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federal action have anything to do with any factor, 
other than those that you have just described, the 
potential expiration of the statute of limitations 
and your desire to take advantage of the provisions 
of the non-prosecution agreement as a potential 
alternative to the state court claim? 
A 
That is the only reason that we filed it at 
that time. 
Q 
Did Scott Rothstein have any role 
whatsoever in that decision-making process? 
A 
He never had any role in any decision-making 
process with anything to do with any of these cases, so 
no. 
Q 
Did you become aware of the fact that your 
Epstein-related files at some point in time had been 
requested by Scott Rothstein? 
A 
Yes. 
Q 
How did you become aware of that? 
A 
I think Mike told me -- Fisten. 
Q 
Was there any explanation offered as to why 
Scott Rothstein wanted to see the Epstein-related 
files? 
A 
That if these cases went to trial, he wanted 
to try the cases with me. 
Q 
He who? 
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A 
He, Scott Rothstein, wanted to try the case 
with me. That's the explanation that I was given. 
Q 
And was there anything suspicious about the 
head partner in the firm telling you that in this 
high-profile case he wanted to be part of the 
prosecution team? 
A 
No. If my associate brought in a 
high-profile case right now, I would be the one to try 
the case, despite the fact that she may be the only one 
who knows anything about it. So there's nothing 
suspicious about that. 
Q 
Files got returned to you? 
A 
Yes, files did get returned to me. 
Q 
And -- was there anything about the request 
for review of the files on the basis that Scott 
Rothstein was considering participating in the 
prosecution of those claims that aroused any 
suspicion on your part? 
A 
No. 
Q 
Was there anything else that went on in the 
short period of time that you were in that law firm 
that gave any cause for you to suspect that your 
files were being used in any way, directly or 
indirectly, in connection with any illegal activity 
of any kind? 
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A 
No. I was just a lawyer just working my case 
and trying to prove my case. That's it. I wasn't 
concerned with whatever other signals or signs there 
were. But there weren't any. The most suspicious 
thing was, there were police officers walking the 
hallway. But police officers in the building didn't 
give me that type of suspicion. It was an unnecessary 
degree of security over the law firm, at best. But 
with these files or any of the files, no suspicion 
whatsoever. 
Q 
Who were your coworkers in that law firm? 
Who were the other lawyers that you were working 
with? 
A 
Just generally who was in the law firm? 
Q 
Yeah. Give us a general description of the 
quality of the people that were working for 
Rothstein, Rosenfeldt & Adler during the period of 
time that you became associated with the firm. 
A 
Well, while I was at the firm, I worked with 
Bill Berger, who had just come off the bench. He was a 
judge. 
Q 
There's been a number of references to Bill 
Berger having just come off the bench. Was Judge 
Berger a respected member of the judiciary in Palm 
Beach County? 
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A 
Very much so, and that's why I welcomed him 
to help with the file. 
Q 
Did he leave under any circumstances that 
gave rise to any suspicion whatsoever? 
MR. LINK: Object to the form. 
THE WITNESS: Not at all. 
BY MR. SCAROLA: 
Q 
Who were the other people that you were 
working with? 
A 
Like I said, I conducted -- I ran the files. 
But other people --
Q 
When I say working with, I'm not talking 
about limiting that question to people who worked on 
the Epstein files. Who were the other folks that 
were a part of this firm? 
A 
Steve Jaffe, Gary Farmer, Matt Weissing. 
Gary's Farmer's father was an appellate judge. In 
fact, I think he was still on the bench then when we 
were working there together. Gary is a senator now. 
Matt Weissing, who became my partner. Steve Jaffe, 
same. Mark Fistos, same. 
These are high-quality people. Good 
lawyers. The people that I associated with there, 
good lawyers, good people, not doing anything bad. 
They're just lawyers who are good lawyers. That's 
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it. 
Q 
Did any of these high-qualify, respected, 
good lawyers ever express any suspicion to you about 
any of the activities that were being conducted 
within that law firm? 
A 
Not at all. 
Q 
Did the unraveling of the Ponzi scheme come 
as a total and complete surprise to you? 
A 
Of course, yes. 
Q 
Did you speak to anybody within the firm, 
among those respected lawyers that you have 
described, who indicated to you that the unraveling 
of the Ponzi scheme did not come as a total and 
complete surprise to them? 
A 
All of them were just as surprised. 
MR. SCAROLA: I have no further 
questions. 
MR. LINK: I have couple follow-ups on 
it. 
