, you're just throwing a bunch 19 specifically the Epstein coign what was your 19 of things together that don't necessarily go together. 20 understanding — was that ever discussed with 20 I am trying my best for you. 23. Mr. Rothstein at the ten-minute meeting? 21 Q. No, that's fine. Commonly in a personal 22 A. Repeat that. I'm sorry. 22 injury closing, you would see the recover, you would 23 Q. Sure. How were, how were costs 23 see a list of the costs. The costs would include 24 investigation costs, deposition costs, travel 24 court reporters, investigation fees, subpoenas, 25 expenses to be reimbursed? 25 things of that nature, correct? 4 (Pages 160 to 163) PROSE COURT REPORTING AGENCY, INC. Electronically signed by Cynthia hopkIns Electronically signed by cynthia hopidns Electronically signed by cynthia hopkins 2434412443724170441B241611M6ean EFTA00611241  Page 164 Page 166 1 A. I have seen them before, yes, sir. 1 responsibility to pay those bills. 2 Q. Okay. And as well there would be 2 Q. And is that what Russell Adler told you? 3 reimbursable expenses such as when you went to New 3 A. Yes. 4 York and took Mark Epstein's deposition. You, you 4 Q. Did you ever discuss that with anyone else 5 paid for the expense up front but, in fact, it was 5 in the firm or just Russell Adler? 6 then reimbursed by the firm, correct? 6 A. last Russell Adler. 7 A. Now we're specifically, specifically talking 7 Q. So, if the bill came in fix one of those 8 about Mark Epstein's deposition, yes, that, what you 8 types of costs, you would give to your secretary or 9 just said is correct. 9 would she handle it automatically? 10 Q. Okay. Not only was the, and if I 10 A. I never would see the bill. Why would it come 11 understand your testimony is the deposition was paid 11 into my name? It just didn't do — that never happened. 12 for directly by the firm. With regard to your 12 It was billed to Rothstein Rosenfeldt Adler. 13 travel, any hotel, other expenses that you had, you 13 Q. So, you would never see the bill that came 14 put in a request for reimbursement and the firm 14 in? 15 would reimburse you? 15 A. Correct. 16 A. Correct. 16 Q. — even if it was a RRA attention Brad 17 Q. All right And with regard to those 17 Edwards, you wouldn't see that? 18 costs, you said you and Mr. Rothstein never had a 18 A. Presuming that happened, attention, Brad 19 discussion about that; is that correct? 19 Edwards, I still never saw it. No, I never saw a bill 20 A. Correct 20 to my recollection right now the whole time I was at 21 Q. All right But you did speak with 21 Rothstein Rosenfeldt Adler. 22 Mr. Adler about how costs would be handled on your 22 Q. Did Mr. Rothstein ever discuss with you 23 cases including Mr. Epstein's case after you started 23 whether there would be a budget associated with how 24 with BRAT 24 much money you could spend on a particular case? 25 A. Correct. 25 A. No. Page 165 Page 167 1 Q. Okay. And is he the only one who 1 Q. Okay. Did anyone at the firm ever talk to 2 explained what the procedure was? 2 you about whether or not there would be a budget 3 A. Yes. 3 associated with how much you could spend on an 4 Q. And what did he tell you? Well, let me 4 Epstein case or any personal injury case? 5 ask you this: Did he tell you what; that is, that 5 A. No. 6 the firm would pay for all of the reimbursements 6 Q. In terms of authorization, if you wanted 7 either costs and/or reimbursements for costs that 7 to order a deposition expedited or if you wanted to 8 were incurred in prosecuting the Epstein files and 8 pay for a specific expense, whether it was an 9 any other files that you had? 9 outside investigator or to send an investigator to a 10 A. Can you split this question up so that we're 10 location, whose decision was that? Is that you and 11 not talking about reimbursement and costs and things 11 you alone to incur that cost? 12 like that 12 A. Which question do you want me to — you asked 13 Q. Sure. With regard to costs such as 13 a bunch of things there that some of them may have been 14 depositions .