EFTA00599662.pdf

Page 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50 2009CA040800XXXXMB AG Complex Litigation, Fla.R.Civ.Pro. 1201 JEFFREY EPSTEIN, Plaintiff, -vs- VOLUME I OF II SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and III. individually, Defendants. VIDEOTAPED DEPOSITION OF BRADLEY J. EDWARDS, ESQUIRE Tuesday, March 23, 20010 10:00 - 5:07 p.m. 2139 Palm Beach Lakes, Boulevard West Palm Beach, Florida 33401 Reported By: Cynthia Hopkins, RPR, FPR Notary Public, State of Florida Prose Court Reporting Job No.: 1333 PROSE COURT REPORTING AGENCY, INC. EFTA00599662  Page 2 1 APPEARANCES: 2 On behalf of the Plaintiff: 3 ROBERT D. CRITTON, JR., ESQUIRE BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 4 Boulevard West Palm Beach, Florida 334O1 Phone: 7 and JACK ALAN GOLDBERGER, ESQUIRE ATTERBURY, GOLDBERGER & WEISS, P.A. 10 West Palm Beach, Florida 33401-5012 Phone: 11 12 and 13 On behalf of the Plaintiff: 14 ALAN M. DERSHOWITZ, ESQUIRE HARVARD LAW SCHOOL 15 Cambridge, Massachusetts 02138 16 Phone: 17 On behalf of the Defendant: 18 JACK SCAROLA, ESQUIRE SEARCY, DENNEY, SCAROLA, 19 BARNHART & SHIPLEY, P.A. 20 West Palm Beach, F on a Phone: 21 22 ALSO PRESENT: 23 Jeffrey Epstein 24 Joseph Kozak, Videographer Prose Reporting Services 25 PROSE COURT REPORTING AGENCY, INC. EFTA00599663  Page 3 1 2 INDEX 3 _ _ 4 5 EXAMINATION DIRECT CROSS REDIRECT 6 BRADLEY J. EDWARDS, ESQUIRE 7 BY MR. CRITTON 5 8 9 10 11 EXHIBITS 12 13 14 EXHIBIT DESCRIPTION PAGE 15 PLAINTIFF'S EX. 1 ALFREDO RODRIGUEZ 211 16 CRIMINAL COMPLAINT PLAINTIFF'S EX. 2 COMPLAINT 239 17 PLAINTIFF'S EX. 3 JULY 22, 2009 276 FACSMILE 18 19 20 21 22 23 24 25 PROSE COURT REPORTING AGENCY, INC. EFTA00599664  Page 4 PROCEEDINGS 2 Deposition taken before Cynthia Hopkins, 4 Registered Professional Reporter and Florida 5 Professional Reporter, and Notary Public in and for 6 the State of Florida at Large, in the above cause. 7 8 THE VIDEOGRAPHER: We are now on video 9 record. This is Media Number One in the 10 videotaped deposition of Bradley Edwards in the 11 matter of Jeffrey Epstein versus Scott 12 Rothstein, Bradley J. Edwards, and 13 Today is Tuesday, March 23rd, 2010 at 14 10:00 a.m. We're here in the law offices 15 of Searcy, Denney, Scarola, Barnhart & 16 Shipley, 17 West Palm Beach, Florida. 18 My name is Joe Kozak. I am the 19 videographer. The court reporter is Cindy 20 Hopkins from Prose, Prose Court Reporting 21 Agency. 22 Will counsel please introduce 23 yourselves, and then the court reporter 24 will swear in the witnesses. 25 MR. CRITTON: Bob Critton on behalf of the PROSE COURT REPORTING AGENCY, INC. EFTA00599665  Page 5 Plaintiff, Jeffrey Epstein. MR. GOLDBERG: Jack Goldberger on behalf of the Plaintiff, Jeffrey Epstein. 4 MR. DERSHOWITZ: Alan Dershowitz on behalf 5 of the Plaintiff, Jeffrey Epstein, of counsel. 6 MR. SCAROLA: The record should reflect that Mr. Epstein is also personally present. 8 My name is Jack Scarola. X am counsel on ° behalf of the Defendant/Counter-Plaintiff, Brad 10 Edwards. 11 Thereupon, 1.2 (BRADLEY J. EDWARDS, ESQUIRE) 1.3 having been first duly sworn or affirmed, was 14 examined and testified as follows: 15 THE WITNESS: Yes. 16 DIRECT EXAMINATION 17 BY MR. CRITTON: 1.8 Q. Would you please tell us your full name 19 and home your home address. 20 A. Bradley James Edwards, 21 22 Q. Date of birth, please. A. )4 Q. Mr. Edwards, have you ever had your 25 deposition taken before? PROSE COURT REPORTING AGENCY, INC. EFTA00599666  Page 6 A. No. 2 Q. Okay. But you've counseled, you've 3 obviously taken a number of depositions both as a 4 Plaintiff and as a Defendant. You're familiar with 5 all the rules? 6 A. I know the rules. 7 Q. All right. Again if I ask you a question 8 you don't understand, if you would ask me or if you 9 want me to rephrase it, I will be happy to do that. 10 A. Yes. 1 MR. SCAROLA: Mr. Edwards, Mr. Edwards, knows the rules. You can skip the preliminaries. 14 MR. CRITTON: Is that a form objection? 15 MR. SCAROLA: No. 16 MR. CRITTON: Just a talk. 17 MR. SCAROLA: It's a, it's a request that 18 you not waste our time. 19 MR. CRITTON: I am not wasting your time. 20 And if we hadn't gone through that, we would 21 have been done with them, Jack. 22 BY MR. CRITTON: 23 Q. Mr. Edwards, are you currently employed? 24 A. Yes. 25 Q. And by whom are you currently employed? PROSE COURT REPORTING AGENCY, INC. EFTA00599667  Page 7 A. I don't understand the question. Q. For whom do you work at the current time? Are you an employee? A. I am a partner in the law firm of Farmer, 5 Jaffe, Weissing, Edwards, Fistos & Lehrman. 