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Q 
So at least in April of 2009, Russ Adler, a 
tort lawyer; Bradley Edwards, a tort lawyer; and Marc 
Nurik, a criminal lawyer, are caucusing about the 
Epstein litigation? 
A 
About the non-prosecution agreement, 
specifically, which is a complicated document that 
related to the civil litigation, yeah. But that's why 
we would involve Marc, because of the complications 
related to that criminal document. 
Q 
And was Mr. Adler a partner? 
A 
No. I don't believe so. No. 
I think there were only two equity 
partners, which was Scott Rothstein and Stuart 
Rosenfeldt. 
Q 
As Mr. Adler the Adler at Rothstein, 
Rosenfeldt & Adler? 
A 
Yes. 
Q 
So he was a named partner? 
A 
He was a name on the door. I believe he was 
a partner at the time. I did believe that, because his 
name was on the door. 
Q 
How about Mr. Nurik? Was he a partner? 
A 
No. 
Q 
Did you believe he was a partner at the 
time? 
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A 
No. I learned -- I don't know about that 
time. A month into my being there, I learned that only 
Scott and Stuart were the actual partners. 
Q 
Equity partners? 
A 
Yes. 
Q 
That he owned the firm? 
A 
Yeah. The name partner really just meant you 
kind of controlled your own life. 
Q 
Did you talk with former Judge Bill Berger 
about the Epstein 
the three Epstein cases that you 
brought to the firm. 
A 
Yes. And Bill Berger was the one I told you 
earlier, he actually did certain things on the case: 
attended hearings, may have helped to draft a motion or 
two. 
Q 
Let's take a look at this one. Was 
Mr. Berger a partner? 
A 
No. 
Q 
Did he hold himself out as a partner? 
A 
I don't know that, but I believe that if --
he may have carried that title partner, which means he 
had his own division. He didn't have to report to 
anybody. 
Q 
If we look on the firm --
A 
That directory thing --
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Q 
-- directory. 
A 
I hadn't seen that until you showed it to me. 
It's not going to surprise me if it says partner. 
Q 
Berger's name probably says partner and so 
does Mr. Adler and Mr. Nurik, right? 
A 
Presumably. 
Q 
So this is an email and it says May 19th. 
And it's from Mr. Berger to Bradley Edwards -- that's 
you -- Russell Adler, Steven Jaffe. Who is Steven 
Jaffe? 
A 
He's a lawyer there and in the successor firm 
that I started after this. 
Q 
And Matthew Weissing? 
A 
Same. 
Q 
And Gary Farmer? 
A 
Same. 
Q 
Is this Gary Farmer senior or junior? 
A 
On this email that's junior. 
Q 
So we have got Berger, Edwards, Adler, 
Jaffe, Weissing and Farmer on email. Six lawyers. 
A 
Right. 
Q 
Discussing meeting with a psychologist 
expert related to Epstein? 
A 
Right. 
Q 
And it's Berger inviting you, in fact, to 
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attend an interview of Dr. Amy Swan, a psychologist, 
"who we're considering as the damages expert in 
Epstein cases." 
A 
Right. Yeah, the cases were being tried in 
West Palm Beach -- in Palm Beach where Judge Berger had 
just come off the bench. So the question really was, 
who are the psychologists who treat sex abuse victims 
in that area. And Judge Berger believed that she was 
somebody that he thought was well qualified who had 
appeared in front of him. So that's who he wanted us 
to interview. 
(Plaintiff's Exhibit Number 19 was marked 
for identification.) 
BY MR. LINK: 
Q 
I got. He's asked five lawyers to --
invited them to participate in the interview? 
A 
Yeah. 
Q 
Right? 
A 
I can't 
I can't imagine that many showed 
up to that, but yeah. 
Q 
Was Mr. Weissing, would he show up as a 
partner on the directory? 
A 
I don't know. Presumably though most 
everybody had that title. 
Q 
Do you have the directory handy? 
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A 
Tell me what exhibit it is. I'm sure I do. 
Q 
I think it's down at the bottom. 
A 
Maybe it was earlier in the day than I 
thought, unless I passed it. Yeah, I passed it. 
Q 
Right after that. 
A 
I will find mine. Ten -- here it is. 
Exhibit 12. You were asking me about Berger, right? 
Q 
Yeah. Let's just look at the folks that 
were all invited to attend this meeting. 
A 
William Berger says -- next to title, it says 
shareholder. 
Q 
Shareholder. Okay. Is that different than 
a partner? 
A 
In reality, no. But it's a different title. 
Everybody was an employee, but -- it's a different word 
than a partner. 
Q 
Well, you said earlier that there's a 
difference between a partner and a shareholder. And 
a shareholder means you actually have equity in the 
firm. 
A 
No, I didn't say that. Again, you're making 
things up. Totally made up. 
