EFTA00800508

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Q 
2017? 
A 
Correct. 
Q 
So I want to get back to anxiety. And you 
understand what I've meant that I have anxiety every 
day. Everybody in life has levels of anxiety. You 
agree with that? 
A 
I suppose. 
Q 
I had a lot of anxiety when I took the bar 
exam. You may not have. 
A 
In some different form -- I think that's a 
word that's used that describes a bunch of different 
feelings. 
Q 
Absolutely. I agree. 
What I'm really trying to understand 
is 
I want to compartmentalize this. I'm focused 
now on 2012, once Mr. Epstein dismissed his claims 
against you in court. So from that date through 
today, that cloud is no longer hanging over your 
head. I would like to understand what your anxiety 
is that relates to the lawsuit filed in 2009. How 
it's impacting you on a day-to-day basis. 
A 
It's hard for me to answer your question, 
while along the way I'm disagreeing with the various 
statements that you're making. 
Q 
Tell me what you disagree with, sir. 
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EFTA00800528

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A 
You're making a statement the cloud is no 
longer over my head. That's the basis -- that's the 
predicate for your ultimate question. That's just not 
true. 
Q 
So as you sit here today, there's a cloud 
over your head as a result of the 2009 lawsuit that 
was filed that was dismissed in 2012? 
A 
For sure. 
Q 
And how does it impact you? What I am 
trying to understand is, you are going to ask the 
jury to award money to you based on your level of 
anxiety, right? 
That's one of the things you want the jury 
to do, is to say, I have anxiety and I want to be 
compensated. 
A 
As lawyers, what we have is our reputation. 
That's what was destroyed. 
Q 
We are going to get to reputation. 
A 
That's --
MR. SCAROLA: Excuse me. Please --
MR. LINK: I'm sorry. I apologize. 
I'm just trying to streamline this. We will 
get to reputation. 
MR. SCAROLA: Well, what will 
streamline it is if you ask a question and 
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EFTA00800529

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allow Mr. Edwards to complete his answer 
before you interrupt him. 
MR. LINK: I got it. Thank you. 
BY MR. LINK: 
Q 
So I want to make sure that I understand --
I want you to tell us -- you are asking the jury to 
award you an amount of money based on your having 
suffered every day anxiety as a result of the lawsuit 
that was filed in December 2009. Do I have that 
right? 
A 
Do you have that right? The anxiety is 
related -- directly related to the harm done to my 
reputation as a consequence of the filing of this false 
lawsuit making up that I am a criminal associated with 
who is known to be a terrible and horrible person. I 
mean, that is the -- the anxiety is related to that. 
Q 
I understand that generally. But I need to 
know specifically. Let me start by this. 
How much are you asking the jury to award 
you for your day-in-and-day-out anxiety from 
December 2009 through today? 
A 
An amount of money that fairly and fully 
would measure the magnitude of the harm done to my 
reputation, and any consequential feelings that have 
resulted or continue to exist because of the damage 
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EFTA00800530

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done to my reputation. 
Q 
How much are you asking for, sir, as it 
relates to anxiety? 
A 
I just explained to you. 
Q 
There's not a dollar figure? 
A 
What six people believe will measure the 
magnitude of the harm that was done. If we want to 
talk about the harm that was done, and then me tell you 
how I would measure the magnitude of that damage, I 
will try to walk you through that. 
Q 
That would be great. But let's start here. 
I want you to start with telling me has the anxiety 
from 2009 through today increased or decreased? 
A 
Until -- until the truth is known and this 
case is behind me, it's the same. 
Q 
So the anxiety level you have been burdened 
with every single day since December of 2009 hasn't 
changed in a positive or negative way? 
A 
Well, there's no scale for anxiety. You know 
this. Like you said, you have anxiety every single 
day. It's not like you wake up and there's an anxiety 
meter. 
Now, when I was first served with the 
lawsuit and people were asking about it and people 
were talking about it all the time as, Hey, look, 
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so-and-so is also saying this lawsuit was filed. 
There's these big-time lawyers that are behind it 
pushing this. People are now believing that you're 
part of this. 
Now, when you're hearing that all of the 
time and you're having to deal with that on a 
day-to-day basis, then your anxiety level, to use 
your word, is -- I wouldn't say higher, but it's 
aggravated on a more consistent basis. 
Q 
So --
A 
These days I hear it less. 
Q 
So from 2009 through today, what other 
events have happened, other than the December 2009 
Epstein lawsuit against you, that have caused you 
anxiety? Anything? 
A 
Nothing that comes to mind. 
Q 
Any mortgage foreclosure actions against 
you during that time period? 
A 
Did I have a foreclosure action? I think I 
did, but not one that caused me anxiety. 
Q 
So having your house sold at sale didn't 
cause you any anxiety? 
A 
No. 
Q 
Ever get sued for not paying a credit card 
after 2009? 
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EFTA00800532

