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you should not respond. 
BY MR. LINK: 
Q 
Without disclosing their names, I will ask 
the question differently. 
Were you representing, in January 2013, 
undisclosed victims that had compensatory and 
punitive damage claims yet to be filed against 
Mr. Epstein? 
A 
I don't know. I don't know if at that time I 
was or not. 
Q 
Well, that's what this statement says, 
right? 
A 
It doesn't really. It says that upon 
information and belief, federal law enforcement 
continues to investigate additional allegations of 
Epstein's serial abuse and molestation of children. 
Q 
That's not the sentence we were just 
looking at. 
A 
"As a consequence" -- that's the sentence you 
are looking at. "As a consequence of the" -- that's 
what it says in the first sentence -- "Epstein 
continues to face the potential of further criminal 
prosecution and huge civil judgments from both 
compensatory and punitive damages in favor of many 
victims of his depraved criminal exploitation of 
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children" --
Q 
Including victims represented by Edwards. 
A 
-- "including victims represented by 
Edwards." 
Q 
So I'm asking you, did you, in fact, in 
January 2013 represent any victims of Mr. Edwards 
(sic) that still had --
A 
Epstein. 
Q 
I'm sorry. Mr. Epstein. Let me do it 
again. 
Mr. Edwards, did you in January 2013 
represent any victims that had potential claims for 
both compensatory and punitive damages against 
Mr. Epstein? 
MR. SCAROLA: You're misreading the 
sentence. It doesn't say what you think --
what you are reading it to say. And as the 
author of the sentence, I can tell you it 
doesn't say what you think it says. 
MR. LINK: I think it says exactly the 
way I'm reading it, but it doesn't really 
matter. So in answering my -- someone else 
will decide what it says, not you or me. 
MR. SCAROLA: Well, I will decide what 
it says because I wrote it. 
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MR. LINK: Well, I don't think it 
actually works that way. I expect the jury 
will have to determine --
MR. SCAROLA: And I suspect that --
MR. LINK: That's improper --
MR. SCAROLA: -- to examine this 
witness about the allegations --
MR. LINK: -- in a pleading. 
MR. SCAROLA: -- in an unsworn 
pleading. That's correct. 
MR. LINK: We will find out. 
MR. SCAROLA: Okay. 
BY MR. LINK: 
Q 
In any event, did you, in fact, in 
January 2013 have any clients that you were 
representing that still had potential civil 
compensatory and punitive damages claims against 
Mr. Epstein? 
A 
I don't remember if in January of 2013 I 
represented anybody who was a victim of Mr. Epstein's 
molestation. I just don't remember. 
Q 
Take a look at the last sentence of 
paragraph six and the first sentence of paragraph 
seven. 
A 
Okay. 
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Q 
Tell me which lawyers were unable to 
persist in the prosecution of their claims based on 
Mr. Epstein's tactics? 
A 
It doesn't say that. You are just reading 
something into it a paragraph that's not even close to 
what it says. 
Q 
Talks about intimidating his victims and 
their legal counsel into abandoning their legitimate 
claims or resolving those claims for substantially 
less than their just value, right? That's a 
statement of fact in here of what has happened. 
And it says, "Epstein's tactics have 
proven successful, while other victims have thus far 
withstood this continued assault upon them and 
persisted in the prosecution of their claims." 
Right? 
So if Mr. Epstein's tactics proved 
successful, then he must have intimidated victims 
and their legal counsel into abandoning their 
legitimate claims or abandoning their legit claims 
or resolving them for substantially less than their 
just value. And I would like to know who those 
lawyers and victims were, sir. 
MR. SCAROLA: That is argumentive. It 
is a misreading of the sentence. 
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MR. LINK: Okay. 
MR. SCAROLA: And if the question is 
are you aware of victims who were 
intimidated by Epstein and compromised their 
claims for less than their value, that's a 
legitimate question. But skip the whole 
bunch of rhetoric that precedes it and ask 
that question. 
MR. LINK: You are done? 
MR. SCAROLA: Yeah. 
BY MR. LINK: 
Q 
Do you remember my question? 
A 
Hardly. 
Q 
Me too. 
So what I'm trying to understand is this 
most current lawsuit against that Mr. Epstein has 
allegations in it. And I know when we looked at 
Mr. Epstein's complaint against you, you were 
bothered by allegations that were in there that you 
said were untrue, right? 
A 
Yeah. The complaint is untrue. 
Q 
I'm just looking at these allegations that 
your lawyer filed on your behalf. Did you review 
this complaint, this counterclaim before it was 
filed? 
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A 
At some point in time, but not recently. 
Q 
I said before it was filed. 
A 
I'm sure. 