Q 
Okay. Then I misunderstood you. What is a 
shareholder? 
A 
I don't know. Another title that was given 
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at the firm. I think everybody was just an employee. 
There were two equity partners: Scott Rothstein and 
Stuart Rosenfeldt. Everybody else, some form of 
employee with a different name next to them, 
meaningless. 
Q 
Well, I see just on this very first page of 
Exhibit 12, I see there's a partner. I see Russ 
Adler is a shareholder. Roger Alvarez is an 
associate. Larry Barsky is an associate. Bill 
Berger is a shareholder. Shawn Birken is a partner. 
Then you have law clerk, shareholder for Boden, and 
partner for Bofshever. 
I see lots of different titles. 
A 
I do too. It's a made up stratification that 
somebody created at the firm. 
Q 
All right. 
So who else was on that list that we just 
looked at of the five names? 
A 
Russ Adler, which we went to. 
Q 
Shareholder. Berger, shareholder. 
A 
Steve Jaffe. 
Q 
How about Mr. Jaffe? So far working on --
with two shareholders and a partner. 
A 
Page seven. 
Q 
What is Mr. Jaffe? 
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A 
Partner. 
Q 
Partner. Okay. 
A 
Farmer. Farmer says shareholder. 
Q 
So we have three shareholders --
A 
And Weissing says partner. 
Q 
And all partners. All right. Stuart 
Rosenfeldt says shareholder, by the way. 
So he had the same title as Adler, Berger 
and Farmer? 
A 
Apparently, on this directory he did. 
Q 
Okay. 
A 
And Scott Rothstein says managing partner, 
chairman, CEO. 
Q 
Okay. 
A 
I assume Mr. Rothstein named everybody, then, 
since he's the only one with the highest title. 
Q 
Look at Number 20. 
A 
Yes, sir. 
(Plaintiff's Exhibit Number 20 was marked 
for identification.) 
BY MR. LINK: 
Q 
This just follows up on what you testified 
earlier. This is from Susan Stirling. Who is Susan 
Stirling? 
A 
That name is familiar. I don't remember. 
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Q 
This is about Epstein. And it's her saying 
to you, "I promise I will tell you about every check 
I get. So far it has only been the one for the 
motorcycle." 
A 
So it looks like I sent an email before that 
saying did we get a check to Wayne Black yet. That's 
probably after he called me saying he hasn't been paid. 
If not, let me know, and I will tell Russ about this, 
again. Which is what I was saying, I will tell Russ 
somebody needs to get paid. 
She says, "No. I promise I will tell you 
about every check I get. So far it has only been 
one for the motorcycle." That's a different case. 
That was a motorcycle in storage on another case. 
Q 
So when you were mentioning about paying 
Wayne Black and talking to Russ, this is --
A 
That's consistent with exactly what my memory 
was this morning, is Wayne was saying he wasn't getting 
paid, and I was referring it to Russ. 
Q 
Mr. Edwards this is Exhibit 21 
(Plaintiff's Exhibit Number 21 was marked 
for identification.) 
BY MR. LINK: 
Q 
And this is the Seventh Amended and 
Supplemental Witness List filed on your behalf last 
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night at 5:20 p.m. 
Can you tell me, please, what 
-- what factual knowledge and information 
she has and why she's expected to be presented as a 
witness? 
A 
I think who is going to be called and in what 
order and what they're going to present is better asked 
of my attorney, who is presenting the case. But I know 
Q 
Did I ask that? I don't remember asking 
that. 
A 
I thought you asked what information 
was going to testify to in this case. 
Q 
Right. Not when or if. She's listed here 
as expected to be presented, right? 
A 
It would be in response to any question --
any witness would be in response to any questions that 
Mr. Scarola asks of them. 
Q 
True. 
A 
So I know what she would say if she told the 
truth: Jeffrey Epstein was my employer. He hired me to 
assist him in recruiting underaged girls so that he 
could molest them. He did it all over the world. I 
watched him traffic them nationally, internationally, 
and I was also made to participate in that. And then 
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when Mr. Epstein was discovered by the FBI, he 
assaulted me on an airplane to get me to cooperate with 
him and not cooperate with the victims. 
If she was going to tell the truth, that's 
along the lines of what she would say. 
Q 
We are talking about the counterclaim for 
malicious prosecution, right, calling her in the 
counterclaim claim for malicious prosecution, right? 
A 
Right. The cases weren't fabricated. 
Epstein really is a child molester. The underlying 
cases that you were prosecuting against him really were 
legitimate underlying cases. III. was a victim, not 
fabricated. 
Q 
Was there something in the claim that 
Mr. Epstein brought where he said anything about his 
interaction with 
and the case that you filed? 
Where does he say that? 
A 
Yeah. He says --
Q 
Show me where that is. 
