EFTA00800508

121 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
bait. He would use legitimate cases as bait for luring 
investors into fictional cases, which -- it then talks 
about -- there were legitimate cases, such as 
which were being handled -- it says here by RRA lawyer 
Bill Berger -- William Berger. Sources say they 
believe Berger wasn't involved in the scam. 
So the article is saying what Rothstein 
was doing is taking cases that were legitimate and 
being legitimately prosecuted by his firm, and 
making up a fictionalized version of it over here to 
sell to investors, not using -- not selling these 
cases or anything like that. That's not what this 
article says. 
Q 
So when you read this article and the other 
articles I have shown you, is it your position that 
Mr. Rothstein was not using the Epstein files in 
order to entice investors to participate in the Ponzi 
scheme? 
MR. SCAROLA: Sorry. That question 
confuses me, because your predicate was when 
you read these articles --
MR. LINK: This is your objection to 
form? Is this your objection to form? 
MR. SCAROLA: It is objection to form. 
MR. LINK: Then just make an objection 
Palm Beach Reporting Service, Inc. 
EFTA00800628

122 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
to form, Jack. 
MR. SCAROLA: I'm trying to understand 
what the question means. 
MR. LINK: It doesn't matter to me if 
you understand it. 
MR. SCAROLA: Are you asking him what 
the article says, or are you asking him what 
his personal belief is? 
MR. LINK: I don't know, but that's 
great coaching. How about we go back to 
object to the form. 
MR. SCAROLA: Okay. Object to the 
form. 
MR. LINK: Fair enough. 
MR. SCAROLA: Yes. 
THE WITNESS: You were actually asking 
me what my interpretation of the article is. 
BY MR. LINK: 
Q 
I did. That was before, and then I asked 
you another question. 
A 
Okay. 
Q 
And my question was, as a matter of fact --
forget what this article says -- as a matter of fact, 
do you now know that Mr. Rothstein used the cases 
that you were in charge of -- I'm not saying he did 
Palm Beach Reporting Service, Inc. 
EFTA00800629

123 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
inflate them, he didn't manipulate them, he didn't do 
other things -- but the cases you were in charge of 
against Mr. Epstein were used by Mr. Rothstein to 
attempt to perpetuate his Ponzi scheme? Is that a 
true statement? 
MR. SCAROLA: Objection. No proper 
predicate. 
THE WITNESS: What I believe, based on 
things that I have read after the fact, is 
that Rothstein used the details of the 
legitimate cases against Jeffrey Epstein to 
lure investors into purchasing some 
fictitious cases that never existed, that 
may have -- where he may have said Epstein 
was somehow involved, but he wasn't 
involved. That's what I believe to be true 
now. 
BY MR. LINK: 
Q 
Are you aware, sir, of the press articles 
and the Razorback lawsuit that alleges that the real 
Epstein files that were at the Rothstein firm were 
put in a room for investors to look at? 
MR. SCAROLA: Objection, compound. 
THE WITNESS: I'm aware of the 
Razorback lawsuit. I'm aware of -- the same 
Palm Beach Reporting Service, Inc. 
EFTA00800630

124 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
articles that you're aware of --
BY MR. LINK: 
Q 
You're aware of? 
A 
I'm aware of. 
Q 
And Mr. Epstein was aware of at the time? 
A 
How would I know? I don't know what he was 
aware of. 
Q 
Do you think he was probably aware of the 
one with his picture that says, "Epstein was bait"? 
A 
No idea. Regardless, it has nothing to do 
with him. He's not suffered any damage by -- no matter 
what type of spin of this whole thing that you try to 
create, there's no damage to Mr. Epstein that Rothstein 
was telling a random story about him about fake cases. 
Q 
Okay. 
A 
It doesn't make the legitimate cases 
fabricated. That's absurd. 
Q 
So is there someplace in what we're looking 
at, Exhibit 1 here, this affidavit, where Mr. Epstein 
ever says that the three individual clients that you 
represented and the cases that they filed in court 
were somehow not legitimately filed? 
MR. SCAROLA: Are you asking whether 
that appears in the affidavit? 
MR. LINK: Yeah. 
Palm Beach Reporting Service, Inc. 
EFTA00800631

