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or anybody else. 
Q 
What is it about Mr. Epstein 
you met 
Mr. Epstein in person, right? 
A 
Yes, several times. 
Q 
How tall is he, roughly? 
A 
Six-foot maybe. I have only read his sex 
offender profile. And I think it says six-foot on his 
flyer. 
Q 
How tall are you? 
A 
Five-ten. 
Q 
He's taller than you are? 
A 
I don't know that. I just remember seeing 
his sex offender -- that's what sticks out in my mind 
when I tell you the answer to that. I think it says 
six foot. 
Q 
Are you physically afraid of him, of 
Mr. Epstein? 
A 
Physically 
if I was in hand-to-hand combat 
with him would I be afraid of him? 
Q 
Are you in fear of him? Do you have a fear 
that he will cause a physical injury and he will hurt 
you? 
A 
In a fistfight? 
Q 
Generally, do you have a fear that he will 
cause you physical injury -- Mr. Epstein? 
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A 
In any sense of the word? 
Q 
Yes, sir. 
A 
If he personally? 
Q 
Yes, sir. 
A 
I don't fear that he personally is going to 
attack me at some point in time. I think I'm answering 
the question that you're asking. 
Q 
Do you think he's going to attack your 
family? 
A 
Do I think that Jeffrey Epstein is going to 
come to my house personally and attack me? No, I don't 
think that. 
Q 
Yes. 
You don't have that fear, do you? 
And this lawsuit was filed in December 
2009. From 2009 through to today, has Mr. Epstein 
threatened you with any physical harm? 
A 
Has he threatened me with physical harm? He 
has certainly said things to make it known to me that 
me or my family could be harmed. But again, not that 
he personally would do it. 
Q 
Tell me what he said to you that makes you 
think that Mr. Epstein was threatening to harm you 
physically. 
A 
I can almost tell you verbatim. 
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Q 
Please. 
A 
Brad, if you continue to prosecute these 
cases this way, somebody is going to get hurt. You are 
lucky that we are not litigating this in New York, 
because you know that I have a lot of friends, a lot of 
power. The fact that we are dealing with one another, 
I have so much more money than you and resources. This 
is not a fair fight. I could have you and your family 
under surveillance 24 hours a day. So think about that 
as you are prosecuting these cases. 
Those types of statements he made to me 
several times. 
Q 
When he said that, it sounds like he was 
talking about the disparity in economics. His 
ability to hire lawyers. But did you feel that he 
was physically threatening you? That he was going to 
physically hurt you? 
MR. SCAROLA: Excuse me. I'm going to 
object to the form of the question. I 
object to the predicate. It's argumentive. 
If the question is, Did you feel he was 
physically going to hurt you, that question 
is repetition. And also in the context of 
the discussion that has occurred, vague and 
ambiguous, because you are failing to 
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distinguish between what Mr. Epstein was or 
may have been threatening to do personally 
and what Mr. Epstein is capable of having 
been done. 
BY MR. LINK: 
Q 
So from December 2009 through today, have 
you been living in fear, sir, that Mr. Epstein 
personally, or otherwise, was going to cause physical 
harm to your body? 
A 
The "or otherwise," yes. The "personally," 
no. I don't think he's personally going to do any of 
the dirty work nor do I think he normally does. I 
think that he has people do those things for him. 
Q 
What do you think he has people do? 
A 
Whatever he wants done. 
Q 
I see. So you think that, based on your 
conversation with Mr. Epstein, that over the last 
eight years there was always this fear in your mind 
that somebody was lurking around and going to cause 
you physical harm, right? 
A 
The only problem with your question is based 
on your conversation. That's not the only reason that 
I think that. It's not based on my conversation with 
Epstein. It's based on the totality of the 
circumstances. 