REDIRECT EXAMINATION 
BY MR. LINK: 
Q 
So, in your evaluation of the plaintiffs' 
cases, generically, I didn't hear you describe any 
aspect of the plaintiffs' past. Did you consider the 
plaintiffs' past? 
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A 
I did. 
Q 
You didn't say that when Mr. Scarola asked 
you. 
MR. SCAROLA: I disagree with you. I 
think that that was identified. But the 
record will speak for itself. That question 
is argumentive. 
THE WITNESS: I considered their past. 
BY MR. LINK: 
Q 
Okay. Talking generically. 
A 
Sure. For a bunch of reasons, not the least 
of which was how vulnerable were they before 
Mr. Epstein abused them, how easy pry were they. That 
factored big time into my assessment of the value of 
the cases. 
Q 
Did you factor into consideration other 
sexual activity that they may have had? 
A 
Sure. I took everything about them. 
Q 
Whether they had worked as prostitutors 
before? 
A 
Before meeting Jeffrey Epstein? 
Q 
Yeah. 
A 
I don't remember that ever being the case 
with any of them before meeting Jeffrey Epstein. That 
might have been right after. 
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Q 
Any of them ever worked at strip clubs 
before meeting Mr. Epstein? Those kind of factors --
A 
All of those things I will take into 
consideration. Every single one of these. These were 
just little girls, so, yes, 
into consideration. 
Q 
Did you take into consideration any of them 
having fake IDs that expressed an age of 18 or older? 
Did you take that into consideration? 
A 
That's ridiculous? That's just not true. 
Q 
You didn't? 
A 
There's, like, 100 underaged girls. That was 
not a factor in this case. It might be --
Q 
I'm asking if it's a factor you'd take into 
consideration generically. 
I didn't think Mr. Scarola asked you about 
a specific case. I said is this generic, and he 
said, yes, this is generic. 
A 
Are you talking about any case or just 
Jeffrey Epstein? 
Q 
No. He asked you about a generic case. 
A 
With Jeffrey Epstein? 
Q 
Yes. 
A 
Yes. Somebody having a fake ID, I think that 
that was, like, one of the defenses that somebody ran 
I took all of those things 
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early on, but it's not a factor to consider in this 
case. 
Q 
Okay. So that's not a factor you would 
have considered? 
A 
No. I would have considered it if that was 
true across the board. It just wasn't a factor in any 
case related to Jeffrey Epstein. 
Q 
Would you consider it a factor of any of 
the victims changing their testimony from when they 
spoke with the FBI until when they were -- when they 
retained a lawyer? Would that impact your evaluation 
of cases? 
A 
I took into consideration all of those 
circumstances. 
Q 
All of those kinds of things. 
How much did 
net from the settlement 
proceeds? 
A 
I don't remember. 
Q 
Of the gross amount of the 5.5, which 
portion was allocated to 
MR. SCAROLA: Excuse me. That assumes 
that there was a lump-sum settlement that 
involved an allocation among the three. 
MR. LINK: I was not suggesting it was 
a lump-sum at all. I just know the total 
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number is 5.5. 
MR. SCAROLA: When you talk about 
allocating a portion of the 5.5, that 
suggests --
MR. LINK: I will ask the question 
again. 
MR. SCAROLA: Okay. Thank you. 
BY MR. LINK: 
Q 
What was the settlement amount for 
A 
You know it as well as me. I believe 
$1 million. I could be wrong on that though. 
Q 
Mr. Scarola asked you a bunch of questions 
about the federal lawsuit and the statute of 
limitations. Are you telling us that you filed a 
245-page complaint to simply toll the statute of 
limitation? 
A 
It's only as long as it is because of the 
number of times that Jeffrey Epstein molested her. As 
you will see, it's just count after count after count, 
so that we captured the number of counts that would 
incorporate what he did to this particular person. 
If it was one of the females who had only 
gone to his house one or two times, it would be a 
much shorter complaint. It's being held against me 
that he molested so many times. 
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Q 
I asked you if it's true that you filed 
that complaint simply to toll the statute of 
limitations. That's what I asked. 
A 
And I've already explained that, yes, that's 
why we filed it, to toll the statute of limitations. 
Q 
And by filing it and not serving it, did 
that accomplish the goal you set out? 
A 
It did. Although, I ordered it to be served. 
I mean, I wanted that complaint served. 
Q 
Did you do anything -- did you believe it 
had been served? Was it your mental state when you 
left the Rothstein firm that that complaint had been 
served on Mr. Epstein? 
A 
I think I knew at that point in time that it 
hadn't been served yet. But the intention was to serve 
it, and I wanted it served on him at his house when he 
was in town. It just wasn't always easy to serve 
Mr. Epstein. 
