EFTA00800508

1 
IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT, IN 
AND FOR PALM BEACH COUNTY, FLORIDA 
Case No. 502009CA040800XXXXMB 
JEFFREY EPSTEIN, 
Plaintiff, 
vs. 
SCOTT ROTHSTEIN, individually; 
BRADLEY EDWARDS, individually, 
Defendants/Counter-Plaintiffs. 
VOLUME I 
VIDEOTAPED DEPOSITION 
OF 
BRADLEY EDWARDS 
Taken on Behalf of Plaintiff 
Friday, November 10th, 2017 
10:02 a.m. - 6:16 p.m. 
2139 Palm Beach Lakes Boulevard 
West Palm Beach, Florida 33409 
Examination of the witness taken before 
Sonja D. Hall 
Palm Beach Reporting Service, Inc. 
1665 Palm Beach Lakes Boulevard, Suite 1001 
West Palm Beach, FL 33401 
Palm Beach Reporting Service, Inc. 
EFTA00800508

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APPEARANCES: 
For Plaintiff: 
LINK & ROCKENBACH, P.A. 
1555 Palm Beach Lakes Boulevard, Suite 301 
West Palm Beach, FL 33401 
By SCOTT J. LINK, ESQUIRE 
By KARA BERARD ROCKENBACH, ESQUIRE 
For Plaintiff: 
ATTERBURY, GOLDBERGER & WEISS, P.A. 
250 Australian Ave. South, Suite 1400 
West Palm Beach, FL 33401 
By JACK A. GOLDBERGER, ESQUIRE 
For Plaintiff: 
DARREN K. INDYKE, PLLC 
575 Lexington Avenue 
New York, NY 10022 
By DARREN K. INDYKE, ESQUIRE 
For Defendants/Counter-Plaintiffs: 
SEARCY, DENNEY, SCAROLA, BARNHART & 
SHIPLEY, P.A. 
2139 Palm Beach Lakes Boulevard 
West Palm Beach, FL 33409 
By JACK SCAROLA, ESQUIRE 
By DAVID P. VITALE, JR. 
ALSO PRESENT 
Visual Evidence, Incorporated 
601 N. Dixie Highway, Suite A 
West Palm Beach, Florida 33401 
By Andrew Mazoleny, Videographer 
Tina Campbell, Paralegal 
Palm Beach Reporting Service, Inc. 
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INDEX 
Videotaped Deposition of BRADLEY EDWARDS 
Page No. 
Direct Examination by Mr. Link 
8 
Cross-Examination by Mr. Scarola 
310 
Redirect Examination by Mr. Link 
325 
Certificate of Oath 
340 
Certificate of Reporter 
341 
Read & Sign Letter to Witness 
342 
No. 
PLAINTIFF'S EXHIBIT INDEX 
Description 
Page No 
1 
Affidavit of Jeffrey Epstein 
92 
2 
News Article 
96 
3 
News Article 
100 
4 
News Article 
112 
5 
News Articles 
145 
6 
Complaint 
147 
7 
Complaint and Demand for Jury Trial 
171 
8 
Email 
178 
9 
Complaint 
179 
10 
Answer and Counterclaim 
185 
11 
Letter 
189 
Palm Beach Reporting Service, Inc. 
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12 
RRA Firm Directory 
190 
13 
Email 
190 
14 
Jane Doe motion 
220 
15 
Email 
231 
16 
Order 
238 
17 
Fourth Amended Counterclaim 
239 
18 
Email 
259 
19 
Email 
264 
20 
Email 
267 
21 
Seventh Amended & Supplemental Witness List 268 
22 
Expert Witness Report (Jansen) 
284 
23 
Brad Edwards Time 
290 
24 
National Crime Victim Bar Association 
297 
25 
Brad Edwards' Accolades 
300 
DEFENDANTS/COUNTER-PLAINTIFFS' EXHIBIT INDEX 
(No exhibits were marked.) 
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THE VIDEOGRAPHER: This is the 10th day 
of November 2017. The time is 10:03 a.m. 
This is the videotaped deposition of 
Bradley Edwards, Esquire, in the matter of 
Epstein versus Rothstein and Edwards. 
This deposition is taking place at 2139 
Palm Beach Lakes Boulevard, West Palm Beach 
33409. 
My name is Andrew Mazoleny. I am the 
videographer representing Visual Evidence, 
Incorporated. 
Will the attorneys please announce 
their appearances for the record? 
MR. LINK: Scott Link on behalf of the 
plaintiff. 
MS. ROCKENBACH: Kara Rockenbach on 
behalf of the plaintiff. 
MR. INDYKE: Darren Indyke on behalf of 
the plaintiff. 
MR. GOLDBERGER: Jack Goldberger on 
behalf of the plaintiff. 
