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MR. SCAROLA: So far you haven't asked 
one that I'm going to let him answer. 
MR. LINK: That's fine. 
BY MR. LINK: 
Q 
What were your damages, sir -- what were 
your damages on December 21st, 2009? 
A 
It was the same types of damages that I am 
claiming now, in that the complaint that was filed 
against me was -- and it was intentionally designed to 
link me to Scott Rothstein, who at that moment was the 
most hated person in South Florida. And link me to him 
in a way that was as if Scott Rothstein and I together 
were running this Ponzi scheme. 
And he did it -- Jeffrey Epstein did this 
at a time when everyone -- everyone -- not 
locally -- and as you said, nationally -- was paying 
attention to the story, so as to cause the most 
damage possible. 
Since that point in time, those damages 
have continued to increase. But they began right 
from the time that this was filed. So whatever 
damages, whatever cause of damage that I was seeking 
back then, it's the same thing as now. 
Q 
I got it. So it's the filing of the 
complaint that caused damages, not it's being 
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disseminated? Is that right? 
A 
Well, the filing of the complaint and the 
consequences of that filing, which included the 
dissemination of the information contained within that 
complaint. 
Q 
I understand that. Can you tell me, 
please, one piece of information that was 
disseminated publicly in newspaper, in articles, 
somewhere before December 17th, when the counterclaim 
was filed with the clerk? Tell me one public 
document, news story, anything, discussing 
Mr. Epstein's complaint against you. 
A 
The complaint. That's public. 
Q 
I understand. 
A 
Okay. There it is. 
Q 
Who saw it? Didn't somebody have to see 
it? It's like if a tree falls it doesn't matter --
in the woods -- and nobody hears it. 
What I'm asking you is, who saw it? Who 
read it? 
A 
The Epstein complaint was also a highly 
publicized case, so then he makes this filing at this 
time. 
Q 
Right. I got that. My question is simple. 
Who was it disseminate to, other than the court, 
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before December 17th when the counterclaim was filed? 
A 
You are going to have to tell me. 
Q 
Do you know one person it was disseminated 
to that caused damage before you sued Mr. Epstein on 
your counterclaim? 
A 
Well, yeah. 
Q 
Who? 
A 
It was disseminated to whoever received a 
copy of the complaint. I mean, how do I know who your 
team -- I know we are through many lawyers now -- who 
your team disseminated it to and who was getting 
information about this. 
Q 
I'm trying to understand. If your 
reputation --
MR. SCAROLA: I'm sorry. You're 
interrupting Mr. Edwards. 
BY MR. LINK: 
Q 
I thought you were done. My apologies. 
A 
And at the time when it was filed against me, 
the purpose also was to sidetrack me from the 
prosecution of his cases -- the cases that I was 
pursuing against him -- basically to extort me into 
abandoning the legitimate cases that I was handling 
against him, to inconvenience me, take my time away, 
and make me have to deal with this complaint that I was 
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now being served with by Mr. Epstein. 
Q 
Did I interrupt you? 
A 
No. I will finish right there. 
Q 
Good. I didn't want to interrupt you. 
So, are you telling this jury that the 
three clients that you represented, the settlements 
that you obtained for them were somehow impacted by 
your inability to fulfill your professional 
obligations as a result of this counterclaim -- this 
lawsuit being filed against you? 
A 
No. I'm telling you that's what Jeffrey 
Epstein wanted to happen, but I didn't let happen. 
Q 
He failed; is that right? 
A 
Look at the numbers. He said it was a 
fabricated case. He paid millions of dollars for these 
allegedly fabricated cases. It was all a big, fat lie 
that he put in that complaint, which the jury is going 
to get to hear about. 
Q 
So his intent was to shut you down and make 
you not settle the cases, or to somehow give them 
away. He failed, because you, on behalf of your 
clients, got every single penny they deserved, didn't 
you? 
A 
I did well for them. 
Q 
You wouldn't have settled them if you 
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didn't believe you had reasonable settlements for 
them, would you? 
A 
It was not my choice to settle the cases. It 
was my clients' choice. 
Q 
Of course. 
A 
So you say I wouldn't have settled them. 
Look, I would have rather tried all three of them, to 
tell you the truth. 
Q 
Of course. I know that now. 
But you settled those three cases. And as 
a member of this bar, you did not believe that your 
representation was somehow impacted by the filing of 
this complaint, did you? 
MR. SCAROLA: Objection, compound. 
THE WITNESS: Thank goodness that Jack 
was there to help me defend against that 
lawsuit, otherwise, Mr. Epstein could have 
been successful. 
BY MR. LINK: 
Q 
But he wasn't, was he? 
A 
We made sure that my representation of my 
clients was not compromised because of his attempt to 
destroy my reputation. 