6 Q. Is that a professional association? 7 A. Yes. 8 Q. And you said you're a partner. Do you 9 have your own P.A. or is the only the Farmer -- what i0 was the second name, Jaffe? 11 A. Correct. '2 Q. And I will refer to it as Farmer, Jaffe, 13 if that's all right with you. Is Farmer, Jaffe itself a P.A.; that is, are you a partnership of P.A.'s? A. Yes. Q. Do you have your own professional It; association? 19 A. Yes. 20 Q. Okay. What's it called? 21 A. Law Office of Brad Edwards, LLC. 22 Q. You are the sole member of that LLC? 23 A. Yes. 24 Q. And then your LLC is a partner of the 25 Farmer, Jaffe firm? PROSE COURT REPORTING AGENCY, INC. EFTA00599668  Page 8 1 A. Correct. 2 Q. And do you hold yourself out to the public 3 as being a partner of that firm; that is you 4 individually? 5 A. What do you mean by hold myself out to the 6 public? 7 Q. If I got your letter would your letter 8 say, if I received a letter from you would it say 9 Brad Edwards, partner, or something to that effect? 10 A. I don't think so. 11 Q. Okay. What does your card say? Do you 12 have a business card? 13 A. I do. 14 Q. Okay. What does your business card-- lb A. Attorney. 16 Q. -- reflect? And when you introduce 17 yourself to clients or other attorneys for the first 18 occasion, do you introduce yourself as a partner of 19 that firm if asked? 20 A. If asked are you a partner; is that your 21 question? 22 Q. Correct. 23 A. Would I say yes? The answer is yes. 24 Q. When did you start -- I want to strike 25 that. Do you consider yourself an employee of the PROSE COURT REPORTING AGENCY, INC. EFTA00599669  Page 9 1 partnership? 2 A. What do you mean by that? 3 Q. Do you understand what an employee is? 4 A. I work for the firm. 5 Q. You are certainly not -- 6 A. I am employed there, so, yes. 7 Q. When did you start your association with 8 the Farmer, Jaffe firm? 9 A. Sometime during the month of November, 2009. 10 Q. And is that when the firm was incorporated 11 as a professional association? 12 A. I believe so. 13 Q. The attorneys who are in the current firm, 14 are they all former Rothstein Rosenfeldt Adler 15 attorneys; that is, the professional staff? 16 A. Yes. 17 Q. Is there anyone -- Let me strike that. 18 Do you have paralegals as well that 19 work there? 20 A. Yes. 21 Q. Are any of the paralegals former, and if I 22 refer to Rothstein Rosenfeldt Adler as RRA, or RRA, 23 is that all right with you? 24 A. I understand what you mean. 25 Q. Are there any other, are any of the PROSE COURT REPORTING AGENCY, INC. EFTA00599670  Page 10 1 paralegals that are currently employed by Farmer, 2 Jaffe in any capacity whether they are independent 3 contractors -- well, let me strike that. 4 As employee's, I probably should ask this question: Does the firm, Farmer, Jaffe have 6 employees 7 A. Yes. 8 Q. -- separate and apart from the partners? A. Yes. 0 Q. And they are actually employed by the P.A., correct? I> A. Correct. 13 Q. Does the firm have any paralegals that 14 came over from the RRA firm, RRA? 15 A. Yes. 16 Q. Who are they? 11 A. Maria and Beth. 18 Q. Does Maria have a last name? 19 A. Yes. 20 Q. What is it, please? 21. A. I believe it's pronounced Kelljian. 22 Q. Can you spell it? 23 A. I can give it my best shot, K-E-L-L-J-I-A-N. 24 Q. And Beth's last name is what, please? 25 A. Williamson. PROSE COURT REPORTING AGENCY, INC. EFTA00599671  Page 11 Q. She's your current secretary/paralegal, or 2 do you have a secretary as well? 3 A. I don't understand your question. 4 Q. Do you have -- is Beth Williamson your 5 paralegal? 6 A. She's a paralegal at the law firm of Farmer, 7 Jaffe, Weissing, Edwards, Fistos & Lehrman. 8 Q. Does she primarily work for you? 9 A. No. 10 Q. Do you have a secretary as well? 11 A. The law firm? Yes. 12 Q. The secretary who works primarily for 13 you -- 14 A. No. 15 Q. You just use whoever is available from a 16 secretary standpoint? 17 A. No. 18 Q. Who do you primarily use for secretary 19 services? 20 A. There is nobody who could fall into the 21 category of who I primarily use. 22 Q. Ms. Williamson, who, by whom, who, who was 23 the attorney at RRA with whom she primarily worked? 24 A. I believe it was several attorneys, and I 25 can't tell you who the attorneys were that she worked PROSE COURT REPORTING AGENCY, INC. EFTA00599672  Page 12 for or with. 2 Q. Did she work with you at all at RRA? A. In some limited capacity, maybe. 