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I mean, I had been involved in the 
investigation of Mr. Epstein and his conduct for 
many, many years. I know a lot about him. He knows 
I know a lot about him. I have talked to a lot of 
people about him, a lot of people who believe he's a 
very dangerous people. I believe he's a very 
dangerous person. He's made it pretty clear to me 
that he's a very dangerous person. 
Someone would be crazy not to have some 
form of fear that something could happen when you 
become a target of his. That lawsuit is a clear 
indication that I am a direct target of his. No 
doubt in my mind. 
Q 
I got it. 
So for the last eight years how many 
bodyguards have you hired? 
A 
Bodyguards? 
Q 
Yes, sir, to protect from you physical harm 
that Mr. Epstein is going to cause you or somebody 
else on his behalf. 
A 
I haven't hired bodyguards. But I don't 
think a bodyguard is going to do any good. 
Q 
So have you -- you never hired a bodyguard, 
right? 
MR. SCAROLA: That question was asked 
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and answered. 
BY MR. LINK: 
Q 
For you -- no bodyguards for you? 
A 
Per se, I have not hired a bodyguard. 
Q 
How about for your family? Have you hired 
protection to keep Mr. Epstein or somebody he knows 
from causing physical harm to them? 
A 
No, with the exception of there were times 
where I had an investigator who would -- when I knew 
that Mr. Epstein had investigators following me, I 
would have an investigator to watch out during those 
periods of time. I think it only happened twice. 
Q 
Well, you had investigators working on the 
Epstein case long before he sued you, didn't you? 
A 
Of course. 
Q 
You had former law enforcement officers on 
the team at Mr. Rothstein's firm investigating 
Mr. Edwards (sic), didn't you? 
A 
I am Mr. Edwards. 
Q 
I'm sorry. Mr. Epstein. Maybe they 
investigated you too. Who knows at that firm, right? 
Let me try it again. 
BY MR. LINK: 
Q 
Did you at Mr. Rothstein's firm --
MR. SCAROLA: I move that Counsel's 
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comments be stricken. 
MR. LINK: About the Rothstein's firm? 
That's fair. 
MR. SCAROLA: Thank you. 
BY MR. LINK: 
Q 
I think there's all kinds of security and 
things at Mr. Rothstein's firm we will get to, but 
let me try it again. 
While you were employed by Mr. Rothstein, 
you had former police officers that were used to 
investigate Mr. Epstein, correct? 
A 
While I was at RRA, investigators were 
investigating issues related to the Epstein cases, yes. 
Q 
Some of them were former law enforcement 
employees, right? 
A 
That's true. 
Q 
One was a former sheriff? 
A 
If you're talking about Ken Jenne, I don't 
know how much he did in investigating anything, but he 
worked there. 
Q 
Mr. Jenne was a former sheriff? 
A 
Mr. Jenne was a former sheriff. 
Q 
Did he have any issues of his own with law 
enforcement? Any procedures before he started 
working at Mr. Rothstein's firm? 
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A 
I believe that I know the same thing you do. 
Q 
What do you know? 
A 
He was arrested at some point in time when he 
was the sheriff. 
Q 
And you were aware of that when he was 
employed by Mr. Rothstein and working on the Epstein 
file? 
MR. SCAROLA: Excuse me. Objection, 
compound. 
BY MR. LINK: 
Q 
You can answer. 
A 
I was. 
MR. SCAROLA: That assumes facts not in 
evidence. 
THE WITNESS: I was aware that -- I was 
aware that he had been arrested when he was 
the sheriff. 
When I was working at -- at the time I 
was working at RRA, I knew that Ken Jenne at 
some time prior had been arrested while he 
was acting sheriff. 
BY MR. LINK: 
Q 
What other former law enforcement folks at 
Rothstein's firm were assigned as investigators on 
the Epstein matters? 
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A 
I worked with Mike Fisten. That was the 
investigator I communicated with. 
Q 
Tell me about Mike Fisten. What was his 
former role before he worked at Rothstein? 
A 
He was a Miami-Dade homicide detective. 