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A 
Could you show me something to refresh my 
recollection? I don't remember that. 
Q 
Being sued for not paying a credit card, 
would that cause you anxiety? 
A 
No. I don't remember it, so it doesn't. 
Q 
Any other lawsuits filed against you for 
not paying your debts, for money that you owed to 
people or banks? 
A 
Talking about since 2009? 
Q 
Yes, sir. 
A 
Do you have anything that could refresh my 
recollection on this? Not that I recall. 
Q 
As you sit here, you don't remember being a 
defendant in a civil lawsuit where any entity has 
claimed you did not pay them money that you owed 
them? 
A 
Ever in my life? 
Q 
No. Since 2009, sir. 
A 
I had an action that resulted from a line of 
credit that I had prior to going to RRA, that I was 
told when I went to RRA was going to be paid, and it 
wasn't. And I resolved that at some point in time 
after suit was filed. 
Yeah, I believe that suit was filed and 
then I resolved the case. It's not something that 
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caused me anxiety. 
Q 
So the three lawsuits that we just 
discussed where you were sued for not paying your 
debts back, that didn't cause you any anxiety; is 
that right? 
A 
Right. There was never a time where I wasn't 
going to pay my debt, so it didn't cause me anxiety. 
Q 
Well, your house was sold at a foreclosure 
sale, wasn't it? 
A 
The answer to your question is yes. 
Q 
That didn't cause any anxiety? 
A 
No. The circumstances of that did not cause 
me anxiety. 
Q 
And you said that Mr. Rothstein promised to 
pay off your $200,000 credit line that you took out 
in order to start your sole practice as a lawyer; is 
that right? 
A 
He promised to pay the credit line over the 
time that I was employed at RRA at some point. I don't 
remember it being $200,000. You are just throwing 
these facts into the question that I don't recall. 
Q 
So how much money did you borrow in order 
to start your sole practice law firm? 
A 
I don't remember that. 
Q 
Did Mr. Rothstein promise you during the 
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time that you were interviewing that he would make 
the monthly payments or he would pay whatever that 
amount was off? 
A 
My meeting with him was about 10 minutes. 
And what he said was, do you have a line of credit? 
Don't worry about it. It will be paid off at some 
point in time that you are at this firm. We are going 
to treat you fairly. That was it. There was no 
specifics about it. Nobody laid out the credit line. 
It wasn't that kind of meeting. 
Q 
I got it. 
Did you ever ask Mr. Rothstein to pay it 
off during the time that you were employed by him? 
A 
No. I hardly talked to the guy. 
Q 
My question wasn't whether you talked to 
him. It was whether you ever asked him to fulfill 
A 
In order to ask somebody you have to talk to 
them. 
MR. SCAROLA: Excuse me. Doesn't 
asking involve talking? 
MR. LINK: You can do it by email or 
letter. Lots of different ways, 
Mr. Scarola. 
BY MR. LINK: 
Q 
But did you, in any form of communication, 
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ask Mr. Rothstein to fulfill his promise to you -- as 
an inducement to become an employee there -- that he 
would pay off whatever line of credit you had? 
A 
No. 
Q 
No. You did not? 
A 
Right. I answered the question. No. 
Q 
I just didn't hear you. 
A 
Still no. 
Q 
Were there any other financial incentives, 
other than paying off the line of credit, in the 10 
minutes you spent with Mr. Rothstein, that made you 
decide that's the place you wanted to work? 
A 
No. 
Q 
Anything else since 2009 through today that 
has caused anxiety, other than the fact that 
Mr. Epstein filed his claim in December? 
A 
I think I told you. That word encompasses so 
many different feelings. Like you said, we all feel 
anxiety to some degree every single day. 
I mean, I try cases. I'm a trial lawyer, 
so there's anxiety. There's healthy anxiety. 
There's unhealthy anxiety. Do things cause anxiety? 
Everything causes some form of anxiety. 
Q 
So you get anxious before you try a case? 
A 
Sure. 
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EFTA00800536

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Q 
You have anxiety? 
A 
For sure. 
Q 
Have you communicated to any of the folks 
you've represented since 2009 that you are suffering 
from a high level of anxiety, an anxiety that should 
be compensated by a jury in describing for them 
whether you were fit to represent them? 
MR. SCAROLA: Objection. 
Attorney-client privilege. Don't answer 
that question. 
BY MR. LINK: 
Q 
Have you not retained -- have you not been 
retained by any client since 2009 as a result of this 
compensable level of anxiety that you suffer every 
day? 
A 
Explain your question a little better. 
Q 
Are there any clients that you wanted to be 
your client that said, I'm not going to hire you, 
Mr. Edwards, because I can see you're manifesting 
some level of anxiety, that's not just a typical 
anxiety that we all go through, it's a heightened 
level, it's a compensable level, as a result of 
Mr. Epstein's lawsuit? 
A 
No. 
Q 
Any clients fire you as a result of this 
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EFTA00800537