4 Q. Did she ever work on any of the -- you 5 have three cases that you ever filed -- or let me 6 strike that. 7 There are three cases that are in 8 existence at the current time. One is Jane Doe 9 versus Mr. Epstein which is, is a federal court case 10 and the Plaintiff's name is Jane Doe. That is one 11 of your cases, correct? 12 A. Correct. 13 Q. Or one of the firm's cases at the current 14 time? 15 A. Correct. 16 Q. There is another case versus . Versus 17 Jeffrey Epstein and a third called III. versus 18 Jeffrey Epstein, correct? 19 A. Yes. 20 Q. And as a result all three of those cases 21 currently now are firm cases, the Farmer, Jaffe firm 22 cases? A. Yes. 24 Q. Did Mrs. Williamson work on any of those cases? PROSE COURT REPORTING AGENCY, INC. EFTA00599673  Page 13 1 A. In what time period? What's your question? 2 Q. I'm sorry. During the time that you were 3 associated with RRA, did Mrs. Williamson work on 4 those cases? 5 A. Without you needing to ask 20 different 6 questions to get to your answer, I will tell you her 7 involvement was that after federal motions were drafted, 8 she was the person to literally file the motion. That 9 is her only involvement with the cases while at RRA 10 Q. She basically filed them through the Pacer 11 system? 12 A. Exactly. 13 Q. Prior to you working at Farmer, Jaffe by 14 whom were you employed? And by employed I mean in, 15 in a broad sense. You could have been an 16 independent contractor. You could have been a 17 partner. You could have been an employee. 18 A. The law firm of Rothstein Rosenfeldt Adler. 19 Q. When did you start working for RRA? 20 A. I believe April of 2009. 21 Q. Beginning of April? 22 A. Yes. 23 Q. I saw a pleading that was filed yesterday 24 and it was either ., I am sorry, . or 25 that looked like there was a change of -- I'm sorry, PROSE COURT REPORTING AGENCY, INC. EFTA00599674  Page 14 1 notice of appearance or something by RRA Would 2 that, in any way, if I asked you to assume that 3 that's correct, would that refresh your recollection that it may have been at the end of March? A. I don't understand that question at all. 6 Q. I saw a pleading that was filed or -- 7 A. Yesterday you said. 8 Q. -- a paper that was filed. I was looking 9 at a pleading filed in either III. or III., and I 10 saw a paper that was basically a notice of 11 appearance on behalf of RRA And it looked like it 12 was dated around March 30 of 2009. 13 A. Okay. 14 Q. Is it possible that you started your 15 association with RRA at an earlier date than April 16 of '09? 17 A. Assuming that what you said is true, if that 18 document says that, then it's possible that is an 19 accurate reflection of when I began. 20 Q. Did you start working with RRA before you 21 filed any documents representing that RRA or that 22 you had now an affiliation with RRA? A. No. 24 Q. Where the -- again, I don't remember, F. whether there was a notice of additional counsel or PROSE COURT REPORTING AGENCY, INC. EFTA00599675  Page 1 1 substitution of counsel. Did you, were the 2 substitution of counsel's filed the exact date that 3 you started with RRA? 4 A. I don't remember. Q. When did your association with RRA 6 terminate or end? 7 A. The end of October 2009 or the beginning of 8 November 2009. 9 Q. And how did it terminate? How did your it relationship with RRA terminate? A. The firm closed. i2 Q. Did you get, notification -- when you say 13 closed, meaning what? 14 A. Meaning what everybody in this entire room 15 knows is that the firm went from operating to no longer 16 operating. 1/ Q. And how did you receive notice; that is, 18 did you receive some sort of notice that told you 10 that RRA now is a defunct firm? Did you receive 20 notification that was in bankruptcy? What, if 2i anything, did you receive? 22 A. I didn't receive anything. 23 Q. And then how did your relationship with 24 RRA end? 25 A. Came to work on a Monday morning, and there PROSE COURT REPORTING AGENCY, INC. EFTA00599676  Page 16 1 was a meeting that was held informing all the employees including myself that the firm no longer was financially 3 able to survive and therefore would be immediately 4 closing down. 5 Q. Who was the spokesperson at the meeting, 6 the main individual who advised those assembled in 7 the room that that's what was going to occur? 8 A. I don't remember. 9 Q. Was it -- did Rosenfeldt speak at all at 10 that meeting? 11 A. I, I can't remember. 