- 14 my decision. Other parts of that would obviously be 15 A. Okay. 15 somebody else's. But you're throwing five or six items 16 Q. — court reporters, court tcputter fees, 16 in there and you want me to give you an answer. 17 video depositions, transcripts of hearing, whether 17 Q. Let me break it them down. With regard to 18 they were expedited or whether they were asked on a 18 any costs that you wanted to incur, incur relating 19 routine basis? 19 to a Jeffrey Epstein matter, was there an 20 A. Right. 20 authorization process; that is, did you have to get 21 Q. Where would the — who was responsible for 21 someone's okay before you could spend X amount of 22 paying those bills? 22 dollars? 23 A. The bills would, to my to the best ofmy 23 A. No. 24 knowledge would be billed to the law firm of Rothstein 24 Q Okay. It was, and who told you that you 25 Rosenfeldt Adler, and it would be their financial 25 never had to get an approval for any expense 5 (Pages 164 to 167) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins Electronically signed by cynthia hopkins (601.051.976.2934) 2d39412d-6712-41704d82-05111176c2ea EFTA00611242  Page 168 Page 170 1 associated with the Jeffrey Epstein case? 1 Q. Did you meet, did you know Mr. Fisten 2 A. I didn't say that anybody did. So, no, 2 before you started working at RRA? 3 nobody, nobody. 3 A. Same answer, no. 4 Q. You could just spend whatever money you 4 Q. No. All right. And Mr. Fisten, did you 5 wanted to in prosecuting your cases; is that 5 direct Mr. Piston to do investigations in Martha's 6 correct? 6 Vineyard? 7 A. No, I didn't say that either. 7 A. No. 8 Q. What was the procedure then? 8 Q. Did you direct Mr. Eislen to do 9 A. That if I was at a deposition and there was a 9 investigations in California? 10 need in my judgment for the transcript to be expedited 10 A. I directed Mr. Fisten to interview people and 11 then i would order it expedited and nobody ever told me 11 ultimately it was learned that they lived in California. 12 that they had a problem with my judgment as to those 12 Q. And did Mr. Fisten go to California to 13 things. And not as to those things. As to that thing 13 interview those individuals? 14 which we were talking about which right now is 14 A. To the best of my knowledge he did. 15 expediting deposition transcripts. 15 Q. Okay. And who did he go and interview? 16 Q. With regard to — so any, how about an 16 MR. SCAROiA: That is work-product and I 17 expense associated with hiring, with either 17 instruct you not to answer. 18 directing -- well, let me strike that. With regard 18 BY MR. CRITIDN: 19 to Epstein, did, were you ever required or did you 19 Q. Did Mr. Fisten interview a person by the 20 ever hire outside investigators to do work 20 name of Michael Sanka (phonetic)? 21 associated with the Epstein case? 21 MR. SCAROLA: That is work-product and I 22 By outside i mean someone who was not an 22 instruct you not to answer. 23 employee of RRA and now i mean dealing with the time 23 MR. CRITTON: Did Mr. Fisten interview a 24 that you were at RRA 24 individual by the name of Michael Friedman 25 A. Right. And your question is did I over hire 25 (phonetic)? Page 169 Page 171 1 an outside investigator to perform work on Jeffrey 1 MR. SCAROLA: That is work-product and I 2 Epstein's case? 2 instruct you not to answer - 3 Q. Correct? 3 MR. CRITION: Mr. Fisten -- 4 A. The answer is no. 4 MR. SCAROLA: — except to the extent as 5 Q. Were, were all the investigations that 5 may have already been disclosed to the defense 6 were done during the time that you were employed by 6 in any of the three cases that are currently 7 RRA, were they done by in-house investigators? 7 pending. Any and all questions about 8 A. I don't know. 8 investigative work will meet with the same 9 Q. Well, if you wanted investigation done on 9 objection and same instruction. 10 Mr. Epstein, how would you go about authorizing that 10 BY MR. CRITTON: 11 or directing that that be done? 11 Q. Did you direct Mr. Fisten that he could 12 A. I would ask one of the investigators to do it. 12 represent that he was an agent of the FBI in 13 Q. So, you would direct the specific 13 interviewing individuals in California? 14 investigator? 