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heightened level of anxiety? 
A 
No. 
Q 
Have you made more money collectively each 
year from January 2010 forward to today than you did 
January 2010 back to when you started practicing law? 
You are staring at your lawyer. You want 
an objection. 
A 
I will answer the question if he wants me to 
answer the question. 
MR. SCAROLA: You can answer that 
question. 
BY MR. LINK: 
Q 
I'm asking big picture. 
A 
All right. Can you repeat the question? 
Q 
Let me do it again. It will probably be 
easier. The good news is, I never remember what just 
came out of my mouth. 
Here is the point. I want to look at this 
injury to your reputation and your embarrassment and 
all of these other things you are asking the jury to 
award money to you for, right? That's what you're 
asking the jury to do, to compensate you for the 
impact that the Epstein lawsuit had on your ability 
to practice law. True? 
MR. SCAROLA: No. 
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EFTA00800538

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THE WITNESS: I can't tell if you're 
talking or asking a question. 
MR. SCAROLA: There is no claim in this 
case for either lost earnings or diminished 
earning capacity. That's been made clear on 
the record previously. 
MR. LINK: I understand that, and 
that's not -- let me back up. That's a good 
point. Mr. Scarola, thank you for helping 
me with that. I appreciate it. 
BY MR. LINK: 
Q 
Is the reputation that was injured Bradley 
Edwards as an individual, or Bradley Edwards as a 
licensed practicing lawyer? 
A 
Both. 
MR. SCAROLA: Excuse me. I'm going to 
object to the form of the question. It 
attempts to draw a distinction that makes no 
sense to me. 
BY MR. LINK: 
Q 
We all have a reputation as a person in our 
community, just as a father, as a husband, right? In 
our regular community we have a reputation, right? 
A 
Okay. 
Q 
Do you? 
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A 
Do I have a reputation? 
Q 
Yes, sir. 
A 
Everybody has a reputation. 
Q 
Right. Then we have -- separate from that, 
we have a reputation. If we're lawyers, we have a 
reputation with judges. We have a reputation with 
opposing counsel. We have a reputation with our 
co-counsel. And we have what I will call a 
professional reputation. And we spend a lot of time 
and effort protecting our professional reputation. 
You agree with that statement? 
A 
Yes. 
Q 
What I'm trying to understand is, was it 
your 
are you seeking compensation from the jury 
for the filing of that complaint based on harm to 
your reputation in your professional capacity as a 
lawyer or in your personal capacity as a husband? 
MR. SCAROLA: And I object to the form 
of the question, because it leaves out the 
obvious third alterative, which is both. 
BY MR. LINK: 
Q 
You can answer my question. 
A 
Both. I answered the question the first time 
both. 
Q 
Can you separate for me -- and tell me from 
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a compensatory standpoint money the jury should award 
to you, what has happened to your reputation from a 
personal standpoint? Give me an example. 
Do you have friends that will no longer 
talk to you since the filing of the complaint by 
Mr. Epstein? 
A 
Do I have friends who don't talk to me 
because of that? 
Q 
Yeah. Do you have friends that --
A 
You are talking about the people who knew me? 
The people who knew me? 
Q 
Yeah. 
A 
No. 
Q 
So in November of 2009, before the lawsuit 
was filed, I assumed you had friends, right? 
A 
Right. 
Q 
Do you still have those same friends today 
for the most part? 
A 
I still have friends today. 
Q 
Did anybody come up to you and say, Listen, 
Brad, you know, I used to like you and I used to like 
being your friend. You were a swell guy to hang out 
with, but geez, I see Epstein filed this claim 
against you and I don't want to be your friend 
anymore? 
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EFTA00800541

