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BY MR. SCAROLA: 
Q 
Mr. Edwards, one of the things I have seen 
is that you have been -- you have gotten awards and 
accolades and different recognition by your peers 
over the years, right? 
A 
Mr. Haddad and I talked about this ad nauseam 
at my second deposition, so yes. You've noticed the 
same thing that your predecessor noticed. 
Q 
What I was going to ask you is, I didn't 
see any such accolades or awards before 
December 2009. Were you rated by Martindale-Hubbell 
before December 2009? 
A 
This is the same line of questioning. We are 
just rehashing the same thing. 
Q 
So you don't want to answer? 
MR. SCAROLA: I will let you answer 
THE WITNESS: It's not that I don't 
want to answer, it's just wasting time. 
MR. SCAROLA: I will let you 
answer that one question. 
THE WITNESS: I don't know. 
When Mr. Haddad told me last time all 
of the accolades, it was -- most of it was 
news to me. Some of the things I didn't 
even know about. Martindale-Hubbell, I do. 
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Was I rated before that? I don't know. 
You would have to go back. 
BY MR. LINK: 
Q 
So the things in this exhibit --
A 
It's mainly Martindale-Hubbell. 
Q 
-- 20 -- 30 -- 23 -- 23. 
MR. SCAROLA: Twenty-five. 
MR. LINK: Twenty-five? 
MR. SCAROLA: Yes, sir. 
BY MR. LINK: 
Q 
Exhibit 25, you're aware of all of these 
because you ordered plaques, right? 
A 
I personally didn't. Did my firm? I don't 
know. Like, I have never seen this before. I don't 
know what this organization is. I haven't seen it. 
Was it ordered? Possibly. 
Q 
Do you put these plaques up in your office? 
A 
I may have three plaques up in my office. 
No. I don't have all these plaques. 
Q 
You don't have all these plaques up in --
where are you storing your plaques? 
A 
I don't know. That's a good question. 
"Highest possible rating in both legal 
ability and ethical standards." I feel like I would 
have remembered seeing this plaque. I haven't seen 
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it. 
Q 
But you see the picture of the plaque? 
A 
I do. 
Q 
With your name on it? 
A 
You've made a great exhibit here. I'm going 
to use it in my next presentation. 
MR. SCAROLA: Marketers send you these 
things with a picture of your plaque all the 
time. 
MR. LINK: Not me. They know better. 
Why don't we take a couple minute's 
break. Let me sort through some of this and 
see where we can get to to move it along. 
How's that? 
THE WITNESS: Anything to move it 
along. 
MR. SCAROLA: Sounds promising. 
THE VIDEOGRAPHER: The time is 
5:15 p.m. We are going off the record. 
(A recess was had.) 
THE VIDEOGRAPHER: The time is 
5:35 p.m. We are back on the record. 
BY MR. LINK: 
Q 
Mr. Edwards, Bill Corte, who is he? 
A 
He's an IT guy. 
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Q 
Worked at the Rothstein firm? 
A 
Yes. 
Q 
And did he join the firm that you guys set 
up, Farmer 
A 
No. 
Q 
Tell me the name of the firm again. 
A 
Farmer, Jaffe, Weissing, Edwards, Fistos & 
Lehrman. 
Q 
Did not join them? 
A 
No. 
Q 
Did you work with him while he was at 
Rothstein when you were employed there? 
A 
We were both employed there. 
Q 
Did you work with him on any of the Epstein 
files? 
A 
No. He didn't work on Epstein files. He was 
an IT guy. 
Q 
I understand. 
Did you use him for any part of the 
Epstein cases? 
A 
I don't think he worked on any -- we didn't 
have any IT needs, I don't believe. 
Q 
We talked earlier about the settlement with 
the three clients that you represented when you were 
at Rothstein, and I think the number was 
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5.2 million --
A 
It was 5.5 million. It settled in July of 
2010, not while I was at Rothstein. 
Q 
No, I understand. They were the three 
same three clients you represented while you were at 
Rothstein's, right? 
A 
Yes. 
Q 
Can you tell me, of the 5.5, how much did 
the three collectively collect from that? 
A 
I don't remember that. 
Q 
You didn't take those cases on a pro bono 
basis, did you? 
A 
No. It was a contingency arrangement, 
similar to my arrangement with Mr. Scarola in this 
case. 
Q 
Okay. I understand. I understand. 
So that contingency, do you remember what 
percentage the contingency was? 
A 
I don't. 
Q 
Was it a third, 40 percent? 
A 
Probably -- I don't know. But the standard 
is between zero and a million, 40 percent if it's in 
litigation; 1 to $2 million, 30 percent; and then over 
$2 million, 20 percent or something. There's a sliding 
scale. That's probably what was used. 