Q 
Did he have any issues before joining 
Mr. Rothstein's firm? 
A 
I don't know. 
Q 
Don't know. 
Does he still work for you? 
A 
No. 
Q 
Did he work for you after you left 
Mr. Rothstein's firm? 
A 
He did. 
Q 
For how long did he work for you? 
A 
I don't remember. 
Q 
Before you -- and that was at your own law 
firm. You started a law firm after Rothstein, right? 
A 
We started Farmer, Jaffe, Weissing, Edwards, 
Fistos & Lehrman basically right -- RRA imploded. We 
started that firm. 
Q 
And the investigator went with you? 
A 
He was an employee of ours. 
Q 
Did you do any background check on him 
before hiring him as an employee at your law firm? 
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A 
I knew his résumé. I mean, I knew that he 
was a Miami-Dade homicide detective. I knew that. I 
had talked to Pat Roberts, who also was an 
investigator, who had told me how highly credentialed 
Mike was. I had talked to Pat Diaz, who was also a 
Miami-Dade homicide detective. And all three of them 
did work for us after RRA. So these are all 
investigators that I knew and I still know them today. 
Q 
Did all of those investigators work on the 
Epstein matter? 
A 
To some degree, yes. 
Q 
How many investigators in total from the 
Rothstein firm and the subsequent firm, the Farmer 
firm, were involved in investigating Mr. Epstein? 
A 
Ever? 
Q 
Yes. 
A 
Over the course of time? 
Q 
Yes, sir. 
A 
The first investigator I used was Wayne 
Black. I don't know if Wayne did any work after we 
left RRA. The RRA period is -- you know, that's a 
six-month period that we are talking about. He 
definitely did work while I was at RRA. I don't know 
about after. He might have even done work before --
before I went to RRA. 
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Mike Fisten was the primary person -- the 
investigator that worked on the case while I was at 
RRA and also the primary investigator after. 
Mike then delegated to other investigators 
other work. I know for a fact that Pat Roberts was 
one of those people. And I also know that Pat Diaz 
was. 
Q 
So that's four investigators that were 
retained to investigate Mr. Epstein? 
A 
Yeah. Not altogether. Not all working 
together, but yes. Wayne Black didn't work with them, 
but yes. 
Q 
I'm just talking about the number --
A 
Yeah. 
Q 
-- of investigators. So four --
MR. SCAROLA: When you say retained to 
investigate Mr. Epstein, you're suggesting 
that the purpose for which they were hired 
was to investigate Mr. Epstein, or are you 
only asking whether at some point in time 
during their employment they investigated 
Mr. Epstein? 
MR. LINK: That question. 
THE WITNESS: Yeah. At some point in 
time those four people investigated 
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Mr. Epstein. 
BY MR. LINK: 
Q 
On your behalf? 
A 
What do you mean on my behalf? 
Q 
You were the lead lawyer in the Epstein 
files, right? 
A 
RRA paid them while there. They were just 
employees of RRA, same as me. And then afterwards, my 
next firm paid Mr. Fisten. He was our investigator 
after that. 
Q 
I asked a bad question. Let's go back to 
RRA for a minute. So you said these investigators, 
the three that you mentioned --
A 
Right. 
Q 
-- were employees of RRA? 
A 
I believe so. I don't know about Pat Diaz. 
He might have been contracted out by Mike Fisten for 
extra help. But Pat Roberts and Mike Fisten were 
employees for sure. 
Q 
So who was it at RRA that made the decision 
to bring in the first investigator, Mr. Wayne Black? 
A 
I think I did. I think I brought him in -- I 
think I was at least talking to him before I went to 
RRA. And then when I got to RRA, I don't believe there 
was already an investigative division in place. I 
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could be wrong about that. 