MS. CAMPBELL: And Tina Campbell 
parallel on behalf of the plaintiff. 
MR. SCAROLA: Jack Scarola and David 
Vitale representing Bradley Edwards, who is 
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the counter-plaintiff in this action; and 
for all practical purposes, the plaintiff in 
the claim against Jeffrey Epstein. 
THEREUPON, 
BRADLEY EDWARDS, 
being a witness in the notice heretofore 
filed, and being first duly sworn in the above cause, 
testified on his oath as follows: 
THE WITNESS: I do. 
MR. SCAROLA: Before we begin the 
substantive questioning, I want to make it 
clear on the record as a consequence of an 
exchange of communications that has occurred 
with opposing counsel, opposing counsel has 
taken the position that Mr. Edwards is going 
to be deposed as if he had never been 
deposed before, that is, opposing counsel 
recognizes no restrictions on the scope of 
this deposition. 
The scope of the deposition was the 
subject of a lengthy hearing before Judge 
Hafele that took place on Tuesday, 
October 3rd, 2017. 
During the course of that hearing the 
Court made it very clear that questioning 
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would be limited to four specific areas 
identified by the Judge: The filing of a 
federal lawsuit on behalf of LM, which was 
based upon facts that also supported the 
filing of a state court claim; interaction 
between Mr. Edwards and Mr. Rothstein and 
others at Rothstein, Rosenfeldt Adler that 
would relate to any potential knowledge that 
Mr. Edwards had or should have had with 
regard to the conduct of a Ponzi scheme by 
Mr. Rothstein; the filing of a motion 
seeking the posting of a $14 million bond 
and issues relating to damages. 
We are here for purposes of responding 
to questions in those specific areas as 
directed by the Court. It is our intention 
to allow opposing counsel broad latitude 
within those four areas. But we will raise 
appropriate objections to any inquiries that 
are outside those four areas, unless it can 
be demonstrated that in some manner I have 
misread, in spite of careful review, the 
transcript of that hearing and the ruling of 
the Court. 
So my suggestion is, if opposing 
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counsel continues to take the position that 
this deposition is going to be conducted as 
if Mr. Edwards had never been deposed 
before, that we should at least deal with 
those four areas as to which there is 
agreement for inquiry, then we will worry 
about whether any inquiry outside those four 
areas will be allowed. Thank you. 
MR. LINK: Obviously we disagree and we 
are ready to proceed. 
DIRECT EXAMINATION 
BY MR. LINK: 
Q 
Ready, Mr. Edwards? 
A 
Ready. 
Q 
Are you feeling anxiety today? 
A 
Sure. 
Q 
Tell me about it. What anxiety do you feel 
today? 
A 
I'm still -- I'm still being accused for 
committing crimes that I didn't commit, and this case 
is my only chance to finally set that record straight. 
Q 
So tell me about the anxiety, though. What 
are you feeling? Anxiety is an emotional reaction to 
something, correct? 
A 
Well, for today 
Palm Beach Reporting Service, Inc. 
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Q 
Yeah. 
A 
-- I think that if you sit in this chair and 
I ask you questions, you would have anxiety as well. 
Q 
Okay. So you have anxiety today about my 
asking you questions. Is that what the anxiety is? 
A 
No. It's about getting this case over. 
Q 
So you have anxiety about the length of 
time the case has been pending? 
A 
Well, with everyday it's worse. I want the 
case over, and I want to right the wrong that's been 
done. So the fact that I have a whole team of lawyers 
over there -- I don't think Mr. Goldberger does it 
anymore -- but there's lawyers on that side who 
continue to falsely claim that I was part of a Ponzi 
scheme. 
In fact, Tonja Haddad just did it a month 
ago. 
Q 
So I don't see Tonja or her dad sitting 
here. Do you? 
A 
You are all together. You are all 
representing --
MR. SCAROLA: Excuse me. Pardon me. 
Would you please allow Mr. Edwards to 
complete his answer? 
Palm Beach Reporting Service, Inc. 
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BY MR. LINK: 
Q 
Yes, sir. Go ahead. 
A 
You also decided to sign on and represent a 
serial child molester, so you have adopted that 
position. 
Q 
Okay. Anything else to add to that? 
A 
No. 
Q 
So you see the lawyers that are here. 
Ms. Rockenbach is with my new law firm, Link & 
Rockenbach, correct? 
A 
I got your card the other day. Thank you. 
Q 
How did it look? 
A 
Pretty good. 
Q 
Pretty good? How about really good? 
A 
I only looked at one side. Sorry. I will 
check it out. 
Q 
Ms. Rockenbach is with me. You see that. 
Mr. Goldberger is down at the end of the table, 
right? And Tina, who is a legal assistant at my 
firm. Tonja Haddad is not here, is she? 
