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How about Prince Edwards? Do you know why 
Prince Edwards was on the witness list? Is 
he coming here to testify? 
A 
I don't even know who that is. 
Q 
You don't even know who he is? 
A 
Prince Edwards. No. 
Q 
Do you know whether he's coming to testify? 
A 
I don't know who that is. How would I know 
if he's coming to testify. 
Q 
You're the plaintiff and a lawyer in the 
case. 
A 
Is that a real person? 
Q 
He's on your witness list, sir, not mine. 
A 
Show me where that is. 
Q 
You don't have the witness list -- you, you 
have the witness list. I can't tell you. I'm 
looking at a chart, and they are not alphabetical. 
It's like a scrambled witness list. 
A 
Let me try. 
Q 
I think he goes by Price Andrew, I'm told. 
A 
Okay. Prince Andrew. If he testifies, he 
would have relevant information. 
Q 
Do you know what he has? 
A 
Yeah. I know that Jeffrey Epstein lent at 
least one underaged female to Prince Andrew. 
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Q 
Lent? What do you mean by that? Tell me 
what you mean by that, please. 
MR. SCAROLA: The witness 
identification actually appears at number 
48, Prince Andrew Albert Christian Edwards, 
which is his full legal name. Duke of York, 
Buckingham Palace Road, London. 
THE WITNESS: I would love for him to 
testify. 
BY MR. LINK: 
Q 
Has he been subpoenaed, do you know? 
A 
I don't know. We have tried to subpoena him 
in the past, and he doesn't seem to want to testify. 
Q 
The Royals are not easy to get in a circuit 
court? 
A 
Apparently not. I think that your client 
would have the ability to get him here, though, so I 
would hope he could. 
Q 
Since he's on your witness list --
Mr. Edwards -- I suspect that you would be the one 
that would be calling him. 
A 
Like I said, I would love to. 
Q 
On the witness list, if you would, turn to 
the back page -- Mr. Scarola's office didn't number 
the pages -- oh, 18 of 22. He did. You see under 
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expert witnesses on page 18 of 22 --
A 
Yes. 
Q 
-- Mr. Josefsberg? Has he agreed to be an 
expert witness? 
A 
Again, that's a question for Mr. Scarola. 
Q 
Have you talked to Mr. Josefsberg --
A 
Ever? 
Q 
No. Let me finish. 
Have you talked to Mr. Josefsberg about 
testifying in this case? 
A 
Have I personally? 
Q 
Yes. 
A 
No. 
Q 
How about Charles Lichtman at Berger 
Singerman? Has he agreed to provide expert opinions 
in this case? 
A 
All of these witnesses, you would have to ask 
Mr. Scarola. 
Q 
So you told me --
A 
He's in charge of the case. 
Q 
I got it. 
So there's one, two, three, four, five, 
six, seven, eight, nine expert witnesses listed? 
A 
Most of which appear to be the plaintiff 
attorneys who handled the other -- who represented the 
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other victims against Mr. Epstein, and would testify 
that all of the discovery that Mr. Epstein claims to 
have been done and so improper for some improper 
purpose were joint decisions by all of us, and was 
entirely proper and served very relevant purposes for 
all of our clients. 
Q 
Now, you have Earleen Cote -- who you told 
me was a personal friend -- listed as an expert 
witness. Does she have an expert opinion she's going 
to provide to the jury? 
A 
That's a question that is directed better to 
Jack. 
Q 
One of the experts that's listed --
Exhibit 22. 
(Plaintiff's Exhibit Number 22 was marked 
for identification.) 
BY MR. LINK: 
Q 
-- actually provided a report in your case. 
A 
It looks like, from the expert witness list 
that you showed me before, that he's the only one 
that's above the paragraph saying, The following, or 
attorneys that are not retained, or are specifically 
employed to provide expert testimony. So that's 
probably why we have a report, because he's the one 
expert that has been employed to provide expert 
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testimony. 
Q 
I understand. He's the only one that 
complied with the disclosure rules and has a report, 
but the rest are listed as under the actual expert 
witness section. 
A 
I hear you. 
Q 
So in looking at -- do you have the report 
in front of you, which we just marked as Exhibit 22 
for Bernard Jansen, PhD? 
A 
Yeah. 
Q 
When was Mr. Jansen retained? 
A 
I don't know. 
Q 
Your counterclaim has been pending since 
December 2009, correct? 
A 
Yes. 
Q 
Do you know why Mr. Jansen did not provide 
a report until 2017? 
A 
Don't know. 
Q 
Do you know why Mr. Jansen was not listed 
on any exhibit list from the beginning of the case --
the first -- I think it was five -- maybe five or six 
witness list to the court? 
