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Whatever is easiest for you. 
MR. LINK: Okay. We can go off the 
record. 
THE VIDEOGRAPHER: The time is 
2:22 p.m. This is the end of tape two. We 
are going off the record. 
(A recess was had.) 
THE VIDEOGRAPHER: The time is 
2:34 p.m. This is the beginning of tape 
three and we are back on the record. 
BY MR. LINK: 
Q 
Okay. Mr. Edwards, you were going to go 
through the Exhibit Number 9, which was the 
December 7th, 2009 complaint filed by Mr. Epstein 
against Scott Rothstein, Bradley Edwards andllill 
and you were going to highlight the paragraphs that 
caused injury to your reputation. 
A 
The complaint as a whole. 
Q 
The entire complaint? 
A 
The entire complaint 
This is a complaint 
that says that Scott Rothstein and I ran a Ponzi scheme 
in which we together committed many federal crimes and 
state crimes and fabricated cases and committed bar 
violations and were guilty of conspiracy and RICO, and 
fraud and conspiracy to commit fraud. 
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It reads like a federal indictment. And 
there's no way to take pieces out of it that would 
not injure somebody, because as a whole, this is 
about as damaging to any lawyer's reputation as it 
possibly could be, and it was intended to do that. 
When I read back over it, I just remember 
how unbelievably painful it was when I received it 
and how I still feel today as a consequence of the 
things that were put out there. 
This is a criminal indictment against me. 
That's what this is. 
Q 
Can you point to the paragraphs, please, 
that you just read through that contain the 
inaccurate statements you just referred to? 
A 
Start from the beginning. 
Q 
So if I read the summary of the action, 
tell me what's inaccurate about that. What's untrue 
about the summary of the action, sir? 
A 
These are statements that are consumed within 
the counts at the back, which I'm part of every one of 
those counts, so this applies to me. None of it is 
true as it pertains to me. 
Q 
I asked you to point out in the summary of 
the action what is untrue. Can you take a look at 
that and tell me --
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A 
Scott Rothstein aided by others. The clear 
implication is that the others are me and 
Q 
Does it say that there? 
A 
It does. That's what a complaint is. It's 
adopting everything into the count at back of this 
complaint. The whole thing is about me. 
Q 
It is? So is III. a lawyer? 
A 
No. She's one of the females that 
Mr. Epstein molested, and in this complaint alleges 
that she wasn't molested and she was somehow 
fabricating her claim against him. 
Q 
Did III. authorize the 234-page complaint 
we looked at that was Exhibit Number 7? 
A 
Yes. 
Q 
She authorized that filing? 
A 
Yes. 
Q 
So when I look at Summary of Action, first 
sentence, it says, "Attorney Scott Rothstein aided by 
other lawyers and employees at the firm" ... "for 
personal greed enrichment." 
Where does it talk about III. in there? 
Does it? 
A 
It's about me. 
Q 
Well, you said you and III. When you said 
how this impacts you, you said other lawyers like me 
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and III. That's what you said. 
MR. SCAROLA: No. 
THE WITNESS: That's not what I said. 
That's fine. 
BY MR. LINK: 
Q 
Then I heard you wrong. 
So in the Summary of Action, do you see 
your name in there? 
A 
My name is in the style of the case. 
Q 
I know that, sir. I'm asking you about the 
summary of the action. 
A 
It speaks for itself. Whether my name is in 
there generally or specifically, that's what this 
complaint is talking about. And this complaint is 
clearly designed to talk about me throughout the entire 
case. Sometimes specifically, sometimes generally. 
Q 
No question you're a defendant. And I'm 
asking you what in the Summary of Action is an untrue 
statement? 
A 
Those things in the summary of the action, I 
did not do. 
Q 
I don't see that it says that you did in 
the summary of the action. 
MR. SCAROLA: Objection, argumentive. 
THE WITNESS: It does. You can't just 
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EFTA00800691