Q 
Did you -- tell me what efforts you made to 
serve that complaint. 
A 
I don't remember. What I usually do is serve 
Q 
I don't want to know what you usually do. 
What did you do to serve that complaint? 
A 
I, like you, don't walk around serving 
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complaints, so I don't make efforts to serve anybody. 
I'm not a process server. I tell somebody I want it 
served, and hopefully they get a process server to 
serve the complaint. 
Q 
Who did you tell to hire a process server, 
sir? Who did you tell to hire a process server? 
A 
I don't remember who was doing that at RRA at 
that time. We are talking about eight years ago. 
Q 
Well, when you went -- started your own 
firm, the Farmer Jaffe firm, did you make efforts to 
serve the complaint? 
A 
I don't remember. 
Q 
Well, if you did, there would be some 
correspondence or communication, I assume, with a 
process server or somebody --
A 
I would think so. 
Q 
Do you still have the communications and 
files that relate to the 
federal court complaint 
during the time period at Farmer Jaffe? 
A 
I don't know. It is so not important to me 
right now. I don't know. 
Q 
But it was really important to you at the 
time, because of the statute of limitations and her 
21st birthday --
A 
We filed the complaint. We tolled the 
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statute of limitations. I don't need to serve it 
before then. 
Q 
You would have to serve it to prosecute it, 
right, and to recover under it? If the ultimate 
goal, based on what you told me, is to recover 
damages, then you can't accomplish that unless you 
serve the complaint, agreed? 
A 
You can accomplish that, but all you need to 
do is file the complaint before the statute of 
limitations run. That tolls the statute. 
Q 
Sir, I'm asking about recovering the 
damages. You gave us this whole litany of the 
damages that you wanted to recover, and that by doing 
this federal complaint you could recover money for 
on the statutory counts. And I'm asking you in 
order to accomplish the goal that you have told the 
jury during Mr. Scarola's questioning, didn't you 
have to first serve the complaint? 
A 
If we were going to go to trial on the 
federal case and not the state case, we would have had 
to serve the complaint, and we would have had to drop 
the state court case, go to trial on that complaint 
because we would have had to proceed against him 
exclusively under that count. So, yes, we --
Q 
You don't usually have to serve the 
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complaint until right before trial? 
A 
I didn't say that. 
MR. SCAROLA: He didn't say that. 
BY MR. LINK: 
Q 
You said if you were going to try it you 
would have to serve it. 
A 
You're just making things up. 
MR. SCAROLA: He didn't say anything 
like that. 
BY MR. LINK: 
Q 
So let me ask you this. When you filed 
that complaint, was it your intent to prosecute that 
action -- to move that action forward? 
A 
When I filed that complaint it was to 
preserve the statute of limitations in case we wanted 
to go forward on that case and not the state case. 
We were weighing, tactically, which way is 
better for III 
Q 
And did you make the decision to not pursue 
the federal court case before service was effected? 
A 
We ultimately made the decision to go forward 
on the state court cases with 
and with 
Q 
When was that decision made, sir? 
A 
I don't remember when that decision was made. 
Q 
Can you tell me approximately how long 
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after the complaint was filed that you made the 
decision to abandon it? 
A 
I don't know that we ever made the decision 
to abandon it. Like I said, it was all premised on 
this argument as to whether or not you are going to get 
a multiplier by the number of events. 
And I seem to remember that we started 
getting into the legal pleadings on that debate 
where Jeffrey Epstein was saying, no, it's $150,000, 
regardless of the number of times I molested 
anybody. And we were saying, No, you get the 
multiplier. You can't molest somebody one time, pay 
$150,000, and then get 99 free molestations. That 
was, at least, our argument. 
It was briefed in early 2010, I think, in 
the Jane Doe case, in response to a motion for 
summary judgment. And when that case settled, I 
don't believe that Judge Marra had yet ruled on that 
issue. In fact, I know that it was never ruled 
upon. We never got the answer to that question. 
So by that point in time, we had decided 
we're going forward on the state court cases with 
respect till.' and 
and we will go forward on 
the federal case with respect to Jane Doe. And if 
we win on that argument with Jane Doe, it may prompt 
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us to dismiss the counts that are not 2255 with 
respect to Jane Doe. That was what was going on in 
our mental processes with respect to how we were 
going to process -- prosecute these cases. 
Q 
So when did you withdraw the federal court 
action foil.? 
A 
I believe it was dismissed by stipulation as 
part of the settlement when Jeffrey Epstein paid III. a 
million dollars for molesting her. That's what I 
believe. 