If memory serves me right, I don't 
remember there being -- Mike Fisten was the first 
investigator I communicated with there. I don't 
think he worked there yet. So I think that when I 
got there, I had already talked to Wayne Black, and 
he was initially retained by RRA, meaning, I think 
that they paid him. 
Q 
Let's see if I can help you with this --
the chronology. The lawsuits that -- the first three 
lawsuits that you filed against Mr. Epstein were 
filed by Bradley Edwards & Associates 
A 
Back in 2008. 
Q 
-- in 2008. 
A 
Right. 
Q 
Before you joined RRA in 2009, you did not 
use or pay for an investigator? 
A 
I don't know if that's right or wrong. It's 
right around that time where I was leaving one firm and 
starting another that I was talking to Wayne Black. I 
would have to look and see when his engagement letter 
was to know did I talk to him and then he was hired by 
RRA, or had I already hired him, you know let's say, 
March, and then I went to RRA in April. It's right in 
that time. I don't know. 
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Q 
Do you remember Bradley Edwards & 
Associates ever paying an investigator related to the 
Epstein matters? 
A 
I don't remember one way or the other. 
Q 
So if you did, it would have been at the 
very tail end of the Bradley Edwards law firm? 
A 
Correct. 
Q 
And then once you started at RRA, there 
were at least four different investigators that did 
some amount of work on the Epstein cases? 
A 
Including Wayne Black, who may have carried 
over from my firm. 
Q 
Right. When you look at Bradley Edwards & 
Associates, as you sit here, you don't remember 
whether you retained Wayne Black or not, right? 
A 
Right. I can do it this way, which probably 
helps you. Even if I retained him beforehand, I don't 
think he did any work on the Epstein case until after I 
was at RRA. That's how close in time that was. 
So, yes, there were four people that were 
investigators, at least, who did work on the Epstein 
file during the period of time that I was at RRA. 
Q 
And during that period of time, was about 
six months, there were at least four investigators 
that were assigned to work on the Epstein matter? 
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A 
Not exclusively, but yes. 
Q 
And you said at least four. Can you think 
of anybody else that was assigned to work on the 
Epstein matters at RRA? 
A 
Well, no. And I'm even including Pat 
Roberts, who I'm not sure was an employee there. I 
think that Mike Fisten brought him in for additional 
help. 
Q 
Let's not --
A 
When you assign, it's not like I'm assigning 
people or anybody is -- you know, I don't know that. 
Q 
Let's go back and try and do this again. I 
think we are both missing each other here. 
A 
Okay. 
Q 
It doesn't matter to me whether they were 
employees of RRA or contracted for. What I'm really 
trying to understand is, in the six months that you 
were at RRA, the number of investigators that --
during that six-month period -- spent any amount of 
time working on the Epstein matters. And you have 
identified four for me so far. Right? 
A 
Right. Here is where I think we are missing 
each other. The four -- those were four investigators 
that were working Epstein-related cases on behalf of 
clients 
and Jane Doe. I'm sure -- although 
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I don't know -- that of the other 15, 16, 17 lawsuits 
that were filed by Bob Josefsberg or Mr. Herman or 
Mr. Scarola, there were probably also investigators 
also working on Epstein cases. Just had nothing to do 
with me. 
Q 
I'm only asking about you, sir. I don't 
care who Mr. Scarola --
A 
If you go back and read back the question, 
that's not how it reads. It reads: Were these the four 
people who were working on the Epstein investigation? 
Q 
So let me try -- it was not supposed to be 
a trick question at all. 
When you started at RRA, you had three 
pending lawsuits against Mr. Epstein. 
A 
Right. 
Q 
While you were at RRA you added a fourth 
lawsuit against Mr. Epstein. 
A 
Fourth client. 
Q 
I said a fourth lawsuit. 
A 
Which one? 
Q 
You do not remember filing a lawsuit while 
you were with Mr. Rothstein's firm? 
A 
I filed many lawsuits against Mr. Epstein. 