1.2 Q. Do you remember the date of the meeting? 13 A. I remember that it was a Monday. 14 Q. Do you remember it being in October or November? 16 A. Either the very end of October or the very t7 beginning of November. is Q. Did anyone -- well, let me strike that. I9 Do you remember whether the person -- let me strike 20 that. 21 At the meeting who was present, and I 22 don't mean individual names. Who did it, by groups, 23 who did it include? 24 A. The meeting was held in a cafeteria type room 25 in the building where RRA maintained its offices. And PROSE COURT REPORTING AGENCY, INC. EFTA00599677  Page 17 the room was completely full to capacity with as many '1 employees of the Rothstein, Rosenfeldt Adler firm as were in attendance at work that day. 4 Q. And included lawyers, paralegals, support 5 staff, investigators? 6 A. Literally -- 7 Q. -- everyone, I mean everyone who obviously 8 showed up at the meeting? 9 A. I don't know. 10 Q. Did you see other lawyers there? 11 A. Yes. 1.2 Q. Did you see staff there? 13 A. Yes. 14 Q. Did you see paralegals there? 15 A. Yes. 16 Q. Did you see investigators there? 17 A. I can't necessarily remember whether or not I 18 saw investor -- investigators there. 19 Q. And did more than one person speak at the 20 meeting? 21 A. I don't remember. 22 Q. Okay. What else were you advised at the 23 meeting, if anything? 24 A. It was -- I stayed for very little of that 25 meeting. I don't know what was advised to others, but PROSE COURT REPORTING AGENCY, INC. EFTA00599678  Page 18 1 what I heard was, firm is closing down. That's all I needed to hear and I left. 3 Q. Did you subsequent -- well, let me strike that. Did you, were you able to gain, gain access to the building that day? I am sorry, access to your, to the offices of the Rothstein firm that day? A. Yes. Q. And were you able to access any of your files or your e-mail at that time? o A. What time? Q. That same day, that Monday that you were advised that the firm was shutting down. 13 A. Yes. 14 Q. And were you able to print documents? 15 Well, let me strike that. Were you able to take 16 documents relating to matters on which you worked 17 from the firm? 18 A. What do you mean by was I able to? 19 Q. Were you able to access and take with you 20 documents that related to files on which you were 21 working the preceding Friday when you were at RRA? 22 A. I believe so. 23 Q. Did you take, did you actually remove 24 documents, papers that were related to files that 25 you had on which you were working from RRA that day? PROSE COURT REPORTING AGENCY, INC. EFTA00599679  Pncin 1 A. I don't believe so. 2 Q. Okay. Was anyone preventing you from 3 taking anything? 4 A. No. 5 Q. Okay. Did you print out any documentation 6 from your server or from the firm's server that day 7 to take with you? 8 A. Not that I recall. 9 Q. Do you recall taking anything from 10 RRA'office that day, that day being that same 11 Monday? 12 A. No. 13 Q. Obviously Scott Rothstein was not there? A. Correct. Q. Have you ever spoken, excuse me, have you ever seen Mr. Rothstein since that Monday at the meeting? A. What do you mean have I seen him? Q. Seen him in person, I'm sorry. 20 A. No. 21 Q. Okay, have you spoken with him at any time 22 since the Monday meeting at which time you were 23 advised that the firm was shutting down? 24 A. No. 25 Q. Have you spoken on any, with anyone on his PROSE COURT REPORTING AGENCY, INC. EFTA00599680  Page 20 1 behalf; that is, who purports to represent 2 Mr. Rothstein since you left the firm that day? 3 A. No. 4 Q. Do you know Mr. Nurik? 5 A. Yes. 6 Q. Do you recog -- are you aware that he 7 represents Mr. Rothstein? A. Yes. 9 Q. Okay. Have you spoken with him since that 10 Monday? 11 A. He called me on a morning before a hearing to 12 ask me where Judge Crow's courtroom was. And I told J3 him, and that was the extent of that conversation. 4 Otherwise, I have had zero communication with Marc Nurik. I6 Q. With regard to the firm being advised that 17 the firm was shutting down on that Monday, did you 18 subsequently return to the firm's offices? Let me 79 strike that. How long did you stay at the firm that 20 day? 21 A. I don't remember. 22 Q. Did you stay all day? 23 A. I believe so. 24 Q. Were you able to work on your files? 