125 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
BY MR. LINK: 
Q 
I'm not sure -- you've given me that 
speech. Is there anything in here? 
A 
Sure. I mean, his complaint against me, that 
I committed RICO and fraud and perjury and all of these 
other crimes that he accused me of, is all about this 
allegation that I fabricated the cases on behalf of 
basically fictitious victims against him. And he 
elaborated on that in his deposition and said that I 
ginned up the cases. I mean, yeah, that's what his 
complaint is about, the fabricated cases. 
Q 
I'm asking. Is that what Mr. Rothstein 
did? Did Mr. Rothstein do everything that you just 
described to me? 
A 
I don't know. I know what you know. 
Q 
Based on what you read. Based on what you 
have read, did Rothstein make up stories about 
Epstein --
A 
Yes. 
Q 
-- in order to lure investors? 
A 
It appears that way from exactly what you're 
looking at. Rothstein made up Epstein stories and 
whatever stories about whoever else in the world to try 
to run a Ponzi scheme. 
Q 
Agreed. 
Palm Beach Reporting Service, Inc. 
EFTA00800632

126 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
A 
We agree. 
Q 
So take a look at paragraph seven. You see 
it says, "In November 2009, Mr. Epstein became aware 
of news stories that, as a result of the Ponzi scheme 
at RRA, the Florida Bar had commenced investigations 
into over one half of the attorneys employed by RRA." 
Did the Florida Bar commence 
investigations into over one half of the attorneys 
employed by RRA? 
A 
I don't know. 
MR. SCAROLA: Excuse me. I object to 
the predicate of the question, not to the 
question. 
BY MR. LINK: 
Q 
Did you see news stories back in 
November 2009 that made that statement? 
A 
I don't think so. I'm not saying they don't 
exist. I just didn't see them. I wasn't watching all 
of RRA news stories about the implosion. I was more 
worried with starting a new firm and dealing with the 
lawsuit that was filed against me and that fallout. 
Q 
I understand. Let me ask you this. Do you 
have any information that would make you think 
or 
any evidence that you could present that would show 
that the statement in paragraph seven was untrue at 
Palm Beach Reporting Service, Inc. 
EFTA00800633

127 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
the time that it was made? 
A 
So he -- he is making this statement on 
June 30th, 2017, this year, about --
Q 
News stories that existed in 2009. I'm 
asking you 
A 
That's not what this is about. It's about --
you're talking paragraph seven. 
Q 
Yes. 
A 
Which says, "I also became aware --" 
Q 
You missed the first three words. 
A 
In November of 2009. 
Q 
Right. 
A 
News stories about the Florida Bar 
investigation? 
Q 
Right. And I'm asking you, do you have any 
evidence that, in November 2009, there were not news 
stories that the Florida Bar had commenced 
investigations into over one half of the attorneys 
employed at RRA? 
A 
I don't have evidence one way or the other, 
whether there were news stories, whether there weren't, 
or Jeffrey Epstein knew about them or he didn't, or he 
became aware or he didn't. I don't know any of those 
things. 
Q 
So let me try it again. Are you aware of 
Palm Beach Reporting Service, Inc. 
EFTA00800634

128 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
any evidence that would prove that there were no news 
stories in November 2009 that the Florida Bar has 
commenced investigations into over one half of the 
attorneys employed by RRA? 
MR. SCAROLA: Didn't Mr. Edwards just 
tell you he doesn't know one way or another? 
THE WITNESS: I have no idea. 
BY MR. LINK: 
Q 
So if I asked are you aware of any 
evidence, instead of just saying no, you want to tell 
me you have no idea, yes, no, maybe. 
A 
Am I aware of evidence? You might have it 
right in front of you right now. 
Q 
I might. I'm asking you if you're aware. 
A 
I don't see this in front of me right now. 
So I am not aware of the evidence one way or the other, 
whether the Florida Bar opened up an investigation into 
over one half of the lawyers or that there were news 
stories in November of 2009 that says that. 
All I have now right about the 2009 --
November 2009 are the things that you have given me. 
And none of them say that, at least from what I have 
read. But I'm not saying it doesn't exist. 
Q 
It's okay. Let's do this then. Let's go 
ahead and mark -- when we take a break here to eat, 
Palm Beach Reporting Service, Inc. 
EFTA00800635

129 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
we will go ahead and mark all of these news articles 
from November 2009 -- and you are welcomed to go 
through them to see if you find any evidence that 
supports a position that what Mr. Epstein is saying 
in this affidavit is untrue in any way. Okay? 
A 
What does it matter whether I know this or 
not? Either it is supported or it's not supported. 
And good. If it's supported, great. It's still 
irrelevant. And if it's not supported, okay, too. 
What does it matter what I know about 
Mr. Epstein's mental state about Florida Bar 
inquiries? 
Q 
I'm not asking about mental state at all. 
I haven't asked that question one time, sir. 
A 
He said, "when I became aware." 
Q 
I didn't ask you whether he's aware. 
That's not been my question. 
MR. SCAROLA: But you've repeatedly 
asked whether the statement in paragraph 
seven is true. And the statement in 
paragraph seven is an assertion of what 
Mr. Epstein became aware of, what his state 
of mind was, whether he knew --
MR. LINK: Is this form again? Jack, I 
remember exactly what I asked, so please, 
Palm Beach Reporting Service, Inc. 
EFTA00800636