Q 
I'm talking about the six-month period of 
time while --
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A 
I represented three clients while I was at 
Epstein (sic) for sure. While I was at RRA I 
represented three different clients. 
Q 
So while you were with Mr. Rothstein's you 
represented three individual clients that had 
lawsuits against Mr. Epstein? 
A 
Right. 
Q 
You also filed a fourth lawsuit while you 
were employed by Mr. Rothstein against Mr. Epstein, 
correct? 
A 
On behalf of 
who already had a state 
case against Mr. Rothstein (sic). 
It wasn't a new 
client. 
Q 
I didn't ask about client. Lawsuit. So 
you filed one lawsuit at RRA and three lawsuits 
before joining RRA? 
A 
Sure. 
Q 
And for those four lawsuits that you -- and 
you were the lead lawyer on those four suits. 
A 
Yes. 
Q 
And you were the lead lawyer at Brad 
Edwards & Associates? 
A 
Yes. 
Q 
And you were the lead lawyer at Rothstein's 
firm? 
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A 
That's your entire question? Was I the lead 
lawyer at Rothstein's firm? No. 
Q 
You were not the lead lawyer at Rothstein's 
firm for the three individuals that you brought with 
you that had lawsuits against Mr. Epstein. 
A 
On those cases, I was the lead lawyer. 
Q 
That's what we're talking about. 
A 
You just asked the question, Were you the 
lead lawyer at Rothstein's firm? 
Q 
On the three cases -- okay. Fair enough. 
A 
You just refuse to add that in. It's not 
going to read back right on the record. We are both 
lawyers here, we know what -- playing with words is not 
what I want to do today. 
Q 
If there's any part of what I'm doing that 
makes you uncomfortable or if you think I'm playing 
with words, just like that, just let me know and we 
will fix it. How is that? 
A 
I will. 
Q 
So for the four pending lawsuits while you 
were a six-month employee of Mr. Rothstein, there 
were at least four investigators that spent some 
amount of time investigating Mr. Epstein? 
A 
Yes. 
Q 
Are there possibly more than four 
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investigators during the six-month window for those 
four lawsuits that were utilized to investigate 
Mr. Epstein? 
MR. SCAROLA: Objection to the extent 
the question calls for speculation. 
THE WITNESS: There's possibly more 
investigators who investigated Mr. Epstein 
on behalf of either-or 
Jane Doe. 
BY MR. LINK: 
Q 
Can you tell me who those investigators 
were during the six-month period that you were 
employed by Mr. Rothstein? 
A 
I just told you the ones I recall. Is it 
possible there could have been more? There could have 
been. 
Q 
Who was it on the -- let me back up for a 
second. Was there a litigation team for the three 
clients that went from Bradley Edwards, PA to 
Mr. Rothstein's firm when you joined Rothstein's 
firm? Was there a team put together for those three 
clients? 
I know you were the lead lawyer for those 
clients at Rothstein's firm. 
MR. SCAROLA: The question included the 
phrase, When you joined the Rothstein firm. 
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I'm trying to understand are you asking 
whether at that time a team was assembled --
MR. LINK: Yes. 
MR. SCAROLA: -- or whether at any time 
subsequent to that time a team was 
assembled. 
BY MR. LINK: 
Q 
Was there a team. When you went over there 
with the three lawsuits, was there a team that worked 
on those three matters. 
A 
I did not take a team over to the Rothstein 
firm. 
Q 
And when got to the Rothstein firm, who was 
assigned to help you with the three clients that were 
suing Mr. Epstein? 
A 
So the way that RRA was set up, there were 
divisions. And there was a tort division there. 
Q 
So were you assigned to the tort division? 
A 
I was one of the tort lawyers who was there. 
I primarily worked the cases. I also had other legal 
minds within the law firm that would bounce ideas 
around, cover hearings. The one that probably 
participated the most on an active basis was Bill 
Berger. 
I don't remember when he joined the firm. 
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