25 A. I don't understand the question. PROSE COURT REPORTING AGENCY, INC. EFTA00599681  Page 21 Q. Were you able to do legal work on the matters that wherein you represent individuals? A. Was I able to? Yes, I was physically able to do that. 5 Q. Did you work on legal matters that day? 6 A. No. Q. Did you subsequently, after that date, did you return to the RRA offices? 9 A. Yes. 10 Q. And where are those offices or where were 11 those offices located? A. 3 Q. The address, please? 14 A. I don't remember. 15 Q. With regard to the -- 16 A. 17 Q. 18 A. (Witness nods head.) 19 Q. Did you, did you after that Monday did you 20 return to the offices at the RRA 21 offices? 22 A. Yes. 23 Q. And did you return every day thereafter 24 for a period of time? 25 A. No. PROSE COURT REPORTING AGENCY, INC. EFTA00599682  Page 22 Q. Was there a point in time that you were 2 prevented from entering your office or the offices of RRA? A. Yes. Q. At what point in time were you prevented from going into the offices? A. I don't remember. 8 Q. How many days were you able to access the 9 offices before you were prevented? 10 A. I don't remember. 11 Q. You don't know whether it was a day or 12 three days or five days that you were allowed to go 13 into the office? 14 A. The period of time that I was able to go into 15 the office encompasses all of those things that you just 16 said, one day, three days, five days, yes. I can 17 definitely say with certainty I was able to do that. 18 Q. During the month of October were you 19 allowed to go into the office more than ten days? 20 A. Yes. 21 Q. Did they put -- well, let me strike that 22 Did someone put restrictions on what your access was 2, to the office, the RRA office? 24 A. Yes. Q. Okay. Who put the restrictions on the PROSE COURT REPORTING AGENCY, INC. EFTA00599683  Page 23 1 entry to the office? 2 A. I don't know. 3 Q. Well, who would, who would monitor whether 4 you came in or couldn't go into the office? 5 A. I don't know. 6 Q. Was there someone there? 7 A. Was there someone where? 8 Q. The impression I got is that there was 9 some limitation on your ability to access the RRA 10 offices after the Monday at which time you were 1.1 advised that the firm was shutting down. Did I 12 misunderstand you? 1.3 A. No, that's correct. 14 Q. Okay. Who then, if you know, or what, if 15 it was an entity, placed any restrictions on your 16 access to RRA offices? 17 A. I don't know. 18 Q. When you would go to the office well, 19 let me strike that. After how many days -- well, 20 let me strike that. 21 The very day, the same day that you 22 were advised that the office was closing down, were >3 there any individuals that were monitoring what, if 24 anything, was to be removed or not removed from the )f office, like a security force, Broward County PROSE COURT REPORTING AGENCY, INC. EFTA00599684  Page 24 1 Police, U.S. Marshals. A. From my recollection there were at some point 3 in time, there were people in the office monitoring 4 activity in the office. 5 Q. Was that the first week after the Monday? 6 A. I don't recall. 7 Q. Did you ever, did you receive any guidelines either at the Monday meeting or thereafter as to what you could or could not remove 10 from the file, from the, I'm sorry from the RRA 11 offices? 12 A. I believe so. 13 Q. And who put those guidelines out, do you 1.4 recall? 15 A. No. 16 Q. Were they in a written form? 17 A. No. 18 Q. Okay. Was given in what form, how did you 19 learn what you could and could not take from the 20 office? 21 A. More rumor than anything else is what I 22 remember. 23 Q. Did you discuss that with other 24 individuals or other attorneys who were working at 25 RRA? PROSE COURT REPORTING AGENCY, INC. EFTA00599685  Page 25 1 A. Possibly. 2 Q. Did you ever attempt to remove something 3 from the office of the RRA offices and someone prevented you? A. No. Q. Did you ever and when I say remove I mean in the sense of physically remove; that is, take out boxes or take out files or something of that nature. 10 A. I understand the definition of remove. 11 Q. With regard to, there were also, I 12 understand you had an e-mail server at the office? 13 A. Okay. 14 Q. Is that correct? 15 A. Yes. 16 Q. And I have seen something, there is 1% something that's called Qtask. Are you familiar 18 with Qtask? 19 A. Yes. 20 Q. And what do you understand Qtask or what 21 did you understand that Qtask did; that is, as an 22 electronic service? 23 A. A web based network to store files and other 24 materials. 