130 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
just limit it to form, if you would. 
I know you love lecturing me, and I 
appreciate it, and you teach me every step 
of the way. But please refrain from 
counseling so much. 
MR. SCAROLA: Please refrain from 
misrepresenting the record. 
MR. LINK: I do not believe I am, and I 
will stand by the record. 
BY MR. LINK: 
Q 
And if I have somehow misled you or did 
something inappropriate on the record 
unintentionally, then I apologize, Mr. Edwards. But, 
in fact, you are not just a witness in this case. 
You are a lawyer of record, aren't you? 
A 
Yes. 
Q 
Which means that you're going to be a 
lawyer trying this case, as I understand, right? 
MR. SCAROLA: No, it doesn't mean that. 
MR. LINK: He can't answer that? 
THE WITNESS: I don't think I need to 
tell you who is trying the case. 
MR. SCAROLA: I'm the attorney in this 
case. 
MR. LINK: Okay. 
Palm Beach Reporting Service, Inc. 
EFTA00800637

131 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
MR. SCAROLA: Your question was about 
who is going to be trying the case. 
MR. LINK: And he can answer that. 
MR. SCAROLA: And I'm telling you who 
is going to try the case, and that doesn't 
include Bradley Edwards as a lawyer trying 
the case. 
MR. LINK: Is there a reason he 
couldn't answer that? 
MR. SCAROLA: Pardon me? 
MR. LINK: Is there a reason he 
couldn't answer that? 
MR. SCAROLA: It is not within the 
scope of his responsibility to answer it. 
It is within the scope of my responsibility 
to answer it. And if what you are really 
looking for is an answer to the question, I 
have just given it you to. 
BY MR. LINK: 
Q 
So you don't intend to participate in the 
trial of this case? 
A 
It depends on how successful you guys are in 
continuing with the case the way that --
Q 
So there's a possibility you will 
participate in the trial of this case in --
Palm Beach Reporting Service, Inc. 
EFTA00800638

132 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
A 
There's a possibility that I wouldn't even be 
alive when this case is tried if we continue going down 
this road. 
Q 
Okay, let's not talk about your pending 
death. Are you in good condition? You're health's 
okay? 
A 
I believe so. 
Q 
How old are you? 
A 
Forty-one. 
Q 
Any medication you are on? 
A 
No. 
Q 
So I'm asking you, is it your intent that 
you will participate in the trial of this case? 
A 
I don't think that I need to tell you our 
strategy as to who is going to participate at what 
stage in this case at all, nor would I ask you or 
expect for you to tell me yours. 
Q 
But you are both a plaintiff, a witness and 
an attorney representing yourself in this case? 
A 
I've agreed to that already, yes. 
Q 
Do you know why you were left off of the 
witness list for this case and were just added last 
night at 5:30 p.m.? 
A 
Again, other information that is 
attorney-client privileged information that I'm not 
Palm Beach Reporting Service, Inc. 
EFTA00800639

133 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
obligated to tell you. 
Q 
I didn't ask you about your communications 
with your lawyer. I asked if you know --
A 
How else would I know? 
MR. SCAROLA: You asked why. How else 
would he know? 
BY MR. LINK: 
Q 
Then you can say there's a privilege. 
MR. SCAROLA: That's what he just did. 
THE WITNESS: I just told you that. I 
said it. 
BY MR. LINK: 
Q 
Is there anything other than communication 
with yourself as a lawyer and with Mr. Scarola as to 
why, as the plaintiff in this case, you were not 
listed as a witness? 
A 
You would have to ask my lawyers as to 
witness lists, exhibit lists and those types of things 
that --
Q 
That you are unaware of? 
A 
That they deal with. 
Q 
Do you work on the day-to-day handling of 
the lawsuit? 
MR. SCAROLA: Objection. Work-product 
privilege. 
Palm Beach Reporting Service, Inc. 
EFTA00800640

134 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
MR. LINK: What does that tell me about 
his anticipating thoughts about trial? 
MR. SCAROLA: What he is doing in 
connection with this case is a work-product 
privilege. 
MR. LINK: I didn't ask what he was 
doing. I asked if he worked on the case 
day-to-day. I didn't ask for any specific 
thing he did, Jack. I don't know how that 
can be work product. 
You stand by your objection? 
MR. SCAROLA: Yeah, I do. 
BY MR. LINK: 
Q 
When the -- let's go back to the time 
period before the lawsuit was dismissed -- the claims 
against you were dismissed by Mr. Epstein. Did you 
work on the defense of that case? 
A 
I had no choice. 
Q 
You didn't have a lawyer. 
A 
Right, but I knew the details. I had to 
spend a lot of time defending that case. 
Q 
But you said you had no choice. When you 
represent clients, a lot of them are not lawyers, 
right? 
A 
It was the nature of the lawsuit. 
Palm Beach Reporting Service, Inc. 
EFTA00800641