A 
He says -- look at this deposition. He 
says --
Q 
I'm asking you about the complaint that he 
filed that you say -- as I understand you -- you have 
one count, malicious prosecution, right? And that 
you say on December 9th, 2007, when that complaint 
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was filed --
A 
7, 2009. I got you. 
Q 
December 7th, 2009 -- that Mr. Epstein did 
not have a -- did not have probable cause to file 
that proceeding. That's the complaint you brought, 
right? 
A 
Right. 
Q 
So, understanding what was in Mr. Epstein's 
mind about what he knew about Rothstein and his Ponzi 
scheme, and what he knew about any connection to 
that -- that he might have in his head, how does 
have personal knowledge about that? 
A 
You just reframed this case to something that 
this case is not. 
Q 
Really. Tell me what the case is about 
then. 
A 
Well, at least as it relates to 
Q 
No, no. Is it not a malicious prosecution 
case? 
A 
It is a malicious prosecution case. 
Q 
And it's whether or not Mr. Epstein had 
probable cause when he filed it, right? 
A 
To bring the complaint that he filed. Right. 
Q 
The proceeding that he brought, whether he 
had probable cause 
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A 
Yes. 
Q 
-- is one of the elements. 
A 
Sure. That's one of the elements. 
Q 
Does 
ave any factual 
information related to whether Mr. Epstein had 
probable cause to make the allegations he did about 
Mr. Rothstein and about you? 
A 
Mr. Epstein --
MR. SCAROLA: Excuse me. To the extent 
that relevance is a legal concept, the 
question calls for a legal conclusion. I 
object to the form of the question on that 
basis. 
MR. LINK: Understood. Thank you. 
THE WITNESS: Mr. Epstein's complaint 
against me for the crimes that he alleged 
that I and Scott Rothstein and
committed is predicated upon the assertion 
by him that I fabricated cases of a sexual 
nature on behalf of victims, or fictitious 
victims, including 
And in furtherance of these fictitious 
cases, that I conducted irrelevant discovery 
that could serve no purpose but to pump a 
Ponzi scheme. 
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would be able to testify 
that 
's case was not fabricated, was not 
as Mr. Epstein elaborated in his deposition, 
ginned up; that it was indeed legitimate. 
She was a legitimate victim. My pursuit of 
discovery, including the flight logs, was 
relevant to the proof of her claim, 
including the punitive damage claim that I 
was prosecuting, which would refute the 
probable cause he claims existed when he 
filed the complaint against me. 
BY MR. LINK: 
Q 
So help me understand. I know you have got 
a bunch of these folks --
A 
I don't know if I can say it better than 
that. 
Q 
You said it very well. 
What I'm asking about is -- if I 
understand the counterclaim that you filed 
the 
probably cause requires a reasonably cautious person 
to have a good faith belief, essentially, in the 
things that they allege -- Mr. Scarola said it more 
articulately earlier, right -- and so that it has to 
do with the allegations made. 
Does Ms. IIIIIIIIIhave any knowledge about 
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what Mr. Rothstein was doing? 
A 
Ms. 
has knowledge about what 
Mr. Epstein did, and therefore, what Mr. Epstein knew. 
And therefore, what Mr. Epstein said in his complaint 
was knowingly false. 
Q 
Let me try my question again. 
A 
Which means no probable cause. 
Q 
I must have confused you. Did Ms. 
have any knowledge about what Scott Rothstein was 
doing? 
A 
Ask her. 
Q 
Pardon me? 
A 
Ask her. 
Q 
You don't know? 
A 
I don't know if she knew what Scott Rothstein 
was doing. 
Q 
Did Ms. 
have any idea what you were 
doing at the Rothstein firm? Were you talking to 
her? Did she participate? 
A 
Not to my knowledge she didn't know what I 
was doing. 
Q 
So Ms. 
testimony has to do with 
claims made by victims that have settled their cases, 
right? 
MR. SCAROLA: It has to do with what 
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Mr. Edwards has described in detail it has 
to do with. He doesn't --
What purpose does it serve for you to 
recharacterize in five words the lengthy 
answer that he gave you explaining in detail 
the relevant, quote, unquote, knowledge that 
you asked him? 
BY MR. LINK: 
Q 
I'm just trying to understand how the 
knowledge is part of your case. That's what I'm 
asking. I understand. 
So her knowledge is about what she knew 
about Mr. Epstein before he did his plea deal, 
right? 
A 
And after. 
Q 
And after. 
A 
It's what she knew about what Mr. Epstein did 
and what Mr. Epstein knew at the time that he filed the 
false complaint against me. That's what it is. 
Q 
Did she talk to Mr. Epstein at the time he 
filed the complaint and say, What's in your mind? Is 
that what she's going to say? Mr. Epstein told me in 
December of 2009 this is why I filed this complaint? 