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Q 
Somewhere in that range, though. So on 
average between 30 to 35 percent on total? 
A 
Yeah. 
Q 
Did your clients fund their expenses in the 
litigation? 
A 
No. 
Q 
You fronted the expenses for them -- the 
law firms did? 
A 
Yeah. 
Q 
The expenses that were fronted by the 
Rothstein firm, were they ever collected? 
A 
What do you mean by that? 
Q 
So I assume when you were at the Rothstein 
firm there were expenses advanced on behalf of the 
three clients, right? 
A 
Right. 
Q 
And when Rothstein's firm went away, were 
those expenses that the Rothstein firm advanced ever 
paid to the trustee --
A 
Yeah. 
Q 
-- or paid back --
A 
Yeah. 
Q 
They were? 
A 
Yes. 
Q 
And how much was paid to the trustee for 
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the expenses? 
A 
I don't remember that. I think this was 
asked in a prior deposition and I gave the answer. I 
remember this line of questioning, and I knew then. I 
just don't now. Too many years have passed. 
Q 
But there is some amount of the recovery 
that went to the trustee, right? 
A 
Yes. 
Q 
Do you remember what the total costs were 
that the three clients had deducted from the 
settlement amount? 
A 
I don't. Again, I definitely testified about 
this at a time that I knew it, which was either my 
second or third deposition. I don't remember anymore. 
Q 
Do you have a rough estimate in your mind 
about what the expenses were or the costs that were 
advanced? 
A 
Approximately $200,000. 
Q 
When -- at the Rothstein firm, the 
four-plus investigators that would work on the 
matter, would they record their time as an expense 
that the clients would pay? 
A 
No. 
Q 
They did not. 
So a couple hundred thousand dollars in 
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costs, roughly 30, 32 percent contingency fee. I 
got that about right? 
A 
Yeah. I mean based on the math that we're 
doing. Again, I'm approximating based on --
Q 
I understand. 
A 
Yeah. 
Q 
So -- that's really hard math. I like a 
round number. Roughly a million six or seven in fees 
to your -- to the firm? 
A 
It wasn't that much, because we had to pay a 
portion of the fees to the trustee, too. 
Q 
Oh, they got a portion of the fees and the 
cost? 
half. 
A 
Yes. 
Q 
Do you remember what portion they got? 
A 
I don't. 
Q 
Half? More? Less? 
A 
I just don't remember. I think less than 
Q 
Do you? All right. 
Other than --
A 
It worked out based on how long different 
lawyers were there. And I was at RRA for such a short 
period of time that it would not have been half. 
That's my deductive reasoning that leads me to answer 
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that question that way. 
Q 
I got it. 
So there was -- obviously there were three 
firms that had an interest in whatever the fee 
recovery was. Brad Edwards, PA? 
A 
Yep. 
Q 
The Rothstein firm? 
A 
Wait. No. Brad Edwards, PA didn't 
It was the Rothstein firm -- when I came 
to that firm, all of my cases became RRA cases. I 
didn't retain --
Q 
Separate interest --
A 
No. I didn't retain any separate interest. 
I just became an employee of a firm. 
Q 
And gave them the cases? 
A 
They were their cases. 
Q 
I got it. 
A 
So when I left, I took the cases with me 
because there was no RRA anymore. 
Q 
I didn't understand. Let me make sure I 
got this. When you left Brad Edwards, PA and 
became -- the salaried employee? 
A 
Yes. 
Q 
Salaried employee -- you brought those 
cases with you and did not retain any percentage in 
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those cases? 
A 
Correct. 
Q 
Got it. And when those case leave and go 
to the new Farmer firm, those cases go with, and 
there's an agreement with the trustee for Rothstein 
about how fees and costs will be shared? 
A 
Exactly. 
MR. LINK: Thank you very much. I have 
questions only as to the areas that you 
instructed him not to answer. But other 
than that, I'm finished. 
CROSS-EXAMINATION 
BY MR. SCAROLA: 
Q 
Brad, there were a number of questions 
asked of you in regard to signatures on documents 
that you do not recognize. But you testified that it 
was your intent that those documents be filed under 
your authority; is that correct? 
A 
Right. 
Q 
Do you have any reason to believe that, 
although you did not recognize those signatures, that 
those documents were signed without your authority? 
A 
No. As I explained, I authorized the cases 
to be filed. And any attorney could sign the pleading 
and have it filed. It was my pleading. I wanted it to 
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be filed. Attorneys sign pleadings for people all the 
time. So I authorized it to be filed. 