Q 
And that's what I was asking. 
A 
I did a pretty good job with that. 
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Q 
You fulfilled your professional 
responsibilities and obligations to your client and 
negotiated fair settlements for them, right? 
A 
I believe so. 
Q 
Good. 
And focusing on this window of when you 
are sued and when the counterclaim is filed, do you 
know of any press that ran a story about the Epstein 
lawsuit against Rothstein and Brad Edwards? 
A 
And what I was getting at before answering 
this question is, even when you were asking me 
questions about the press and the timing of the press 
with respect to the Ponzi scheme, I don't remember the 
chronology of any of the press or any of the news on 
any of these things. 
I would have to look and see what was out 
there at that time to be able to answer that 
question. I just don't remember. 
Q 
Have you sought press from December 2009 
forward about your litigation with Mr. Epstein? 
A 
If you could show me something to refresh my 
recollection, I will try to answer that question. I 
would do anything possible to mitigate the damage that 
Mr. Epstein tried to cause. If the opportunity arose 
and I thought the press could assist me in that 
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endeavor I would do it. Did it do it? I don't 
remember doing it. 
Q 
You don't remember having communication 
with the press about your litigation with 
Mr. Epstein? 
MR. SCAROLA: Which litigation are we 
talking about? Are we talking about 
Mr. Epstein --
MR. LINK: His -- his litigation. 
MR. SCAROLA: Yes. I understand that. 
But he had -- he had litigation against 
Mr. Epstein in which he was representing 
clients. He also had litigation with 
Mr. Epstein in which Mr. Epstein was suing 
him. He also had litigation with 
Mr. Epstein in which he was suing 
Mr. Epstein. So the question -- so the 
question is vague and ambiguous because we 
don't know what lawsuit you are talking 
about. 
BY MR. LINK: 
Q 
We have been talking about the Epstein 
versus Rothstein and Edwards lawsuit, right, in this 
deposition? 
So I'm talking about Epstein versus 
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Rothstein and Edwards. And in the counterclaim by 
Brad Edwards against Mr. Epstein, I'm asking you if 
you've ever gone to the press or talked to the press 
about that lawsuit and counterclaim. 
A 
Those are two different questions. I would 
say that the answer to the first question, did I go to 
the press 
Q 
Uh-huh. 
A 
-- I believe with great certainty that's not 
true. Did I --
Q 
You don't recall issuing any press releases 
about the litigation? 
A 
At any point in time? Even with 
Q 
Well, after it was filed, December 7th, 
2009. 
A 
I don't remember issuing a press release. 
But thinking back on it, when the case was dismissed 
against me, that seems like an opportune time to 
release a press release in order to mitigate the 
damages that were being caused. 
If I didn't, I wish I had. But I don't 
remember doing that. 
Did I ever speak to somebody from the 
press who called me about it? I would if I believed 
that it would mitigate the damages. I don't 
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remember a specific conversation like that. 
Q 
Well, the lawsuit Mr. Epstein filed against 
you was dismissed in 2012. 
A 
Three years later. 
Q 
2012, okay. 
And I asked you earlier if the dismissal 
of that lawsuit stopped the damages that you are 
claiming, and you said, No, it carries all the way 
on to today. You remember telling me that? 
A 
It carries on until a jury decides otherwise, 
decides that these things against me were untrue and 
hurtful. 
Q 
What I have been asking you is, you filed a 
counterclaim on December 15th, 10 days after the 
lawsuit was filed. And I am trying --
A 
I think that's 14. 7th to the 21st. 
Q 
The 17th is when it's filed. The 21st is 
when it's stamped. 
A 
Oh, it is. Okay. 
Q 
Whether it's the 17th or the 21st 
A 
Okay. 
Q 
One's 10, one's 14th, right? 
A 
Yeah. Very soon after. 
Q 
Had you been contacted by the press during 
that 10-to-14-day window to ask you questions about 
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Mr. Epstein's lawsuit against you? 
A 
I just don't remember anymore. 
Q 
Did you have any damages -- any damages --
real damages on the 17th or the 21st of December 2009 
related to the December 7th lawsuit Mr. Epstein 
filed? 
A 
Of course. 
Q 
What were they? 
A 
I was just linked with the biggest Ponzi 
schemer in history as his primary co-conspirator. The 
only lawyer in the whole law firm singled out by 
Jeffrey Epstein in a complaint as being the 
co-mastermind of a Ponzi scheme. It's filed in the 
local community. 
Every day my reputation is being tarnished 
by that. That's going to be patently obvious to 
anybody who sees this situation. 
To you right now, you know this. That's a 
complaint that's harmful. You read this and you go, 
there's a criminal indictment basically against me 
in the legal community that links me with the most 
hated person in South Florida right now. 