Q 
And if there was something that you saw in 
there that you thought Mr. Scarola got wrong or was 
inaccurate, he unintentionally made a mistake, you 
would have pointed it out, right? 
A 
Well, Mr. Scarola was one of the lawyers who 
also represented Epstein victims, so he knew -- he knew 
the case, so did I. Did he know facts that I didn't 
know? Maybe. But this doesn't look foreign to me. I 
mean, Epstein intimidated victims. You've seen the 
police reports. He intimidated victims. He 
intimidated their families. 
Q 
And their legal counsel, you say in here. 
Mr. Scarola did not --
MR. SCAROLA: No, no. The complaint 
said he attempted to intimidate victims and 
legal counsel, and in some circumstances he 
was successful. 
MR. LINK: Right. I'm trying to figure 
out who it was. 
MR. SCAROLA: Okay, well, then ask that 
question --
MR. LINK: I did. 
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MR. SCAROLA: -- are you aware of 
victims or legal counsel who were 
intimidated? 
MR. LINK: I asked it my way. You are 
better at it than I am. I will keep going 
my way. 
BY MR. LINK: 
Q 
Can you tell me one lawyer who was 
intimidated and resolved or abandoned a legitimate 
claim, or resolved it for substantially less? Can 
you tell me one? 
A 
Because of intimidation, many of the victims 
either didn't bring claims or abandoned their claims or 
settled them for much -- well below the value of the 
cases. 
Q 
You said lawyer. Tell me one lawyer, 
please, is what I asked. One lawyer. Did 
Mr. Scarola? There's no chance, right? 
MR. SCAROLA: How about one question at 
a time. 
MR. LINK: Fair enough. 
BY MR. LINK: 
Q 
Did Mr. Scarola capitulate and was afraid 
of Mr. Epstein? 
A 
It wasn't the --
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MR. SCAROLA: That's two questions. 
MR. LINK: It was? 
MR. SCAROLA: Yes. Did Mr. Scarola 
capitulate? Was Mr. Scarola intimidated by 
Mr. Epstein? 
MR. LINK: I bet he can handle that 
question. 
MR. SCAROLA: I'm sure he can, but the 
law requires that you ask one question at a 
time. 
MR. LINK: It actually requires that 
you just object to the form and then we will 
see. That's what it requires. I know you 
know that. I think you taught me that 
during my objections. 
MR. SCAROLA: Let's ask the proper 
question, please. 
THE WITNESS: All right. What's the 
question? 
BY MR. LINK: 
Q 
Can you tell me one lawyer that represented 
an Epstein plaintiff that abandoned their claim based 
on Mr. Epstein's intimidation? 
A 
I believe what is being said here is that the 
intimidation of the victim caused the lawyer or the 
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victim to settle the case or the lawyer to not be able 
to get the full value of the case. 
I think that if you talk to Bob 
Josefsberg, he will tell you that that happened. 
Q 
That he settled his cases for less than he 
otherwise would have because of him being intimidated 
or not getting the evidence? 
A 
His clients being intimidated. 
Q 
I will ask him that. 
A 
Perfect. 
Q 
You can try to massage the words, as you 
have done, but this says intimidate his victims and 
their legal counsel. And I keep asking you about 
legal counsel. 
A 
And I keep telling you to ask him. Ask some 
other legal counsel. It wasn't me. 
Q 
This isn't his pleading. This is yours, 
sir. And I'm asking you in this pleading that you 
filed to please tell me one person that you are 
referring to in this statement that you made. One. 
Tell me one lawyer that abandoned a legitimate claim. 
A 
I just told you who to go to ask and you 
acted like I didn't say it. 
Q 
Sir, your pleadings says that a legal 
counsel abandoned a legitimate claim. 
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A 
It's Jack Scarola's --
MR. SCAROLA: My pleading does not say 
-- my pleading does not say that any lawyer 
was intimidated. My pleading says that 
Jeffrey Epstein sought to intimidate victims 
and their legal counsel into abandoning 
their legitimate claims. That's what it 
says. That's what he sought to do. 
BY MR. LINK: 
Q 
Can you identify any lawyers that were 
intimidated and abandoned their claim, please? If 
you can't, you can't. Just say, I don't know of any. 
A 
I just told you it wasn't me. 
Q 
I didn't ask if it was you, sir. I said if 
you can identify any. This is about the 50th time 
I've asked you can you tell me any lawyers that have 
abandoned their claim. And all you have to say is, I 
don't know of any. Or I do know, and here is who 
they are. 
A 
Any lawyers that abandoned their claim? 
Q 
Yes. 
A 
I don't know of any lawyers that abandoned 
their claim. 
Q 
Okay. Thank you. 
Do you know of any lawyers that have 
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resolved their claim for substantially less than 
their just value? 
A 
I don't know of any lawyers that had a claim. 