A 
With certainty I don't know. I know the 
types of things he does. And typically his report is 
most useful right before trial, because it is a 
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quantification of the number of people who have seen 
the articles associated -- depending on the type of 
lawsuit in which he's testifying -- with the derogatory 
and defamatory statements, so --
Q 
Dr. Jansen --
MR. SCAROLA: Excuse me. I'm sorry. 
You interrupted Mr. Edwards. 
BY MR. LINK: 
Q 
Did I, Mr. Edwards? 
A 
Yes. I was almost finish, though. 
So his report can't be completed until 
well, you want it to be complete as close up to the 
trial as possible so that you can have the final 
numbers. 
Q 
I understand you can update reports. But 
you could have retained him at any time, because 
there were other trial settings and there would have 
been a witness list, right? 
A 
Well, we have been on appeal for a while, 
but --
Q 
I understand. But you've had five trial 
settings. 
In any event, you have used Mr. Jansen 
before, correct? 
A 
I have used Mr. Jansen before. As a 
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plaintiff I have not. This is my first time, I think. 
Q 
As a lawyer? 
A 
Yes. 
Q 
I saw on his Appendix B on page 77 he lists 
a lawsuit 
versus Maxwell, that we talked 
about earlier --
A 
That's the one I told you earlier. 
Q 
-- with Boies Schiller --
A 
Right. 
Q 
-- and your firm, Jaffe, Weissing, Edwards, 
Fistos & Lehrman, right? 
A 
Exactly. 
Q 
And is that where you met Mr. Jansen, 
during that lawsuit. 
A 
Yes. 
Q 
Was he somebody that the Boies Schiller 
firm recommended that you use? 
A 
In that lawsuit? 
Q 
Yes. 
A 
I don't remember who first found him. I 
would say that in the first call with Mr. Jansen, right 
before he was hired, it was either myself and 
Mr. Boies, or somebody from his firm. So together we 
found him. 
I think he testified in the Erin Andrews 
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case. That's initially how we discovered him. 
Q 
If you flip back in this report to 
forward in the report. Sorry -- to page 13. You see 
the first article that he references is from 
October 4th, 2017. 
A 
I do see that. 
Q 
This is one of the articles he references 
as being dissemination of defamatory material about 
you, correct? 
A 
I don't know. I haven't read this report. 
Q 
You didn't read his report? 
A 
No. 
Q 
So what was it that he was retained to do, 
then, if you didn't read his report? Do you know? 
A 
It wasn't so I could read his report. That's 
definitely not what he was retained to do. 
Q 
Okay. Did you understand that he was 
supposed to do a search to see where articles had 
been disseminated and the number of viewers? 
A 
How many viewers viewed the dissemination of 
the false allegations that were made against me that 
were prompted or set in motion by Mr. Epstein's 
complaint. 
Q 
So he lists some examples here on page 13. 
Are you familiar with the article, October 3rd, 2017, 
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in the Palm Beach Post about Jeffrey Epstein paid 
three women $5.3 million to end sex lawsuits? 
A 
Yeah. 
Q 
Did your office or Mr. Scarola's office 
invite that reporter to the hearing on that day? 
A 
I did not. I wasn't even in town, I don't 
believe, for that day. 
Q 
Do you know whether Mr. Scarola had lunch 
with that reporter that day before the article came 
out or the day before? 
A 
I do not know. I don't think it's of 
consequence, since that article contains these false 
allegations, and it was only set in motion by this 
complaint. 
Q 
So even if you reached out and asked a 
reporter to attend a hearing and publish an article, 
that's Mr. Epstein's responsibility because he sued 
you in December 2009; is that right? 
A 
You got it. Although, I didn't do that. 
Q 
You retained Mr. Scarola on a contingency 
fee to represent you in this case? 
A 
Yes. 
Q 
So you haven't had to pay Mr. Scarola for 
his work; is that correct? 
Let's take a look at Exhibit 23. 
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(Plaintiff's Exhibit Number 23 was marked 
for identification.) 
BY MR. LINK: 
Q 
Can you tell me from looking at Exhibit 23, 
which is a compilation of Brad Edwards' time, when it 
is that you started taking contemporaneous notes of 
your time -- contemporaneous time records? 
A 
I believe by February. 
Q 
Of February 2010? 
A 
I believe so. 
Q 
What is it about February 2010 that makes 
you think that's when you started? 
A 
It looks like that's when 
Q 
Is there something different about that 
February 2nd entry that's different than the 
January 29th and 30th entry? 
A 
No. What I thought was that there was a 
hearing, because I remember -- like I said, I remember 
being at a hearing at the courthouse. But now that I'm 
looking at this, this says, "Review of" -- it's a 
notice. 
Okay, it was before my deposition, which 
was March 23rd, 2010. It was before that day. 
Q 
Before March 23rd? 
A 
That's the date that it says my deposition 
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was taken here. 