A 
All right. Let me just give you an example. 
Q 
Okay. 
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A 
as on the airplane with Jeffrey 
Epstein and an underaged girl. Jeffrey Epstein makes 
the allegation in the complaint that the proof that 
Brad Edwards was pumping a Ponzi scheme is that he 
sought flight logs, despite knowing that there were no 
underaged girls on the airplane. Jeffrey Epstein knew 
that to be false, because there were indeed underaged 
girls on the airplane. 
To the extent that Jeffrey Epstein himself 
won't say that I knowingly filed this false 
allegation, 
could say, I know that 
Jeffrey Epstein knew that that was a false 
allegation, because I too was on the airplane and so 
was this underaged girl, and he knew that. 
So at the time that he filed this 
complaint, he knew that it was false, the 
allegations that he was making, which allegedly 
formed the basis of his assertion that I was 
involved in a Ponzi scheme. 
Q 
Okay. 
You lost me, but I'm not going --
A 
Read it back. I think it makes sense. 
Q 
I'm not going to try to figure that out. 
Do you have anyone that can testify about 
what was in Mr. Epstein's mind in December 2009 at 
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the time that the lawsuit was filed about why he 
filed it? 
A 
Mr. Epstein testified to that. 
Q 
Other than Mr. Epstein, do you have any 
witnesses that are going to testify about the reasons 
why Mr. Epstein made the decision to file the 
lawsuit? 
A 
No. It's very obvious why he filed the 
lawsuit. 
Q 
You have no other witnesses other than 
Mr. Epstein, correct? 
A 
We have attempted to take his attorneys' 
depositions and they have all rejected that 
opportunity. So he has no witnesses that can testify 
as to what was in his mind at that time. 
Q 
You are the plaintiff in the counterclaim, 
right? 
A 
We will see how this unfolds, right? 
Q 
Let me just wrap this up, because you have 
given me a lot of information to which I think are 
simple questions. Do you have a witness that will 
testify, other than Mr. Epstein, about what was in 
his mind in December 2009 about why he brought the 
lawsuit? 
MR. SCAROLA: Direct evidence or 
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circumstantial evidence or both? 
THE WITNESS: Let me think about that 
question. About why he brought the lawsuit. 
Specifically that. 
MR. LINK: Can you read back the 
question for him, please? 
I won't take that as coaching at all. 
In any event, well done. But I don't think 
you heard my question. 
Can you read it back? 
(Thereupon, the requested portion of the 
record was read back by the reporter as 
above duly recorded.) 
THE WITNESS: A witness other than 
Mr. Epstein, no. 
BY MR. LINK: 
Q 
Thank you. 
Why was Bill Berger added to the witness 
list last night? 
A 
You will have to ask somebody other than 
myself. 
Q 
Do you know what Mr. Berger -- why he's 
listed as an expert in this case? 
A 
Again, that's a question for the lawyers. 
Q 
Do you know when Mr. Berger agreed to 
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testify as an expert in this case, or if he has? 
A 
Also a question for Mr. Scarola. 
Q 
Have you --
MR. SCAROLA: All of which I will be 
happy to answer at the appropriate time. 
BY MR. LINK: 
Q 
Do you know what factual knowledge 
Mr. Berger has upon which he will predicate an expert 
opinion in the case? 
A 
Again, this is not a question for me. 
Q 
How about Earleen 
Earleen? 
A 
He certainly knows why certain discovery was 
done and for what legitimate purpose it was done. But 
what he's going to testify to, again, that's just a 
question for somebody else. 
Q 
I will ask him. That's okay. 
Earleen Cote --
A 
She's --
Q 
Do you know why she was listed last night 
at 5:20 p.m. to the Seventh Amended and Supplemental 
Witness List? 
A 
She's a -- she's my former boss at Kubicki 
Draper. 
Q 
Why was she listed last night? What is she 
going to testify about Mr. Epstein? 
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A 
She will not testify about Mr. Epstein's 
knowledge of what was in his mind before -- whatever 
that question was you asked. She won't testify about 
that. 
Q 
Can you tell me what the purpose for her 
being included? What is the knowledge she has about 
the lawsuit? 
A 
No. Only about me. 
Q 
She's going to testify about you as an 
employee at Kubicki Draper? 
A 
I have known her for many years, from that 
time until today, so she can testify about 
Q 
About what? Related to the lawsuit. 
A 
Sure. How the lawsuit has affected me over 
time. 
Q 
I see. Okay. So she's not -- that's what 
she's going to testify about. Okay. 
How about -- you took Mr. Dershowitz off 
the witness list. Do you know why Mr. Dershowitz is 
no longer --
A 
I didn't know he was on the witness list. 
Q 
On for years. 
A 
By you or by us? 
Q 
This is your witness list, not mine. 
You don't know why he was on there. Okay. 
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