But if they had a claim against Mr. Epstein, I don't 
know of any lawyer who abandoned his claim for 
substantially less value. 
Q 
Now, I'm not talking about a lawyer's 
claim. 
A 
That's what you just asked me. 
Q 
No, it's not. It's the claim for the 
clients they represent. 
A 
Okay. 
Q 
I am assuming that's what your paragraph 
talks about here, are lawyers representing victims, 
and that those lawyers, as a result of intimidation, 
either walked away from the case, or took less money 
than they thought was professionally and ethically 
available for the case because of the intimidation. 
That's what we're talking about. 
So let's try it again, which is really 
simple. Are you aware of any lawyer that abandoned 
a legitimate claim filed on behalf of a client 
because they were intimidated by Mr. Epstein? 
MR. SCAROLA: Who is the they you're 
speaking with? 
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MR. LINK: What? 
MR. SCAROLA: You used a pronoun. 
MR. LINK: Yeah. 
MR. SCAROLA: The pronoun followed two 
specific references. One was a reference to 
client and the other was a reference to 
lawyer. 
BY MR. LINK: 
Q 
You can answer the question. 
A 
So am I aware -- is it your question or does 
it relate to this paragraph? Does your question relate 
to the paragraph? 
Q 
Ignore the paragraph for a minute. 
A 
Pretend the paragraph doesn't exist 
Q 
I can tell it's confusing. 
A 
It is, because it doesn't relate to your 
question, but -- okay. 
So your question is --
Q 
You're objecting too? Now you're objecting 
for yourself. 
A 
No. I just thought that you were trying to 
relate it to this paragraph, and that's what's making 
this hard. 
Q 
Don't worry about what's going on in my 
head. 
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A 
So omit the paragraph? 
Q 
I would like to know if you can identify 
one lawyer that represented a victim with a 
legitimate claim against Mr. Epstein where that 
lawyer abandoned that claim because of Mr. Epstein's 
intimidation. 
A 
I'm not sure one way or the other. Like I 
said, if -- Bob Josefsberg represented a lot of people. 
If anybody's claim was abandoned because of 
intimidation, he would probably know better than me. 
Q 
Mr. Josefsberg is not sitting in that 
chair, sir. 
A 
Right. 
Q 
I'm asking you. So if you don't know one, 
is it hard no say I don't know of any? 
A 
I believe victims abandoned their claims. I 
remember that as a fact. I believe also that they were 
represented by Mr. Josefsberg. I'm not positive about 
that, but that's to the best of my memory. That's what 
I think happened. 
How this has anything to do with this 
lawsuit, God only knows. But I'm trying for you. 
Q 
So I should talk to Mr. Josefsberg to see 
if, when he was legal counsel for a victim he 
abandoned a legitimate claim because he was 
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intimidated by Mr. Epstein. Is that what you're 
saying? 
A 
That's not what I said. I said whether a 
victim abandoned her claim where he happened to be the 
lawyer because she was intimidated or Mr. Epstein used 
his -- employed his extraordinary financial resources, 
sought to avoid damages by employing extraordinary 
resources at his disposal with the purpose of 
intimidating his victims or legal counsel, I think that 
that would be the person you would ask about that. 
Q 
All right. 
Turn to paragraph 25, which is on page 
eight. 
A 
Okay. 
Q 
You see that it talks about Mr. Epstein 
filing this claim against Edwards and Edwards' client 
A 
I do. 
Q 
-- for the sole purpose of further 
attempting to intimidate? 
A 
Yes. 
Q 
And to abandoning or settling their 
legitimate claims. 
A 
Right. 
Q 
We talked about that earlier, right? 
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A 
Yes. 
Q 
And can you -- III. was a defendant in this 
lawsuit, right? 
A 
Right. 
Q 
At the time that she was a defendant, she 
was represented by you and your law firm as her 
lawyer against Mr. Epstein, right? 
A 
Correct. 
Q 
Did you and your law firm represent III. in 
the defense of this lawsuit? 
A 
Yes. 
Q 
And in representing III. in the defense of 
this lawsuit where you're also a defendant, did you 
charge her for that work? 
A 
No. 
Q 
Did you do it on a contingency basis? 
A 
No. 
Q 
Did you charge her for costs? 
A 
No. 
Q 
Did you have a written fee agreement with 
her? 
A 
Specifically for the defense of this case? 
Q 
Yes, sir. 
A 
Not a fee agreement, because I didn't charge 
her a fee, and I don't think that there was a written 
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agreement at all, to the best of my memory. 
Q 
Did you have any writing with her at all 
discussing the terms upon which this representation 
would go forward? 
A 
No, other than I told her I would represent 
her pro bono in this. It was unfair that this was his 
tactic to try to extort her into abandoning her claim, 
as well. 