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take this piece. The whole complaint refers 
to itself. 
BY MR. LINK: 
Q 
So can you point to a single sentence in 
the Summary of Action that is an untrue statement? 
A 
Sure. 
Q 
Which one? 
A 
All of it as it pertains to me. 
Q 
Look at paragraph six. Can you tell me why 
you denied being an employee, agent or associate or 
partner, shareholder or other representative of RRA? 
A 
You have my answer? 
Q 
I do. 
Take a look at Exhibit 10, which is the 
answer and counterclaim of defendant Bradley 
Edwards, which was date stamped December 21st, 2009, 
and I believe it was filed with the clerk on the 
17th of 2009. Okay? 
A 
I think this would invade the attorney-client 
privilege to tell you why. 
(Plaintiff's Exhibit Number 10 was marked 
for identification.) 
BY MR. LINK: 
Q 
Why you denied --
A 
Yes. 
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Q 
-- being a partner at RRA? 
A 
Okay. I wasn't a partner at RRA, so that's 
one reason. 
Q 
So you weren't a partner at RRA? 
A 
I was not. 
Q 
So for the six months that you were 
employed there, you did not hold yourself out as a 
partner of the Rothstein firm; is that true? 
A 
You are asking a different question. What 
I'm saying is --
Q 
Okay. 
A 
I don't understand the faces, but --
Q 
Let me start over. Did you hold yourself 
out as a partner of the Rothstein law firm? 
A 
This is something that we have gone over in 
prior depositions. We are just rehashing what other 
lawyers have asked me and I've explained this in 
detail. 
MR. SCAROLA: And because that is in 
fact the case, and because that is clearly 
outside the scope of the admitted areas of 
inquiry for this deposition, I am going to 
instruct Brad not to answer. 
BY MR. LINK: 
Q 
Were you an employee of the Rothstein firm? 
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EFTA00800693

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MR. SCAROLA: Same objection. Same 
instruction. 
BY MR. LINK: 
Q 
Were you an associate of the Rothstein 
firm? 
MR. SCAROLA: Same objection. Same 
instruction. 
BY MR. LINK: 
Q 
Did you get paid by the Rothstein firm for 
the six months that you worked there? 
MR. SCAROLA: Same objection. Same 
instruction. 
BY MR. LINK: 
Q 
Were you paid as a W-2 employee or a 1099 
employee? 
MR. SCAROLA: Same objection. Same 
instruction. 
BY MR. LINK: 
Q 
Did you have a website for Jeffrey (sic) 
Edwards & Associates? 
MR. SCAROLA: Did you mean that 
question as you asked it? 
MR. LINK: I think so. 
MR. SCAROLA: No, I don't think so. 
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EFTA00800694

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BY MR. LINK: 
Q 
Your answer is no? 
MR. GOLDBERGER: Change the first name. 
MR. LINK: I'm sorry. You're right. 
Thank you. 
BY MR. LINK: 
Q 
Did you have a website for Bradley Edwards 
& Associates? 
A 
I don't think so. 
Q 
When you would sign letters while you were 
at the Rothstein firm, did you ever sign as a partner 
of that firm? 
MR. SCAROLA: Same objection. Same 
instruction. 
BY MR. LINK: 
Q 
Do you agree that it would have been 
reasonable for a person who was not within the 
Rothstein firm to conclude that you were a partner of 
that firm? 
MR. SCAROLA: Question calls for 
speculation and is an incomplete 
hypothetical. 
THE WITNESS: I don't know what would 
have been reasonable for somebody to infer 
in terms of how anyone was paid or whether 
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EFTA00800695

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they shared equity according to any title. 
BY MR. LINK: 
Q 
I am going to show you Plaintiff's Exhibit 
Number 11. 
(Plaintiff's Exhibit Number 11 was marked 
for identification.) 
BY MR. LINK: 
Q 
Can you tell us what Exhibit 11 is, please? 
A 
It's a letter about depositions that were 
already set by other plaintiff counsel and depositions 
that we intended to take, in addition to those that 
were already set. 
Q 
What day is this letter? 
A 
July 22nd, 2009. 
Q 
Is it referencing any particular cases you 
were working on. 
A 
I don't see it, but it's representing 
it's 
Epstein -- it's Epstein related. 
Q 
Epstein related. All right. And how did 
you sign that letter? 
A 
Um. 
Q 
What does the signature block say, sir? 
A 
That's my signature, but --
Q 
What does the signature block say? 
A 
Rothstein Rosenfeldt Adler, Bradley J. 
Palm Beach Reporting Service, Inc. 
EFTA00800696