14 A. Of course not 15 A. Yeah. There were plenty of times where I 15 Q. Did you — and if in fact Mr. Piston 16 directed the specific investigator. i want you to talk 16 represented he was an agent of the FBi, you would 17 to this witness or so-and-so, yes, just like you would 17 find that reprehensible, true? 18 in any case. 18 A. This is some hypothetical question that I do 19 Q. In this particular instance associated 19 not believe exists. 20 with Mr. Epstein, what investigators worked on 20 Q. I'm asking you to assume that Mr. Fisten 21 Mr. Epstein's case during the time you were at RRA? 21 represented that he was an agent of the FBI. You 22 A. If you want an exclusive list, I don't know. 22 would find that type of conduct by the investigator 23 Q. I want to know? 23 to be inappropriate, correct? 24 A. I can tell you Michael Fisten did because I 24 A. I'm not going to render an opinion on a 25 communicated with him directly. 25 hypothetical that doesn't exist 6 (Pages 168 to 171) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthia bodkins Electronically signed by cynthia bodkins Electronically signed by cynthia bodkins 2d39412d-6112-4170-9d82-0511ff76c2ea EFTA00611243  Page 172 Page 174 1 Q. So, you're refusing to answer that 3. Q. Could he -- is it your — 2 'question? 2 A. How would I know associate, he may have been? 3 A. You're asking me about my definition of 3 Q. Let me ask you this, was he employed by 4 reprehensible as it pertains to a specific hypothetical 4 the Miami-Dade Police Department in addition to RRA 3 5 that you've just created. 5 during the time he worked there? 6 Q. Let me ask you -- 6 A. To the best of my knowledge, no. 7 A. Now, you want me to try to analyze that 7 Q. Did -- with regard to Mr. Epstein's cases 8 particular hypothetical and tell you whether it meets 8 was there any type of cost account set up for, for 9 the definition of reprehensible? them? 10 Q. I will let you — if Mr. Fisten, if l ask 10 A. I don't know. 11 you to assume that Mr. Fisten represented to a 11 Q. Could you access any of the financial 12 witness out in California that he was an agent or 12 files within the RRA firm? 13 working for the FBI, would you find that conduct 13 A. No. 14 appropriate by Mr. Fisten? 14 Q. Could you access any files that were 15 MR. SCAROLA: And I will tell you that you 15 associated with your specific, excuse me, clients or 16 are not obliged to answer hypothetical 16 your specific case such as if you wanted to know how 17 questions. 17 much in costs had been incurred by Mr. Epstein -- on 18 THE WITNESS: And therefore I am not going 18 Jane Doe's case while at the RRA firm, could you 19 to answer that question. 19 request that, could you access that information? 20 BY MR. CRITTON: 20 A. I don't know. 21 Q. If Mr. Fisten represented that he was 21 Q. Did you ever try to rots that 22 associated with the Miami-Dade Police Department, 22 information? 23 Miami-Dade County Police Department, would you find 23 A. No. 24 that conduct inappropriate? 24 Q. At any time did you request that anybody 25 MR. SCAROLA: Same instruction and I would 25 provide you copies of what the costs were associatcd Page 173 Page 175 1 also observe with regard to each of the 1 with Mr. Epstein's cases? 2 hypothetical questions that you are asked that 2 A No. 3 they are incomplete. And without knowing all 3 Q. Since you left the firm have you requested 4 of the surrounding circumstances, it would be 4 any type of detailed billing or cost analysis such 5 impossible for any witness to pass judgment 5 as to the cost of any of the costs that were 6 upon what may have occurred. 6 incurred on any of Mr. Epstein's cases? 7 BY MR. CRITTON: 7 A. Of course. 8 Q. So, Mr.-- would it be a correct statement 8 Q. Okay. And did you receive those costs? 9 at least as you understood it, Mr. Edwards, that 9 Did you receive that information? 