25 Q. In terms of electronic storage, or ari PROSE COURT REPORTING AGENCY, INC. EFTA00599686  Page 26 electronic data at the RRA firm, in addition to, 2 excuse me, the e-mail server was and Qtask, was 3 there anything else from an electronic storage or 4 communication means through RRA? 5 A. Yes. 6 Q. What else was there? 7 A. That stored electronic materials? 8 Q. Right, or that you could communicate with 9 someone else either inside or out of the firm. You 10 had the server, e-mail server. You had Qtask. What else did you have? 12 A. To communicate with others, e-mail and Qtask. 13 Q. And how about within the confines of the 14 firm, was there another electronic mail system or 15 electronic system either for storage or for 16 communication? 17 A. To the best of my recollection, none for 18 communication. Storage, yes. There were electronic 19 paperless storage case management systems in place. 20 Q. And with regard to the electronic case 21 management system, were your files, including the 22 three cases involving Mr. Epstein, were those cases 23 on the electronic case management system? 24 A. Yes. 25 Q. And could you access the electronic case PROSE COURT REPORTING AGENCY, INC. EFTA00599687  Page 27 management system; that is, did you utilize the 2 software that was available? A. Yes. 4 Q. And had you ever used a system like that before you came to the RRA firm, RRA? 6 A. I don't understand. Q. Okay. Had you ever used an electronic 8 case management software system before you came to 9 RRA? 10 A. Yes. 11 Q. Was yours the system that you had used 12 before was that were you able to integrate that with 1.3 RRA, with the RRA file or system when you got there, 14 or did your files have to be put on the new RRA 15 system? 16 A. The latter. 17 Q. In addition, so we had the e-mail server, 18 Qtask, and electronic case management system. Was 19 there any other type of electronic storage or system 20 that was available for communication or storage at 21 RRA? 22 A. Not that I recall. 23 Q. With regard to the e-mail system, well, 24 with regard to the e-mail system, Qtask, and 25 electronic case management, did you require, was PROSE COURT REPORTING AGENCY, INC. EFTA00599688  Page 28 1 there a password required to use or access each one? A. No. Q. Was there a password required to use any 4 of the three? A. I don't believe so. 6 Q. As I saw in an order that with the Qtask 7 system that there was some sort of access code that 8 was required to get into Qtask. 9 A. I saw that too. 10 Q. Did you ever have, did you ever have such 11 a code or a password with regard to Qtask? 12 A. I don't remember. 13 Q. Has the receiver and/or it's, Mr. Seton or 14 his attorneys asked for you to provide any passwords 15 or information to access any of your files? 16 A. I don't think so. 17 Q. Do you understand that you have a 18 requirement or you're required to give the password 19 if requested by Mr. Seton? 20 A. I don't know the password to give to anybody. 21 I never knew there was a password. 22 Q. Did you -- 23 A. I don't believe. 24 Q. Did you use Qtask? 25 A. I have used Qtask. PROSE COURT REPORTING AGENCY, INC. EFTA00599689  Page 29 1 Q. With regard to your, the files 2 specifically, specifically the -- well, let me 3 strike that. During the time you were at RRA, of 4 the three files, Jane Doe, ill., and III. or in addition to those three files, did you represent any other individuals who were potential claimants against Mr. Epstein? A. I don't believe so. Q. All right. I received notification from you as to a Ms. 11 A. 12 Q. . and Ms. III. I believe is her name? 13 A. Correct. 14 Q. Were either of those individuals, had 15 either of those individuals contacted you prior to 16 leaving the RRA firm? 17 A. I don't believe so. 18 Q. Is it your testimony then that none, I9 neither Ms. III. nor Ms. III. would have had a fee '0 agreement or representation agreement with the RRA 21 firm because they hadn't contacted you prior to your departure from that firm; is that correct? 