Q 
There was --
A 
I think that the implication was that I 
authorized somebody to sign my signature. I didn't 
authorize anybody to sign my signature. I authorized 
the cases to be filed -- an attorney could sign it, get 
it filed. 
Q 
Was that an unusual circumstance? 
A 
No. 
Q 
Was it unique in any respect with regard to 
anything having to do with the Epstein cases? 
A 
No. 
Q 
Is it unusual in your experience for other 
lawyers to operate in the same fashion? 
A 
No. I signed pleadings. People sign 
pleadings for me. It happens in every law firm that I 
know, so --
Q 
You were also asked questions about your 
knowledge of the compromise of claims based on 
Jeffrey Epstein's intimidation. Did you have any 
authority to settle claims without the knowledge and 
consent of your clients? 
A 
No. 
Q 
Did you have any authority to refuse to 
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settle claims where your clients directed that their 
claims be compromised? 
A 
Repeat that question again. 
Q 
Yes. You told us that you couldn't settle 
a claim without your clients' authority. Did you 
have any authority to refuse to settle a claim where 
your client directed you to settle it? 
A 
I did not. And as I explained, I wanted to 
try all of those cases and not settle them. I settled 
them because the clients wanted them settled. 
Q 
Did Jeffrey Epstein's intimidation of 
clients, to your knowledge, and without violation of 
any attorney-client communication privilege, have an 
impact on the amount for which claims against Jeffrey 
Epstein were being settled? 
MR. LINK: Object to the form. You are 
going to testify about what the client said 
but you are not waiving the privilege? 
MR. SCAROLA: No. I'm asking him 
whether from his perspective, as the trial 
lawyer on those cases, whether Jeffrey 
Epstein's intimidation had any impact on the 
amount for which the claims were settled. 
THE WITNESS: We are talking about just 
the cases that I handled or all of the 
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cases? 
BY MR. SCAROLA: 
Q 
Right now I'm talking about just cases that 
you handled. 
A 
Of course. It wasn't just my clients. Every 
single one of the girls were scared to death of Jeffrey 
Epstein and his intimidation, and my clients were no 
different. It was the same. His intimidation was very 
successful in reducing the amount that should been paid 
to every single one of these abused girls very 
successfully. 
MR. LINK: I am going to object and 
move to strike as inconsistent with the 
testimony that you already gave under oath 
to me, but you may continue. 
BY MR. SCAROLA: 
Q 
Do you have an opinion with regard to the 
full value of the claims of the three clients that 
you represented? 
A 
Sure. 
Q 
Did the value of those claims exceed the 
amounts for which they actually settled? 
A 
Of course. 
Q 
What are the factors that go into the 
assessment of the value of a claim against Jeffrey 
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Epstein? 
MR. LINK: Object to the form. 
THE WITNESS: In my view, it was the 
disparity of age between Jeffrey Epstein and 
the particular victim. The way -- the types 
of conduct, specifically, that Jeffrey 
Epstein engaged in with the particular 
victim. It wasn't all identical. 
The psychological control that Jeffrey 
Epstein gained over the particular victim, 
the method that he gain that control over 
the particular victim, and the lasting 
impact that his abuse played in that 
particular victim's life. Some recovered 
better than others. Some didn't do well at 
all. 
MR. LINK: When you say some, are we 
talking about your three clients? 
THE WITNESS: I think we're talking 
about how do you go into evaluating a claim 
against Jeffrey Epstein. 
MR. LINK: Generically, unrelated to 
anyone specifically? 
MR. SCAROLA: Generically. 
MR. LINK: Okay. 
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THE WITNESS: And then -- and then it 
was an assessment of punitive damages, 
which, from the best that any of us could 
tell, it appeared that his net worth was 
going to be in the range of $2 billion. And 
the idea of punitive damages was to punish 
him for the conduct that he committed 
against that particular victim as well as to 
deter him from engaging in similar conduct. 
So understanding just how many other 
victims had been abused, how long he had 
been abusing these victims, with what --
with what frequency he was engaging in this 
conduct, were all variables that would go 
into making a determination just what amount 
of money somebody would have to assess 
against him to deter him from this habitual 
conduct that he had been engaged in for 
many years. 
So when I put into a complaint that we 
were requesting $50 million -- which is the 
exact same number that Jeff Herman put into 
his complaint -- I thought that was a very 
fair number. 
And in fact, I always knew that if you 
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took a billion dollars from Jeffrey Epstein 
and left him with a billion dollars, you 
would not have actually satisfied the rule 
under punitive damages, because he would not 
have been deterred from that future conduct 
and using his money to create this pyramid 
of underaged girls that he could abuse. 
So all of that was what went into how I 
assessed the value of all of these cases. 