10 Mr. Fisten was not an agent, was not an FBI agent 10 A. Yes. 11 during the time that he worked for RRA? 11 Q. And what costs have been incurred in the 12 A. You're asking me was he an FBI agent or did he 12 cases, in the Epstein cases associated up — let me 13 work for RRA He worked for RRA 13 strike that. What costs, what is the total amount 14 Q. Correct. He was not an FBI agent, true, 14 of costs that were incurred in the Epstein cases 15 to the best of your knowledge during the time he 15 during the time that those files existed in the RRA 16 worked for RRA 16 firm? 17 A. Okay. 17 MR. SCAROLA: If you're able to answer 18 Q. I am not talking about any other time 18 that question with regard only as to amount 19 period right now. 19 without specifying any of the specific cost 20 A. Okay. Then the answer is he was not an FBI 20 expenditures, then I think we can answer that 21 agent at the time he was working for RRA 21 question only as to 8MOUnt. 22 Q. During the time he worked for RRA he as 22 THE WITNESS: And the question as to the 23 well was not associated with Miami-Dade Police 23 aggregate in the three cases? 24 Department, comet? 24 MR. CRITTON: Correct. 25 A. Oh, I don't know that. 25 THE WITNESS: Because I can't delineate 7 (Pages 172 to 175) PROSE COURT REPORTING AGENCY, INC. Electronically signed by cynthla hopkins Electronically signed by cynthia Napkins Electronically signed by cynthla hopkins 2d39412d-6712-4170-9•182-0511t176c2ea EFTA00611244  Page 176 Page 178 1 for you. 1 firm had you, you had spent some of your own money 2 MR. CRITTON: Your best estimate. 2 and/or LLC money on the files; is that correct? 3 THE WITNESS: Okay. I believe more than 3 A. That's comet. 4 $300,000. 4 Q. Approximately how much is that amount? 5 BY MR. CRITTON: A. Fin, I'm not sure. I think as you're aware 6 Q. With regard to, if investigation was done 6 most of the depositions and costly work that was done on 7 on, on a Epstein case, was the investigator charged, 7 the files happened to have been done during that time 8 that is for his time, as an example Mr. Fisten, if 8 period for all of the respective cases or claims against 9 he did work in California would his time, I'm not 9 Mr. Epstein during that time period of last summer of 10 talking about his expenses, would that be billed as 10 2009. 11 a cost to the file? 11 Q. All right. But in terms of your costs 12 A. I don't know. 12 prior to coming to RRA, what's your best estimate of 13 Q. On the cost that you received, well, let 13 the costs that you have paid either out of pocket or 14 me strike that. If I understood it, up to 300,000 14 are responsible to a bank to repay? 15 approximately $300,000 that's been spent on the 15 A. I don't know. 16 Epstein file, were you able to look -- 16 Q. More than 25,000, less than 25,000? 17 A. It would be more than that. I am just saying 17 A. I'm not sure. 18 it's at least $300,000. 18 More than 100,000? 19 Q. Something between three and $400,000, 19 A. No. 20 could it -- 20 Q. More than 50,000? 21 A. Something that I would say is definitely 21 A. I don't know. 22 between 300 and $500,000, but I'm not sure. It could be 22 Q. That's a record obviously you could pull 23 301. It could be 450. I really don't know. 23 up, correct? 24 Q. When was the last time that you looked at 24 A. Correct 25 that ledger or the printout associated with the 25 Q. All right. Now, with regard to, prior to Page 177 Page 179 1 Epstein files? 1 your coming to RRA, had there been any investigation 2 A. I have never looked at the printout. 2 work that you had done on the Epstein files -- and 3 Q. Okay. How, how do you know what is amount 3 let me strike that. Had you hired or retained an 4 is then? That is how do you have the estimate of it 4 investigator to do any work for you on the Epstein 5 being between 350, I'm sorry between 300 and 5 files prior to coming to RRA? 6 $500,000, the cost associated with Epstein? 6 A. I don't think so. 7 A. I asked a paralegal within my current fimi for 7 Q. All right. 8 the total amount of costs on these three cases that is 8 A. It would have been around that time. !don't 9 being claimed by Rothstein Rosenfeldt Adler. And I 9 remember whether the initial investigator was hired by 10 remember the cost number in the aggregate being given to 10 me from my previous, from my solo firm or was hired by 11 me reflecting an amount what I just told you. 11 Rothstein Rosenfeldt Adler. I can't say. 12 Q. Have you request