Q 
Did you have any writing with her 
describing a conflict situation related to your being 
a defendant in this lawsuit representing her in the 
claims against Mr. Edwards (sic) and defending 
A 
Epstein. 
Q 
Epstein. Thank you. 
-- and defending her in the claim brought 
by Mr. Epstein against her? 
A 
I don't know if she signed a conflict waiver. 
I'm trying to think through what that conflict would 
be. It's not jumping out at me. I don't think that 
she signed a conflict waiver. 
Q 
Just so I get the names right -- thank you 
for correcting me. 
At the time you, Brad Edwards, represented 
in a state lawsuit against Mr. Epstein. 
A 
Right. 
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Q 
You, Brad Edwards, represented 
in a 
federal lawsuit against Mr. Epstein. 
A 
Right. 
Q 
Mr. Epstein sued_ 
and you individually 
in December 2009. 
A 
Right. 
Q 
Your law firm and you represented yourself, 
right, in the defense of Mr. Epstein's suit? 
A 
Mr. Scarola represented me. 
Q 
Well, you filed a notice of appearance. 
A 
Not then. 
Q 
When did you file it? 
A 
I don't remember. You would have to show me 
the pleading, but not initially. 
Q 
But you did, before Mr. Epstein's suite was 
dismissed, file a notice of appearance, right? 
A 
Before Mr. Epstein 
Mr. Epstein's lawsuit 
with m was dismissed? 
Q 
Against you. 
A 
Against me was dismissed? 
Q 
Uh-huh. 
A 
Yes. 
Q 
And Mr. Epstein sued_ and you and your 
law firm agreed to represent her without charging her 
to defend against the lawsuit Mr. Epstein brought? 
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A 
That's right. 
Q 
And as far as you can remember, there's no 
written fee agreement? 
A 
True. 
Q 
And there's no written conflict waiver 
letter? 
A 
Yes. We just went through that. 
MR. SCAROLA: Good place for a break? 
MR. LINK: Yeah. Perfect. Thank you. 
THE VIDEOGRAPHER: The time is 
4:01 p.m. This is the end of tape three and 
we are going off the record. 
(A recess was had.) 
THE VIDEOGRAPHER: The time is 
4:17 p.m. This is the beginning of tape 
four. We are back on the record. 
BY MR. LINK: 
Q 
Mr. Edwards, looking at Exhibit 18 -- we 
started the day talking about lawyers in the 
Rothstein firm that worked on the Epstein matters 
with you. And that is -- you testified earlier that 
Russell Adler -- this is an email from him -- was the 
head of the tort group. 
A 
Right. 
(Plaintiff's Exhibit Number 18 was marked 
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for identification.) 
BY MR. LINK: 
Q 
And this is a memo from him to you copying 
Marc Nurik. Marc Nurik was a lawyer at Rothstein's 
firm? 
A 
One of the criminal defense lawyers. 
Q 
And it's references Mr. Epstein's 
non-prosecution agreement? 
A 
That's what it looks like. 
Q 
And it looks like it's a message from 
Mr. Adler to you. Says, "Brad, Wayne Black and I 
just had a great conversation with Marc Nurik about 
the non-prosecution agreement, and I need you to 
please get in contact with Marc and meet with him to 
discuss the possibilities. Bring with you a copy of 
the agreement." 
Next sentence says, "We also discussed the 
assets situation and there are some major 
possibilities that need to be explored with Marc and 
others." 
"Get on it" exclamation point. 
Were you reporting to Mr. Adler in how to 
represent the three Rothstein clients -- the three 
ladies -- on how to prosecute the Epstein matters? 
A 
Well, this email is dated April 8th, 2009, so 
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I had just started at the firm. I had just got there. 
Russ Adler was one of the only lawyers 
that I had known for years before I got to the firm. 
And Russ Adler handled sexual abuse cases. So, 
especially in the beginning, I talked to Russ about 
how to kind of navigate through the complications 
with Jeffrey Epstein and with the type of defense 
that was going on. So this just appears that Wayne 
Black and Russ Adler -- Wayne was the 
investigator -- that they were talking also about 
how to -- what we needed to do in the investigation. 
Yeah, Russ was definitely involved then. 
He didn't do much in the day-to-day, so I don't want 
to say anything to that. 
Q 
I understand. But I'm talking about on 
April 8th, 2009, it looks to me like he's giving you 
instructions on what to do. Do you agree? 
A 
Not giving me instructions on what to do. I 
mean, he's telling me bring Marc Nurik the 
non-prosecution agreement, is the instruction. 
If anything, we are working together with 
the common goal. 
Q 
The get on it, exclamation point --
A 
We're buddies. Then we were just friends. 
Get on it is let's do this. 
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