23 A. I'm not sure. 24 Q. Is it possible that Ms., either Ms. III. 25 or. Ms. III. contacted you before you left the RRA PROSE COURT REPORTING AGENCY, INC. EFTA00599690  Page 30 1 firm but you just didn't sign them up before you left? MR. SCAROLA: Objection, calls for speculation. THE WITNESS: Yes. 6 BY MR. CRITTON: 7 Q. Is there a reason that you would not have 8 signed them up during the time you were with -- or let me strike that. Prior to the implosion, prior, 10 prior to that Monday when you were advised that the 11 RRA firm was closing down, had you made any plans to 12 leave that firm, that is the RRA firm? 13 A. No. 14 Q. Okay. Had you discussed with any other 15 attorneys in RRA departing from RRA or the RRA firm 16 prior to that Monday meeting at which time you were L; advised that the firm was shutting down? I A. No. Q. You indicated it's possible that Ms. III. 20 or Ms. III. may have contacted you prior to your zi departure or prior to that Monday meeting. What 22 makes you believe that? 23 A. I don't remember exactly the timing of any 24 communications between myself and Ms. III. or Ms. III. 25 And it seems to me that it was around the time period PROSE COURT REPORTING AGENCY, INC. EFTA00599691  Page 31 1 either just before or just after I do believe I spoke with one or maybe both of them on at least one occasion 3 before the disbandment of RRA 4 And I know for a fact I signed each 5 one of the clients up after the disbandment of RRA 6 I can't tell you with any degree of certainty whether they signed a fee agreement with RRA prior 8 to the disbandment. 9 Q. Have you been able to do any transfers of 10 your, of -- let me strike that. With regard to the 11 e-mail server at RRA, have you had occasion to access that since that Monday; that is, the Monday 13 meeting that you referred to in either late October 14 or early November of '09? 15 A. Yes. 16 Q. All right. And have you had full access, 17 at some point did you get full access to all of your 18 e-mail that, that existed at least, that you had not 19 removed -- let me start again. 2.0 Under an e-mail server you, you have 21 the ability, obviously, to delete what you, what you 22 choose, correct? 23 A. As do you. 24 Q. As do I, right. And were you using like a 25 Microsoft Outlook program? PROSE COURT REPORTING AGENCY, INC. EFTA00599692  Page 32 A. I don't remember. Q. Okay. A. I am now. Q. Well, with the program that you did have, 5 could you delete it and then you would have to go 6 into the delete it and further delete it to clean it 7 out? 8 A. I don't remember. 9 Q. You don't remember back to October or lo September of '09 at this point? 11 A. That's just not what i do. I mean, I don't 12 just delete e-mails. So I don't know what you had to 13 do. You take me for somebody more e-mail savvy than I 14 am about that. 15 Q. Do you basically save all your e-mails or 16 had you in the past when you were at RRA? 17 A. I don't intentionally save or delete. They 18 are just there. 19 Q. And when you, when you, at some point 20 after the Monday meeting, were you able to transfer 21 whatever e-mails you had from RRA to your current 22 program? A. At Farmer, Jaffe, Weissing? Q. Correct. 21-) A. No. PROSE COURT REPORTING AGENCY, INC. EFTA00599693  Page 33 1 Q. Were you at some point given access to all 2 your e-mails so it could be downloaded either on a 3 disk, hard disc, floppy disk, or some other storage medium so that you had access to all your prior e-mails when you were at RRA? A. I don't know. Q. Did you ever make that request to someone, either the receiver or anyone else associated with RRA? 10 A. I don't remember if I made that request. 11 Q. I thought you indicated earlier, 12 Mr. Edwards, that you had access to some of your 13 e-mails. 14 A. I had access to all of my e-mails on that 15 Monday of the meeting, on the next day, on that Tuesday, 16 right, the immediately following the meeting. 32:46 at 17 some point in time it was cutoff and since that time, 18 when it was cutoff, I don't believe I have ever had 19 access back to my entire e-mail system. 20 Q. Okay. Have you had access to portions of 21 your e-mail system? 22 A. Not that I remember. 23 Q. Have you attempted to obtain access or 24 requested that you obtain access or information from 25 your e-mail, from the RRA e-mail server? PROSE COURT REPORTING AGENCY, INC. EFTA00599694  Page 34 1 A. I don't remember. 2 Q. You say you don't remember. Would there 3 have been a reason that you either requested or 4 didn't request access to your prior e-mail? When I 5 say prior I mean at RRA 6 A. Usually you read all of your e-mails and there 7 shouldn't be anything that I had not read. However, 8 there are some e-mails that you would like to keep 9 around. So there may have been reason for me to have 10 requested. However, I don't believe I was ever granted 1.1 access to those e-mails, and I can't specifically 12 remember requesting the e-mails. 