Q 
Was your deposition taken for 12 hours? 
A 
It was similar to today, which, you know, I 
left my house this morning at whatever time. It was 
it's going to be longer than 12 hours, you know. 
Q 
So you bill from the time you leave your 
house until the time you get back? 
A 
Yeah. For that day I wrote that down. The 
time I left -- the time I came here -- the whole time 
that this deposition took out of my life that day, I 
billed it. 
Q 
When you're billing clients, do you bill 
clients for the amount of time it takes you to drive 
from your house to wherever the deposition is, if you 
are charging them on an hourly-rate basis? 
A 
That's usually worked out with the client. 
Sometimes if it's out of town, I tell them you are 
going to have to pay for travel. But most of the time 
not if it's out of town. If it's in town -- it's down 
the street, I bill from -- there's usually preparation 
before the deposition, too, so, you know, it's --
Q 
I'm just reading what you wrote here. And 
what you wrote is deposition of Brad Edwards at 
Searcy Denney, 12 hours? 
A 
Yeah. It was probably longer than that. 
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From the time that I -- the time that it took out of my 
day was longer than that. And that wasn't in billing a 
client. It was -- I couldn't do anything for any 
client that day, because I was wrapped up in this 
nonsense. 
Q 
Well, you said -- okay. Let's go back, 
then, and take a look at the beginning. Remember, I 
asked you about your review of the complaint? You 
said you did that on the 7th. And I total 22.7 hours 
that you have recorded to review the complaint in 
this case. 
A 
I have reviewed it for longer than that. I 
may not 
Q 
So to read this complaint you spent more 
than 22 hours? 
A 
Over the course of the last eight years, yes. 
Q 
I'm talking about in the first five days, 
it has the 22 hours, sir. 
A 
If that's what the time records say. That 
doesn't seem --
Q 
You have got 8.1 on the 7th. You see that? 
Initial complaint, review and research. 
A 
It's not just reviewing the complaint. It's 
also research related to the complaint, which includes 
a lot of things. 
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MR. SCAROLA: Do you have any questions 
relating to these time records that concern 
any of the four areas that the Court has 
described, other than a general review of 
the time records that was already conducted 
by your predecessor counsel and still 
co-counsel Fred Haddad? 
MR. LINK: I am asking about his claim 
for damages. 
MR. SCAROLA: Yes, sir. I understand 
that. But this aspect of his claim for 
damages was the subject of prior deposition 
testimony. 
These records were produced in advance 
of that deposition. Mr. Haddad had them. 
Mr. Haddad conducted an examination with 
regard to these time records. 
We are not going to go through that 
again. That is an area that was inquired 
into. And everything about these time 
records could reasonably have been asked at 
that time or was asked at that time. 
MR. LINK: I understand. 
MR. SCAROLA: So I'm going to object to 
any further questions, unless those 
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questions can be tied into the areas 
specifically permitted by Judge Hafele. 
MR. LINK: I believe Judge Hafele has 
given me permission to ask about damages. 
BY MR. LINK: 
Q 
So would you take a look, if you would, at 
September 2nd, 2010? And do you see on that date you 
recorded 41 hours of time? 
A 
It wasn't all done on that date. 
Q 
By September 2nd, 2010, you told me you 
were keeping contemporaneous time records. So if you 
were keeping contemporaneous time records, you 
recorded on that date 41 hours. 
A 
But I'm not billing a client. This is 
keeping records for me, so I know how much time I'm 
spending on the file. 
If you have seen the summary judgment 
motion and seen the undisputed statement of facts, 
and seen the volume of exhibits attached to it, you 
would know how long is spent to assemble that 
motion, and know that that's not really an 
unbelievable amount of time. 
So by that date, that's the number of 
hours that I had spent on that, that block billed 
that. This is not something that -- I am doing it 
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for me. It's not going to a client. 
Q 
But you are doing it in order to recover 
damages against Mr. Epstein, right? 
MR. SCAROLA: Excuse me. Don't answer 
that question. 
And unless you can tie a specific 
question regarding these time records to the 
area specifically identified by Judge 
Hafele, or demonstrate that the questions 
that you are asking are questions that could 
not reasonably have been covered during the 
third session of Mr. Edwards' deposition, 
then we will not answer the questions. 
MR. LINK: So, if I understand it, any 
questions that I have that relate to damages 
that are set forth on Exhibit 23, your 
position is I'm not allowed to ask? 
MR. SCAROLA: Unless they can 
specifically be tied to the filing of the 
federal lawsuit, interaction with Rothstein 
and knowledge of the Ponzi scheme, or the 
$14 million bond motion, that's correct. 