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A 
Are you talking now about lawyers or are you 
talking about --
Q 
No, personal. 
A 
People who are nonlawyers. 
Q 
Nonlawyers. Because you said both. 
A 
I'm just trying to get a category so I 
understand the question. So have nonlawyers come up to 
me and say I will no longer be your friend because of 
the lawsuit? 
Q 
Yeah. 
A 
No. 
Q 
Do you go to a church? 
A 
Not regularly. 
Q 
Did you go to a church in 2009? 
A 
Periodically. But nobody has come up to me 
at church and said I'm not going to be your friend 
anymore or associate with you because of this lawsuit. 
The people who know me don't do this. 
Q 
So from a personal standpoint anyone who 
knew you, your reputation really didn't take a hit as 
a result of Epstein filing his lawsuit in 
December 2009. 
A 
The lawsuit is not about -- about 
reputational damage that was caused to me by the people 
who know me well. The people who know me well know 
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that those things are not true. 
The lawyers I practice with know that 
those things are not true. It's the rest of the 
world that --
Q 
Oh, okay. 
A 
Your reputation is made up of what society 
thinks of you. The people who don't know me and only 
got a snapshot of this person -- is Rothstein's 
co-conspirator in a Ponzi scheme and continue to spread 
that message from that point in time forward, whether 
it's 9 million people or 100 million people, my 
reputation right there suffered damages that, unless 
and until a jury returns a verdict in my favor, can't 
be undone. 
Q 
So these are the nameless, faceless folks 
that you don't know, that you have never met, never 
had conversations with, never interacted with, who 
are -- that have impacted your reputation. 
A 
Your question is way too extreme. 
Q 
So you told me it's anyone who knows you, 
knows for sure that there's nothing 
A 
I didn't tell you that. 
Q 
You didn't? 
A 
No. Who knows me well. 
Q 
They have to know you well, right? 
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EFTA00800543

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A 
Can I just finish my answer? 
Q 
Sure. 
A 
I let you finish every question. You refuse 
to let me finish the answer. 
Q 
Answer away, sir. 
A 
If it's an attorney who knew me well before 
this, who worked with me, knew my ethics, knew my 
abilities as a trial lawyer, they knew this to be 
false. 
If it were lawyers who did not know me or 
knew of me but didn't really know me well, then 
certainly this looks like where there's smoke 
there's fire, and it impacts your reputation in the 
minds of all of those people. 
Whether lawyers or nonlawyers, the same 
exact thing can be said for the rest of the 
9 million or so people who saw these false 
allegations. 
Q 
So I like the where there's smoke there's 
fire. That's an interesting statement. Would the 
same thing be true about what Mr. Rothstein was doing 
that where there's smoke there's fire? 
A 
What does your question mean? 
Q 
Well, you used this analogy where there's 
smoke there's fire. You saw the press that was out 
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about Mr. Rothstein in November -- the month of 
November 2009 describing all of the vehicles he owned 
and something about a pair of $1.5 million 
Lamborghinis or something, mansions and a 
million-dollar wedding, and $8 million home here, and 
a $7 million home there -- these numbers may not be 
exactly accurate, but close to that. And how the law 
firm was 70 lawyers, and a payroll of X dollars was 
surviving, and that there was a lot of speculation in 
the press about how Rothstein did it, whether he did 
it alone, and whether there were potential unnamed 
co-conspirators. Do you remember reading about that? 
MR. SCAROLA: Excuse me. I am going to 
object to the question. It grossly 
compound, it lacks factual predicate, and is 
not capable of reasonably being responded 
to. 
BY MR. LINK: 
Q 
Give it a try. 
A 
Some of those things I believe I read about 
or was told about after the implosion of RRA. Some of 
those things don't sound familiar to me at all. But 
you strung together --
Q 
A lot of stuff. 
A 
-- a bunch of things, some of which I 
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remember, some I don't. 
Q 
Let's pick it apart a little bit. When you 
worked at --
A 
I don't know what this has to do with smoke 
and fire, but 
Q 
You said where there's smoke there must be 
fire, and --
MR. SCAROLA: No, that's not what he 
said. 
BY MR. LINK: 
Q 
Well, maybe I misheard you. What did you 
say about smoke and fire? 
A 
That when someone reads the complaint about 
me, they are going to read this and believe that if 
these allegations are being made by this person, who is 
a wealthy person, who has lawyers that also have good 
reputations, and it details out like a criminal 
complaint, that if somebody is willing to make this 
type of detailed complaint it must be true 
Q 
Right and --
A 
-- about me. 
Q 
I got that. I understand that. 
By the way, you said somebody with this 
kind of money makes this complaint. So you were a 
Florida lawyer in December 2009, right? 
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EFTA00800546

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A 
Right. 
Q 
And what was Mr. Epstein, the person you 
just said if somebody makes these allegations 
everybody will believe they're true? What was his 
state in life at the time, December 2009? 
A 
He had a bunch of different states in life. 
Q 
What was it in December 2009? 
A 
I think he was out of jail. 
Q 
So he had served time, right -- jail time? 
A 
Right. 
Q 
And he was an admitted what? 
A 
Sex offender. 
Q 
Admitted sex offender who did jail time. 
A 
Right. 
Q 
And you are telling me that if somebody 
looked at the allegations made by the admitted sex 
offender who did jail time compared to you, that you 
think anybody who read them would say, We believe 
what Mr. Epstein says in here, and where there's 
smoke there must be fire so the allegations must be 
true? 
MR. SCAROLA: I am going to object as 
incomplete hypothetical. 
THE WITNESS: They are very detailed 
allegations. And when you read it in 
Palm Beach Reporting Service, Inc. 
EFTA00800547