13 Q. Within, within the e-mails you would have .4 corresponded with or communicated with people 5 outside of the firm and as well as people within the firm, true? A. Ever, yes. Q. During the time you were RRA A. Did I ever communicate with somebody outside? 20 I communicated with you. 21 Q. Correct. 22 A. So you know that to be true. Yeah, of course. 23 Q. I know that to be true. And my question 24 is as well within the server or e-mail system with 25 RRA, did you ever also communicate with other PROSE COURT REPORTING AGENCY, INC. EFTA00599695  Page 35 1 paralegals, other staff at RRA? A. Yes. 2 Q. And would you see, receive, if it was 4 something from one of the other partners at RRA 5 would you receive; that is, did you get firm-wide 6 e-mails from time to time about specific topics? 7 A. Yes. 8 Q. All right. When you, during the time that 9 you went back to RRA, did you printout, and up until 10 the time you were denied access to the e-mail 11 server, did you ever print, printout any e-mails or 12 transfer any e-mails that you can recall? L5 A. Not that I can recall. 14 Q. All right. With regard to the Qtask 5 system, have you been, since that Monday have you been able to use that system in any fashion? A. What do you mean by that? 18 Q. Have you been able to access Qtask either 19 to look to see what was there or in the alternative 20 pull information from so that you could printout 21 information from Qtask? 22 A. I don't know. Probably. 23 Q. Okay. Have you attempted since that 24 Monday -- well, after that Monday meeting -- let me 25 strike that. PROSE COURT REPORTING AGENCY, INC. EFTA00599696  Page 36 Since the meeting that occurred on that Monday at which time you were advised the firm was shutting down, have you accessed Qtask for any reason? A. I don't believe so. Q. What kind of -- you said, you described earlier that Qtask was a web based network of files for files and other materials. And in what fashion did you use Qtask during the time you were with RRA, RRA? 11 A. Qtask is a project centric web-based program. 12 So projects could be created. The project would 13 normally be a case, and that case discussed with lawyers 14 the way that you may gather around a table and discuss 15 it. And at times I was invited to projects on various 16 cases and utilized that system. 17 Q. Is that the only fashion that you would 18 have used Qtask during the time you were with RRA? 19 A. Yes. 20 Q. And when you say a project, as an example, 21 Jane Doe versus Jeffrey Epstein, if that had been 22 put, just this is hypothetically and then I will ask 23 you later whether that was in the system but if you 24 wanted or let me strike that. 25 Could Jane Doe versus Jeffrey Epstein PROSE COURT REPORTING AGENCY, INC. EFTA00599697  Page 37 been put in the Qtask program for, for purposes of 2 creating a project? A. Repeat it again. Q. Okay. Could a case like Jane Doe versus 5 Jeffrey Epstein been put in the Qtask system as a 6 project so that you and others could look at it? 1 You mean is, is, is the project capable of A. holding such a project? O. Yes, just generically. tu A. Yes, yes. 11 Q. And in terms of the RRA system, did the 12 RRA system ever have as, as a project Jane Doe 13 versus Jeffrey Epstein? 14 A. I don't believe so. 15 Q. Did you ever look in the Qtask, Qtask 16 system to determine whether you or anyone on your 17 behalf or any other person in the firm had ever put 18 Jane Doe versus Jeffrey Epstein into the Qtask 19 system? 20 A. Yes. 21 Q. Okay. And what did you find or not find? 22 A. I, I don't remember if that was the name of 23 any project in the system. It could have been, but it 24 may not have been. I don't remember that as a specific >5 project in the system. PROSE COURT REPORTING AGENCY, INC. EFTA00599698  Page 38 Q. When you say a specific project, if I 2 understand you correctly, Mr. Edwards, that would 3 have been, as an example, it could be any case. It 4 could be a real estate case, it could be a labor case, it could be Jane Doe versus Jeffrey Epstein, o but someone could, someone whether it was you or someone else could put in facts and information 8 about the case? 9 A. Similar to any case management system that's, 10 it just happens to be web based, but you have the right 11 concept. 12 Q. Is the concept the same concept for an 13 electronic, for the third electronic system, you had 14 the electronic case management system? 15 A. I suppose at full capacity it, it may. I just 16 wasn't that adept at Qtask to know all of the 17 capabilities of Qtask. 12 Q. With regard to the third item which I am t9 g