So the feeling that you get when you read 
that is, I know that this is really, really, really 
bad. There's only one way to come back from this, 
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and that's to prove that this is false. That's why 
we are here still. 
Q 
Only one way to come back from this you 
said. Come back from what? Your career has been 
more successful than ever since this lawsuit was 
filed, right? 
A 
Well, this kind of goes back to before. The 
people who really know me and know the outstanding work 
that I do for clients and see -- I'm a successful 
lawyer in that way. 
The people who don't know me, the 
9 million people who read this who won't call me, 
that don't want to have anything to do with 
me because of this association, and this being what 
they remember from that period of time and my 
relationship to that period of time. There's only 
one way to do this. 
Q 
So you're really bothered that 9 million 
people haven't called you? You just said these 
9 million people aren't going to call you. Do you 
think they were going to call you before the Epstein 
suit? 
A 
The only thing that matters to you is not 
your reputation amongst your best friends. It's your 
reputation in the community as a lawyer. 
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Yes, it's general people. I care about 
people. And I care about what people think about 
me. The truth, not some false indictment against 
me. 
Q 
Who do you think Mr. Epstein hurt more from 
a financial standpoint and from a pain and suffering 
and anxiety standpoint, you or the three clients that 
you were representing while you were at the Rothstein 
firm? Who's more the victim here? You or those 
three folks, sir? 
A 
It's tough put me up against -- it's not just 
those three victims. It's the hundreds and hundreds of 
little girls that he's molested over the years. I 
mean, that's what he does on a day-to-day basis. 
That's what he's still doing, I'm sure. 
So hurting people is something that he 
will do in any way, shape or form. But the fact is, 
he tried to hurt me in a way so that he could 
continue to hurt others and not have me call him out 
on it. 
Who's hurt more? 
Q 
Yeah. 
A 
It's different ways. He hurt my reputation 
more, because I had more of a reputation in the 
community. He hurt them more physically and 
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emotionally and has caused, you know, certain lives to 
be destroyed. 
I think I'm a stronger person than some of 
them. I was older. I wasn't a 14-year-old little 
girl. It's just very hard. You're comparing apples 
and oranges. We have all been hurt to the maximum 
degree possible. And that's always been his intent. 
Q 
So let's go back to 2009 and '10, and have 
you focus on my question. That was a good speech, 
and I appreciate that. But I asked you whether the 
three folks you represented -- not these hundreds 
that you didn't represent or these thousands that you 
think exist, or whatever you think Mr. Epstein is 
doing today. You represented three individuals, 
correct? 
A 
Yes. At that time, yes. 
Q 
At that time. 
A 
Yes. 
Q 
And you settled all three of their 
lawsuits, right? 
A 
I did. They settled their lawsuits, yes. 
Q 
You were their lawyer, weren't you? 
A 
I was. But I don't want you to make it seem 
like I chose to settle their lawsuits. My clients 
choose what they're going to do. They settled their 
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lawsuits. I was their lawyer, yes. 
Q 
So you were their lawyer. You told me they 
were really good lawsuits. You were proud of the job 
you did, right? Isn't that what you told me? 
A 
I was proud of the job that I did, yes. 
Q 
Good. So I'm asking about those three 
people and the harm that you believe Mr. Epstein 
inflicted on those three people that you represented. 
Do you think, sir, that the harm he inflicted on you 
is more or less than the harm he inflicted on those 
three individuals that you just told us about. 
MR. SCAROLA: That question has been 
asked and answered in great detail. 
THE WITNESS: The best way for us to 
get the answer to that question is, in this 
trial we can try each one of those cases and 
let the jury determine what amount of 
damages fairly and fully compensates each 
one of us for the harm he's cause, and we 
will have our answer who was harmed worse. 
BY MR. LINK: 
Q 
Well, is that what your intent is in this 
case, is 
A 
No, I'm trying to answer your question. 
Q 
-- to try the clients' cases that you 
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settled? 
A 
No. No. I'm just trying to play into your 
sociological experiment that you are trying to ask me 
about. 
Q 
I was just asking you to tell me 
A 
If I were a juror? 
Q 
No, sir, you, as the plaintiff in this 
case. If you believe that the harm inflicted on you 
by Mr. Epstein by filing his complaint in 
December 2009 causes you more anxiety and suffering 
than whatever he did to the three folks you 
represented? 
MR. SCAROLA: And that question is 
argumentive. It's not reasonably calculated 
to lead to the discovery of admissible 
evidence. It's the fourth time you have 
asked it. It's been answered. I will 
instruct you not to answer again. 
BY MR. LINK: 
Q 
When Mr. Epstein filed his complaint 
against you in December 2009, did he issue a press 
release? 