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Edwards, Esquire, Partner for the Firm. 
Q 
And who signed that letter for you? 
A 
I don't know. 
Q 
Take a look at Exhibit 12 and go to page 
five, please. 
(Plaintiff's Exhibit Number 12 was marked 
for identification.) 
BY MR. LINK: 
Q 
Exhibit 12 is the Rothstein Rosenfeldt 
Adler Firm Directory Updated: October 23rd, 2009. Do 
you see your name listed under Attorneys and Staff on 
page five. 
A 
Yes. 
Q 
What is your title, sir? 
A 
It says partner. I have never seen this 
document before, but that's what it says. 
Q 
Did you have an employment with the 
Rothstein firm? 
A 
Again, something else that has been asked in 
previous depositions, but the answer, again, is no. 
Q 
Take a look at Number 13. 
(Plaintiff's Exhibit Number 13 was marked 
for identification.) 
BY MR. LINK: 
Q 
This is a May 22nd, 2009 email from Bradley 
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J. Edwards to somebody at the Palm Beach Post, right? 
A 
It appears to be a writer, I'm assuming, at 
the Palm Beach Post. I don't remember her. 
Q 
So back in May 2009, you were corresponding 
with a writer at the Palm Beach Post about the 
lawsuit, Jane Doe versus United States of America? 
A 
Yeah. I'm telling that person that the 
non-prosecution agreement was released pursuant to 
protective order, so I can't discuss the contents of 
the non-prosecution agreement. I'm assuming that 
reporter called asking about the contents. 
Q 
What does the signature block say? 
A 
I'm not contesting that the signature block 
probably always said Bradley Edwards, Partner, 
Rothstein Rosenfeldt Adler. I would guess everything 
that was signed there probably said that. 
Q 
So you held yourself out as a partner in 
the law firm, true? 
A 
What does partner mean between us? I mean, a 
partner is an equity partner. In a business, I was 
not, nor did I ever tell anybody that I was. Lawyers 
in the law firm, all -- almost all went by either 
partner or shareholder, with very few exceptions. 
So partner was an informal title that 
indicated I carried my caseload as opposed to I 
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worked on somebody else's cases. 
I was never an equity partner. I never 
acted like I was an equity partner. I never told 
anyone I was an equity partner, which in the sense 
of a business is what an actual partner is. 
So that's the full and complete answer. 
Did it say partner as opposed to just mere employee 
or whatever else it would say? Yes, that's what it 
said. 
Q 
Did you ever clarify when you were having 
conversations with these folks that you just 
mentioned that you never said I'm an equity, I'm an 
owner, so on and so forth; that you were simply an 
employee of the firm? 
A 
Sure. With anyone that I had these 
discussions with, including Michael Pike, who was one 
of Mr. Epstein's lawyers. We talked about the 
arrangement there, and including whether he would want 
to come over to RRA at some point in time. 
Q 
Tell me what you told him about the 
arrangement there and why he might want to come over? 
A 
It's a good law firm. It's a good law firm. 
You get a lot of help. There's sufficient staff. You 
will like it. You don't have to represent pedophiles. 
You can actually be on the other side of the cases. 
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EFTA00800699

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And at the time I didn't think that he was a bad guy, 
and he -- and we had those types of conversations. 
Q 
And you said to him, they will give you the 
title partner but it doesn't really mean you're a 
partner, but you get to hold yourself out to the 
public as though you're a partner? Did you talk to 
him about? 
A 
Nobody says that. 
Q 
The conversation you had with Mr. Pike must 
have been before the lawsuit was filed against you in 
December. 
A 
I said it was while I was at RRA, which was 
before the lawsuit was filed against me in December. 
Q 
Now, if you would, please, turn to page --
A 
Which exhibit are we looking at? 
Q 
Huh? 
A 
Which exhibit? 
Q 
We are on Exhibit 9, the complaint, which 
you said the entire thing has caused damage to your 
reputation, right? And did it --
Let's back up for a second. When did you 
receive a copy of this complaint? 
A 
I don't remember. 
Q 
Were you personally served with it? 
A 
Yes. 
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Q 
Where were you served at? 
A 
I believe at a restaurant. 
Q 
Which restaurant? 
A 
I don't remember. 
Q 
How many times have you been served by --
have you been served with a complaint? 
A 
This is the only one that's memorable to me. 
But we talked about a complaint previously. 
Q 
Talked about several. 
A 
I presume that I was served. I don't 
remember being served, but I'm sure there's a 
certificate of service where I was. Or if there was 
substitute service at a law firm or something else, 
that's possible too. 
This complaint, though, I remember that I 
was personally served. I am not sure exactly where 
I was. 
Q 
the 7th? 
A 
Your guess is as good as mine on that. 
Q 
If you look at the counterclaim that was 
prepared, do you remember when you started drafting 
that? 
Were you served on the 7th or was it after 
A 
No. 
Q 
How long after you received a copy of the 
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complaint that was filed on December 7th did you 
start drafting the counterclaim? 
If we're looking at the counterclaim -- do 
you have that in front of you? I believe that's 
Exhibit Number --
MR. SCAROLA: I don't know that it was 
marked. 
MR. LINK: Did we not mark it? 
THE WITNESS: Yeah, it's 10. 
BY MR. LINK: 
Q 
So we're looking at Exhibit Number 10 --
let me back up. Did you draft the counterclaim 
that's attached to the answer? 
A 
No. 
Q 
Who did? 
A 
I don't know. 
Q 
Mr. Scarola's office? 
A 
Yes. 
Q 
So Mr. Scarola's office drafted an abuse of 
process counterclaim based on the filing of a 
complaint? Is that true? 
A 
It appears that way. I mean, the document 
speaks for itself. There's a signature for that 
office, so it looks like that's what happened. I only 
know what you are knowing right now. 
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EFTA00800702