This aspect of damages was fully and 
completely explored by Mr. Haddad. We are 
not here to redepose Mr. Edwards with regard 
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to matters that were already covered. And 
no objections were raised with regard to 
those questions, so this is not an area 
where the Court sought a clearer record with 
regard to the nature of the objections that 
were being raised and any privilege 
assertions that were being raised. 
MR. LINK: Okay. You're entitled to 
instruct him. I disagree with the way you 
read the transcript. It is what it is. 
MR. SCAROLA: That's fine. 
MR. LINK: So the record is clear, 
there are many questions I would want to ask 
you about these time records, particularly 
in light of you telling me that you kept 
contemporaneous records, which I don't think 
is true, based on the time that I see here 
and based on the testimony I just heard, 
which is that I block billed here, and that 
I would like to explore that further. 
Mr. Scarola --
MR. SCAROLA: Your personal assessment 
of Mr. Edwards' credibility is neither 
relevant nor material, particularly when 
your predecessor counsel had every 
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opportunity to explore issues regarding 
credibility with regard to these records. 
MR. LINK: Move on? 
MR. SCAROLA: Please do. 
BY MR. LINK: 
Q 
Mr. Edwards, since 2009 when Mr. Epstein's 
lawsuit was filed, you have actually made 
presentations about the Epstein case and about 
representing sexual abuse victims, right? 
A 
I have definitely made presentations about 
representing sexual abuse victims. And one of those 
cases is the case against Jeffrey Epstein. 
Q 
Okay. Let's take a look at Exhibit 24. 
(Plaintiff's Exhibit Number 24 was marked 
for identification.) 
BY MR. LINK: 
Q 
If you would, I would like you to turn to 
-- it's page 99. This was part of a bigger package. 
I think it's a presentation you made to the National 
Crime Victim Bar Association. Do you remember that 
presentation? 
A 
Let me see. Where was it? I know where it 
was --
Q 
If you look on page one, it says, "Bradley 
Edwards. Protecting the Rights of Crime Victims. 
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Why do we do what we do. Papers and Presentations." 
You see that? 
A 
I have given that presentation. 
Q 
Turn to page 99. 
A 
Yep. 
Q 
So, if you look at Subsection F, you make 
the comment in A that defendant will likely invoke 
the Fifth. Does that mean the Fifth Amendment? Is 
that what you mean by that, the constitutional right 
to not testify against yourself? 
A 
The Fifth -- your client does it all the 
time. Yes, that's what I'm talking about. 
Q 
Were you talking about Mr. Epstein here or 
generally? 
A 
Doesn't look like --
Q 
Doesn't look like Mr. Epstein to me. 
A 
It doesn't look like it. 
Q 
In most cases that are brought involving 
sexual abuse, do the defendants invoke the Fifth 
Amendment? 
A 
When you sue a pedophile, typically they 
invoke the Fifth. I mean, I can't even think of an 
instance where they haven't. 
The only time that they don't is if they 
try to claim that it was negligent or they 
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misunderstood the age or misapprehended something 
about the situation. But where they're actually 
guilty, yeah, they take the Fifth. 
Q 
You see here where you say here in those 
cases where somebody pleads the Fifth, you can and 
should ask -- something you put in quotes 
pressure 
point questions. You see that? 
A 
Yeah. 
Q 
And then you give an example of a pressure 
interrogatory. 
A 
Yep. 
Q 
What do you mean by finding pressure points 
to ask defendants? 
A 
Well, so this is talking about in an STD 
transmission case, which I have had a bunch of them 
not a bunch of them, four or five of them. And one of 
the things that is difficult about those cases is 
proving that the perpetrator -- the perpetrator usually 
doesn't admit, Yeah, I knew I had it beforehand. So in 
this case, getting the names and numbers of all their 
prior girlfriends and tracing back the disease is a 
pressure point that typically when they see that you 
are headed down this road that you are ultimately going 
to get information from previous people to be able to 
prove your case, it will lead to the defendant 
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understanding that you got me and --
Q 
A settlement? 
A 
Yeah, and the case will settle. 
Q 
So that if you apply the appropriate 
pressure to the right -- in the right circumstances, 
you will get them to settle? 
A 
Yeah. 
Q 
Is that a tactic that you were teaching 
that folks should do if you were representing a 
plaintiff, which is to find the right pressure points 
so that you can extract the best settlement possible? 
A 
Well, that's what every plaintiff lawyer does 
in every case, is try to maximize the recovery. And in 
order to do that, you need the right evidence. And in 
order to get the right evidence, these are the types of 
questions that you need to do to get it. 
Q 
And you have to squeeze the pressure point, 
right? Push the pressure point to get the best 
settlement? 
A 
You've got to get the right evidence to get 
it, yeah. Of course. 
MR. LINK: Let's mark this as a 
composite Exhibit 25. 
(Plaintiff's Exhibit Number 25 was marked 
for identification.) 
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