BY MR. SCAROLA: 
Q 
Your earlier testimony established that 
there were two separate cases filed in different 
jurisdictions on behalf of 
One claim filed in 
state court, one claim filed in federal court, 
correct? 
A 
Correct. 
Q 
You have also acknowledged that both of 
those claims arose out of the same misconduct on 
Jeffrey Epstein's part, correct? 
A 
That's correct. 
Q 
Did the federal lawsuit seek the same 
relief that the state lawsuit sought? 
A 
No. 
Q 
Explain that, if you would, please. 
A 
So when Jeffrey Epstein agreed to a 
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non-prosecution agreement with the federal government, 
there was a provision within that agreement that said 
that if one of his victims brought a case against him 
exclusively under 18 USC 2255, then only under that 
circumstance of bringing that case exclusively under 
that count would Jeffrey Epstein not contest liability 
and agree to a minimum statutory damage amount of 
$150,000. He later contested and said that an earlier 
application of the statute applied and it should only 
be $50,000. 
But nonetheless, that was the general 
principle. That statute did not allow for punitive 
damages. And as I just explained, we assessed the 
punitive damages as being extraordinary in the case. 
So that's the answer to that question in 
terms of the difference of the damages that we were 
claiming in the state action, which contained a 
claim for punitive damages and proceeded under 
common law theories of battery or intentional 
affliction, emotional distress. Those kinds of 
things in the federal claim was to proceed under 18 
USC 2255. 
What happened in the summer of 2009 was 
that it was realized -- like I said, not by me -- it 
was initially realized by Mr. Cassell, but I agreed, 
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that III.'s case was proceeding only in state court, 
and that we had not taken advantage at all of the 
provision in the non-prosecution agreement, which 
would allow for statutory damages under 18 USC 2255, 
and that 
's birthday -- 21st birthday, I 
believe -- was coming up in August, and that the 
statute of limitations would run -- or begin to run 
at that birthday for bringing the 2255 claims. 
Q 
Explain to the ladies and gentlemen of the 
jury, if you would please, what the statute of 
limitations as applied under the circumstance meant. 
What was the significance of the statute of 
limitations? 
A 
Well, the statute of limitations in any sense 
is you only have so long from the time that the tort or 
the crime is committed to bring a claim, otherwise it's 
waived forever. 
So what we did not want to do is fail to 
bring the claim under 2255 and that claim expire at 
her 21st birthday, and it ultimately be a more 
beneficial claim to have brought and us not have the 
ability to bring it any more. Because it was also 
around that same time that we began to believe 
that -- there was an argument -- and perhaps the 
right argument -- the argument that I still believe 
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to this day probably we would win on, but it never 
got tested -- was that while Jeffrey Epstein, under 
2255, would have to agree -- if you exclusively sued 
him under that -- would have to agree to admit to 
liability and to statutory minimum damages of 
150,000. It was his position that that would be the 
maximum regardless of the number of times that he 
molested that particular person. 
IMIIIII's circumstance, she had been 
molested by him for years and dozens and dozens and 
dozens of times. I don't know how many times. 
Maybe 100 times while a minor. So we started to 
think, you know what, if you settled one of these 
cases for $150,000, it's grossly undervaluing the 
case. If he has to admit to liability and you can 
multiply 150,000 times the number of offenses that 
he committed, it saves that victim from having to 
endure extensive discovery and intimidation that 
they -- especially 
-- was having to endure. 
And if we win that argument, then that's definitely 
the best way to try this case, especially for 
Q 
Why that difference? Why would 
be 
shielded from abuse to which she was subjected in the 
state court proceeding if the determination was made 
to proceed in federal court under 18 USC 2255? 
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A 
If that determination was made in federal 
court, she would not have been shielded in state court, 
but we could have dismissed the state court claim and 
only proceeded under the federal case. Then we would 
be presenting a case in front of the jury where all of 
the -- let's call it dirt that Jeffrey Epstein had dug 
up about 
would not be -- would not all have to 
come into evidence, and we could save her some of the 
problems that we assessed as being problems with her 
case. 
Q 
You spoke about the statute of limitations 
andM 
turning 21. What is the statute of 
limitations that applies in a federal 18 USC 2255 
claim? 
A 
From recollection, there were two readings of 
the statute. I haven't seen the statute in a long 
time -- at least in a while -- but it's -- it uses some 
language that it's three years from the date that the 
disability no longer exists, which we interpret as her 
being a minor. So I think it's three years from the 
time that she's no longer a minor. 
So at the time she turned 21, there was an 
argument that her 2255 claims, if we chose to 
proceed under them, would have expired. 
Q 
Did the timing of the filing of that 
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