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Q 
Do you remember earlier you told me about 
how much time you had to spend on this doing the 
legal work because you were the one who knew and that 
you were the one doing the drafting, not Mr. Scarola 
or his firm? 
MR. SCAROLA: That's an inaccurate 
representation of the earlier testimony. 
THE WITNESS: The record will speak for 
itself just how badly you just bastardize 
what I just said. 
BY MR. LINK: 
Q 
So this counterclaim that was filed, you 
didn't draft it. Did you approve it before it was 
filed? 
A 
I'm sure. 
Q 
Had there been any other pleadings or 
anything done since December 7th and when this 
counterclaim was prepared? 
A 
Your question is had there been anything 
done --
Q 
In this lawsuit --
A 
Oh, in this suit. 
Q 
-- that you sued for abuse of process, 
other than the filing of the complaint? Anything 
else happen? Any other papers filed? Anything take 
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place? 
A 
Did anything happen? Did anything take 
place? Or were any papers filed? 
Q 
Yeah. All the above. 
A 
Which one is your question? 
Q 
All of the above. 
A 
I'm sure things happened. 
MR. SCAROLA: Objection, compound. 
BY MR. LINK: 
Q 
Okay, what happened? 
A 
You want me to recall what I did every day 
between December 7th and December 21st? 
Q 
No, sir. I want you to tell me what was 
the abuse of process. What took place after the 
complaint was filed to justify this counterclaim. 
MR. SCAROLA: Excuse me. Can you tell 
me where within the Court's defined area of 
inquiry those questions fall? 
MR. LINK: Uh-huh. I can. 
MR. SCAROLA: Where? 
MR. LINK: Probable cause and damages. 
MR. SCAROLA: Filing of the federal 
lawsuit, interaction with Rothstein and 
knowledge of the Ponzi scheme, $14 million 
bond --
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EFTA00800704

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MR. LINK: That's your reading of it, 
not mine. I sent you an entire email with 
all of the Court's statements about starting 
over --
MR. SCAROLA: I read every one. 
MR. LINK: -- and probable cause --
MR. SCAROLA: I read every one --
MR. LINK: -- and damages --
MR. SCAROLA: You're wrong. 
MR. LINK: And this relates to damages. 
MR. SCAROLA: How does it relate to 
damages? 
MR. LINK: Because he's claiming 
damages in this lawsuit. And he is seeking 
damages from when he filed this. And I want 
to find out what his damages were. 
MR. SCAROLA: He's seeking damages from 
the point at which he was maliciously named 
in a false and fraudulent claim by a serial 
pedophile. 
MR. LINK: Good statement. I'm sure 
the jury will enjoy that. 
But for my purposes and today, are you 
instructing him not to answer? 
MR. SCAROLA: Yes. 
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BY MR. LINK: 
Q 
So, are the damages you are seeking in this 
case related to the complaint that was filed on 
December 7th, 2009? 
A 
They are related 
yes, they were proximally 
caused by the complaint. 
Q 
This is the complaint we're talking about, 
right? 
A 
Yes. 
Q 
December 7, 2009. 
A 
Yep. 
Q 
And now we are looking at your answer and 
the counterclaim to that complaint, right? 
A 
Okay. 
Q 
And through the counterclaim is how you 
seek damages, isn't it, sir? 
A 
I don't think this is the operative 
counterclaim. Do you? 
Q 
I didn't say it was the one operative 
today. It's the one that you filed as soon as you 
received the lawsuit in less than 14 days. 
A 
Your statement is the counterclaim that we 
are looking at is the one through which you are seeking 
damages? 
Q 
Yeah. When you first filed the 
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counterclaim you sought damages, correct? 
MR. SCAROLA: This is an abuse of 
process counterclaim. 
MR. LINK: I know. And I am trying to 
find out what the damages are. 
MR. SCAROLA: The case that is being 
prosecuted currently is a malicious 
prosecution claim that relates back to the 
December 7th, 2009 case. 
As you are well aware, a malicious 
prosecution claim cannot be filed until the 
underlying action has been disposed of in 
favor of Mr. Edwards. 
MR. LINK: I actually thought that was 
true, but you didn't wait that long. I do 
agree with that statement. You're right. 
But this is the pleading that was filed 
that seeks damages, and it is the response 
to the complaint. 
If you won't let me ask him questions 
about it, then instruct him not to answer 
and we will go see what Judge Hafele says. 
MR. SCAROLA: Well, let me hear what 
the question is. 
MR. LINK: I just asked it. 
Palm Beach Reporting Service, Inc. 
EFTA00800707