A 
There isn't just a table long enough, I 
assume. But, no. 
Q 
Your lawyer hasn't shared with you -- you 
haven't seen -- heard that they are withdrawing from 
the case? 
Palm Beach Reporting Service, Inc. 
EFTA00800517

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A 
No. 
MR. SCAROLA: Excuse me. Has there 
been a notice of withdrawal? Because I 
haven't seen it either. 
MR. LINK: I think we represented it to 
Judge Hafele on Wednesday with the 8:45 when 
Kara was in front of them. 
MR. SCAROLA: I have seen no notice of 
withdrawal. So as we sit here today, there 
are a total of, I think, six law firms that 
are representing Mr. Epstein. 
BY MR. LINK: 
Q 
And one really good one. The one you saw 
the card on this week, right? 
Okay. So I want to focus on this anxiety. 
We all have anxiety in life, right? I wake up every 
morning with anxiety about something. How my kid's 
doing in college. Did he get home last night. Is 
my son going to get a hit today on the baseball 
team. 
I want to talk about a different kind of 
anxiety. The anxiety that you feel in November 2017 
that relates back to the lawsuit that was filed in 
December 2009. Can you separate that anxiety that I 
am talking about? 
Palm Beach Reporting Service, Inc. 
EFTA00800518

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with. 
A 
Just an anxious feeling to get this over 
Q 
And you had that anxious feeling every 
single day from December 2009 through today 
November 10th, 2017? 
A 
The more reminders that I have of the case, 
and the fact that there still looms this false 
allegation over my head, that is clearly a trigger. 
Q 
You said it looms this false allegation. 
What is the false allegation looming over your head? 
A 
That I was a participant in a Ponzi scheme 
with one of the individuals that might be the most 
hated person in South Florida, especially amongst our 
profession. 
Q 
Mr. Rothstein? 
A 
Right. 
Q 
But why is there an allegation hanging over 
your head? The case against you was dismissed in 
2012, correct? 
MR. SCAROLA: Excuse me. Which case? 
BY MR. LINK: 
Q 
The case against you by Mr. Epstein was 
dismissed in 2012, was it not? 
A 
Right. The case was dismissed. 
Q 
Five years ago the case was dismissed, 
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true? 
A 
Yes. 
Q 
So what I'm trying to understand is, you 
said that this was hanging over your head. Since 
2012 there has not been a pleading that was alive in 
circuit court from Mr. Epstein directed at you, true? 
Since 2012? 
A 
Has there -- was there a pleading against me 
since 2012. 
Q 
Yes, sir. 
A 
The answer to that question is no. 
Q 
So 2012, this allegation, that you said was 
hanging over your head, has been removed, true? 
A 
The complaint was dismissed. 
Q 
Right. That was the allegation. And that 
complaint has been dismissed. 
MR. SCAROLA: Compound. 
THE WITNESS: You are asking two 
different things. 
BY MR. LINK: 
Q 
Well, you said --
A 
The allegation was made. 
Q 
In 2009. 
A 
-- and 9 million people read that allegation. 
And --
Palm Beach Reporting Service, Inc. 
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Q 
We are going to get to all of that. 
MR. SCAROLA: Excuse me. 
THE WITNESS: If you don't want me to 
answer the question, then don't 
then ask 
a question, I will answer, and you can shape 
it however you want. 
If you want me to give you an answer, 
I'm willing to sit here and give you a full 
answer. 
BY MR. LINK: 
Q 
I do. And I asked you if there has been a 
pleading making those allegations since 2012. 
A 
That's not the question that you asked. But 
is that now the question that you are asking? 
Q 
Yes. 
A 
Sure. Pleadings have been filed, including 
by Mr. Epstein's long-time recruiter of girls for him, 
Ms. Maxwell. She made an allegation -- the same 
allegation as part of a motion to recuse me as trial 
counsel in a totally separate case. 
Q 
What case was that you just brought up? 
A 
versus Maxwell. 
Q 
Where was that case pending? 
A 
In New York. 
Q 
And you were counsel in that case? 
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A 
Yes. 
Q 
Are you admitted in New York? 
A 
I was pro hac. 
Q 
Who was the admitted lawyer in New York? 
A 
David Boies. 
Q 
So you and Mr. Boies worked on that case 
together? 
A 
Yes. 
Q 
How did Mr. Boies get involved? 
A 
We co-represented 
, who is 
also one of Mr. Epstein's victims. 
Q 
Okay. Talking about the case you just 
mentioned to me where you said Ms. Maxwell -- is that 
right? 
A 
Yes. 
Q 
-- filed a pleading. Was Mr. Epstein a 
party in that case? 