A 
Other than to take the Fifth, he doesn't say 
anything. 
Q 
So my question was, did he issue a press 
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release? I know you like to keep telling your story 
as a trial lawyer, but my question was, did he issue 
a press release? 
MR. SCAROLA: Objection to the form of 
the question. 
BY MR. LINK: 
Q 
Did he? 
MR. SCAROLA: It's argumentive. 
THE WITNESS: You tell me whether he 
issued a press release. He's your client. 
BY MR. LINK: 
Q 
So you don't know whether Mr. Epstein 
issued a press release related to the lawsuit he 
filed against you that you are seeking damages for? 
A 
If he did issue a press release, I did not 
personally see it. If you are going to show me a press 
release, then I'm not going to debate you with it. 
Q 
You ever file any papers in federal court 
that were devoid of factual support? 
A 
What does that mean? 
Q 
Have you ever filed any papers against 
Mr. Epstein that were determined to be devoid of 
factual support? 
A 
What are we looking at? 
Q 
Just asking you that question, sir. 
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A 
Oh, in my life? Up to today, or are we going 
back to 2009? I'm confused what time period we are on. 
Q 
2009. 
MR. SCAROLA: The first question wasn't 
limited to Epstein. The next time the 
question was asked, it was limited to 
Epstein. 
BY MR. LINK: 
Q 
Let me ask it again. Was there ever any 
time that you filed a federal court paper, motion, 
pleading related to a case with Mr. Epstein that it 
was determined to be devoid of factual support? 
A 
Not that I recall. 
Q 
You remember filing a petition to have 
Mr. Epstein post a bond while you were working at the 
Rothstein firm? 
A 
Yeah, I remember that motion. 
Q 
Did you sign that motion? 
A 
Let me see. 
Q 
Do you remember if you signed that motion? 
A 
No. But I remember --
Q 
Do you remember the court's ruling on the 
motion? 
A 
It was denied. 
Q 
Do you remember the Court making any 
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specific findings about your factual basis for 
bringing the motion? 
A 
I don't. But it was 
I believe that the 
court denied it because prejudgment, you can't freeze 
assets. 
Q 
Did you have any evidence before you filed 
that motion that Mr. Epstein was transferring his 
assets offshore? 
A 
Yeah, I had many sources during this 
investigation. And we had significant evidence that 
the way in which -- the way -- what we should fear is 
that we would get a judgment and there would be no 
money in his name, and that the money would have been 
transferred offshore. 
Q 
Who is the source that told you, 
specifically at the time you filed the federal court 
pleadings, that Mr. Epstein was, in fact, 
transferring every dollar that he had offshore, so 
there would be nothing left to pay the plaintiffs you 
represented? Who was that? 
MR. SCAROLA: Objection, work product. 
BY MR. LINK: 
Q 
Was it something you relied on in filing 
the federal court action under your Rule 11 
obligations? 
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A 
It's not something that I relied on in filing 
this case. 
Q 
No, sir. I'm not talking about that. I'm 
talking about the federal court case where you sought 
a bond in which you still have Rule 11 obligations. 
Right? 
A 
Right. 
Q 
And before you file something in federal 
court, you have to have a factual evidentiary basis 
to do so, correct? 
A 
Correct. 
Q 
I'm asking you what was your factual 
evidentiary basis for seeking the relief that you 
sought on the bond motion. 
A 
I had numerous sources. I had numerous 
sources, and numerous sources that was (sic) shared 
amongst plaintiff's counsel on the case. 
Q 
I don't want to know about sources. I want 
to know about evidence. Evidence is not protected. 
You have to submit it to the court. 
I'm not looking for your confidential 
sources. I want to know what evidence you had, sir. 
A 
Well, we knew that there were cars, boats, 
houses that were placed in Larry Visoski's name. 
That's some evidence that we had. 
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Q 
Uh-huh. 
A 
And other than that, we had individuals who 
were familiar with Mr. Epstein and knew him 
some of 
which had known him for many years -- to provide us 
good information that that's what he was doing. 
Q 
And they were going to get on the stand and 
testify. 
A 
Would they have testified to that if 
subpoenaed and on the stand? Yes. 
Q 
Is there a reason you didn't get affidavits 
from these folks to support your petition, if they 
would have testified? 
A 
Yes, there is. 
Q 
What was the reason? 
A 
This is also work-product privilege 
information. 
Q 
Let's take a look at Plaintiff's Exhibit 
Number 14. 
(Plaintiff's Exhibit Number 14 was marked 
for identification.) 
BY MR. LINK: 
Q 
So we are on Exhibit Number 14, which is 
United States District Court for the Southern 
District of Florida. And if you go to page four of 
this exhibit, you will find the motion for injunction 
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