Q 
So it sat there -- even though it wasn't 
served, you didn't dismiss the case until there was a 
settlement? 
You filed it, but you didn't serve it? 
A 
Right. I think that's right. It got 
dismissed in 2010 when he settled the cases, when he 
settled her --
Q 
So it just sat there without being 
prosecuted, the federal court case? 
A 
Yes. I think it got joined with the other 15 
or 16 cases for discovery purposes and whatever else, 
so I don't know about just sit there. It's not like a 
normal case where it just sits. 
Q 
Can you conduct discovery in a case before 
you serve it? Can you do that? 
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A 
What would discovery look like? It's still 
taking the same depositions of the same people, the 
same time. So we were conducting discovery on behalf 
of 
In the state court action, it would have 
looked exactly the same over here, which all would 
have been together with all of the other victims 
that he molested. So it wasn't like a single-act 
case where you are not getting to do anything. 
Everything else was happening. We weren't 
hamstrung. 
Q 
There wasn't anything happening for 
in 
the federal court, was there? 
A 
She's still the same person. Whether she has 
a case in the state court or the federal court, we 
still needed to conduct discovery against Jeffrey 
Epstein to prosecute the same type of case. 
Q 
So Scott Rothstein, what was his trial 
experience in the fall of 2009? 
A 
I was told from the time that I got there 
that he was this amazing employment lawyer, trial 
lawyer, and that's how -- that's how he had built this 
reputation as -- that he was the best employment trial 
lawyer in South Florida. 
Q 
So you practiced in Fort Lauderdale for 
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seven years before you joined the firm -- before you 
joined Rothstein's firm? 
A 
I mean, I was a prosecutor for three of those 
years, so you don't really know anybody. When you're a 
prosecutor you know -- that's a different world. 
Q 
You know criminals? 
A 
Yeah, you know criminals. Exactly. And then 
I was insurance defense attorney for the next three 
years. 
Q 
So you don't really know anybody? 
A 
Well, you just know a different world of 
people. It's not the same thing. I didn't run into 
Scott Rothstein. 
Q 
Had you ever heard of him? 
A 
No. I had not really heard of him. I mean, 
I heard of him from -- I had heard of the firm from 
Russ Adler. I worked out of the same gym as Russ, so 
he would tell me all the time how great the firm was 
and how great Scott was. Personally, I had no 
experience with the guy. 
Q 
When Mr. Rothstein decided he was going to 
be the lead trial lawyer, which case was that? 
A 
He didn't decide he was going to be the lead 
trial lawyer. You just make things up in questions all 
day long. 
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I was told that he was going to try the 
case with me. Period. Not more than, not less than 
that. That's just it. Not be the lead, not be the 
second, not be the third. 
Q 
Just try the case with you? 
A 
That's what I was told. 
Q 
And that was okay because he was head of 
the firm and he owned the files, right? 
A 
Correct. 
Q 
You were an employee, in your mind, and he 
was the lawyer ultimately at the firm responsible for 
the three clients, true? 
A 
There's seventy lawyers at the firm. They 
all work for him. Hundreds of files. He's still the 
equity partner of the firm, so they are the firm's 
files. They are not --
Q 
I understand. You told me earlier. And I 
didn't realize that, that the interest that Bradley 
Edwards, PA had in three files, you gave up to 
Mr. Rothstein and became a salary employee, 
essentially. 
A 
Gave up to RRA. 
Q 
Mr. Rothstein's firm, correct? 
A 
Right. We've established this. 
Q 
And so that Mr. Rothstein was the lawyer at 
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that firm as the -- one of two equity shareholders 
who was ultimately responsible for the three Epstein 
matters? 
A 
For every case in the entire firm, including 
those --
Q 
Including the three Epstein matters? 
A 
Every case, yeah. 
MR. LINK: I have no further questions. 
MR. SCAROLA: I have nothing further. 
We will read. 
THE VIDEOGRAPHER: The time is 6:16 
p.m., and that concludes this deposition. 
- - - 
(The deposition was concluded 
at 6:16 p.m.) 
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CERTIFICATE OF OATH 
STATE OF FLORIDA 
: SS 
COUNTY OF PALM BEACH ) 
I, the undersigned authority, certify that 
BRADLEY EDWARDS personally appeared before me and was 
duly sworn. 
WITNESS my hand and official seal this 13th 
day of November, 2017. 
Sonja D. Hall 
Commission No.: FF 082994 
Notary Public - State of Florida 
My Commission Expires: 2-01-18 
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