A 
He had a joint defense agreement with her, so 
he was -- he was basically advising her behind the 
scenes. So for lack of a better word, he was basically 
a party to the case. 
Q 
So you have been practicing how many years 
now? Fifteen? 
A 
Yeah. 
Q 
And you know what a party to a case is, 
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right, in a civil lawsuit? 
A 
I do. 
Q 
Was Mr. Epstein a party in that lawsuit? 
A 
A party in the sense was he in the style of 
case, he was not. 
Q 
Do you know what a party is in a lawsuit? 
A 
Do you? 
Q 
Yes, sir, I do. 
A 
Okay. So right before trial we had an 
argument that I believe was going to go in our favor 
that we were going to be able to use his --
Mr. Epstein's Fifth Amendment invocation against 
Ms. Maxwell, because of the LiButti factors, and 
because he was basically a party and interest to the 
case. 
Was he in the style of the case? He was 
not. But because they were so tightly connected as 
conspirators, his interests were so intertwined with 
hers, that we were going to be able to use his Fifth 
Amendment invocation against her, which is a very 
unusual and atypical situation. 
Q 
Sounds like an interesting evidentiary 
issue. 
A 
Agreed. 
Q 
In that case, who brought the client to 
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whom? Did you have the client and you went to 
Mr. Boies, or did Mr. Boies have it and he came to 
you? 
A 
I represented 
first. 
Q 
What made you go to David Boies? 
MR. SCAROLA: You don't need to answer 
that question. We object on the basis of 
work product. 
BY MR. LINK: 
Q 
Other than work product, was there a reason 
that you went to Mr. Boies for this 
what type of 
case is it, by the way? I'm sorry. The case that 
you filed. 
A 
When David Boies became involved with 
-- it's a complicated question, 
because as a client in the case that was brought 
the 
defamation case -- she was David Boies' client before 
mine. In a more general sense, in terms of who 
represented 
first, myself or Mr. Boise, I did. 
I represented her in the Crime Victims' Rights Act 
case. 
Q 
Here in Florida? 
A 
Here in Florida. 
Q 
Yes, sir. 
A 
David and David's firm filed the defamation 
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action and represented her in the defamation action 
before bringing me in. 
Q 
Who did Ms. Roberts sue in the defamation 
action? 
A 
Ghislaine Maxwell. 
Q 
They did not sue Mr. Epstein? 
A 
No. 
Q 
And they brought you into the case after it 
was filed to provide assistance? 
A 
Correct. 
Q 
So David Boies hires you in Florida to help 
him prosecute the case; is that right? 
A 
When you say the case, we are talking the 
defamation action? 
Q 
The defamation case, yeah. Dave Boise's 
firm --
A 
We are talking multiple cases, so I just want 
to make sure that we make the question and the answer 
clear. Yes, defamation case he brought me in. 
Q 
So David Boies filed the defamation action 
and made the decision to co-counsel with you in 
Florida to help him in New York; is that right? 
A 
He made the decision to co-counsel with me. 
Q 
In a New York case? 
A 
In a New York case. 
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Q 
Got it. Okay. 
In that case, Mr. Boies had represented 
in a prior proceeding other than a 
defamation action, or only in the defamation action? 
A 
I am trying get the timing. He represented 
her in another proceeding. Whether it was a prior 
proceeding --
Q 
What was the other proceeding? Then we 
will figure out the chronology. 
A 
He represented her as a witness. 
Q 
In what case was that? 
A 
In a defamation action I filed against Alan 
Dershowitz. 
Q 
You're right. It is completed. 
So the first action that gets filed is you 
sued Alan Dershowitz? 
A 
Right. 
Q 
For defamation? 
A 
Right. 
Q 
That case has been dismissed, right? 
A 
Right. 
Q 
In that case 
was a witness? 
A 
She was subpoenaed by Dershowitz to be a 
witness. 
Q 
And she hired David Boies to represent her? 
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A 
Correct. 
Q 
As a witness? 
A 
Right. 
Q 
And was she deposed in that case? 
A 
She was. 
Q 
And Mr. Boies was there to represent her? 
A 
Someone from his firm was there to represent 
her. 
Q 
Then as a result of that, he ended up 
representing -- Mr. Boies ended up representing her 
in her own defamation case? 
A 
Right. I'm not sure that the chronology is 
exactly that, whether her deposition came first or the 
defamation action came first. In fact, I think the 
defamation action was filed before her deposition in 
the other case, but that's why this just gets a little 
complicated. 
Q 
The chronology is complicated? 
A 
Right. 
Q 
I got it. 
Now, is that case still pending, the 
defamation case? 
A 
No. 
Q 
That case has been resolved? 
A 
Settled in May, I believe, of this year. 
Palm Beach Reporting Service, Inc. 
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