135 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Q 
There was something about the lawsuit when 
it was filed that made it -- you uncomfortable 
relying on Mr. Scarola to do the work? 
A 
It required -- it was about legal actions 
that I had taken in the case. I had taken those 
actions, so I had to do the work. 
Q 
So you had to do the legal work because of 
legal actions that you had taken? Is that what you 
are telling me? 
A 
I was most equipped 
I'm a lawyer. I was 
most equipped to answer as to the falsity of the 
complaint that was filed against me. I was best suited 
to point out and to strategize as to what needed to be 
done to prove the falsity of those allegations. 
Q 
And I'm sure Mr. Scarola appreciated that 
help. 
A 
I'm sure. 
Q 
And did you draft the counterclaim? 
MR. SCAROLA: Same agreement. 
MR. LINK: Well, it can't be. You're 
seeking recovery for the pleadings. It's in 
everything you've disclosed. It can't be --
THE WITNESS: Not for the counterclaim, 
I don't think --
MR. LINK: It can't be part of the 
Palm Beach Reporting Service, Inc. 
EFTA00800642

136 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
agreement. 
THE WITNESS: For the counterclaim, we 
are not seeking fees for that. 
BY MR. LINK: 
Q 
You're not? 
A 
That's the affirmative case, as opposed to 
the defense of the case. 
Q 
Okay. 
A 
If what you're representing to me is that 
statement you just made to me is true, I will accept 
your word for it, but I don't believe it to be true. 
Q 
I'm not going to represent anything to you 
about your time. 
A 
Okay. 
Q 
If you're telling me that you are not 
that all of your time that you recorded, 1,300 hours, 
was in defending solely the claim brought by 
Mr. Epstein, then that's what you're telling me, and 
the records are what the records are. 
A 
The time records are what the time records 
are. 
Q 
But I'm asking you, are you telling me that 
the 1,300-plus hours that you are seeking 
compensation for were spent solely on defending 
against the complaint Mr. Epstein filed against the 
Palm Beach Reporting Service, Inc. 
EFTA00800643

137 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Rothstein -- against Mr. Rothstein and against you? 
A 
If you show me my time records I can answer 
that question without any doubt. 
Q 
I'm asking you. You are the plaintiff in 
this case and you are seeking that recovery. 
A 
I understand that. But why won't you give me 
something that will help to refresh my recollection on 
exactly what -- and the only thing that's holding me up 
is that there were various versions of both the 
complaint and the counterclaim that overlapped one 
another. But I believe that the time records that were 
submitted to you, which -- which is less than the total 
time records that I kept up to that point, I believe 
that they were reduced by my counsel to the time that 
was spent -- to my time that was spent defending the 
case. 
But I can tell you without any doubt, if 
you will just show me the documents, because I know 
that you have them. 
Q 
We are going to look at a lot of documents. 
A 
Okay. 
Q 
But I am certainly allowed to test your 
memory. 
A 
That's my memory. 
Q 
That's all I am doing. 
Palm Beach Reporting Service, Inc. 
EFTA00800644

138 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
I guess you are telling me that you gave 
all the contemporaneous time records to Mr. Scarola, 
and somebody in his office determined what to be 
produced as to what you're seeking recovery for. 
A 
This gets into attorney-client privilege. 
Q 
You told me you gave them all to 
Mr. Scarola, and they decided what to give me. Is 
that what you said? 
A 
There's no way for me to answer that question 
as to how the time records that were produced in this 
case came to be without getting into discussions with 
counsel. 
Q 
Did you keep contemporaneous time records? 
A 
Yes. 
Q 
So starting in -- when did you start 
keeping contemporaneous time records of the amount of 
time you spent on the Epstein versus Rothstein and 
Edwards matter? 
A 
I don't know exactly. 
Q 
You know what contemporaneous time records 
are? 
A 
Yes. 
Q 
Day-to-day, writing down your time. 
A 
I understand. 
Q 
And that's what you did. So somewhere 
Palm Beach Reporting Service, Inc. 
EFTA00800645

139 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
there is backup for what has been produced to me that 
would show me day-to-day what you wrote down on a 
day-to-day basis? Is that true? That's how you kept 
your time? 
A 
You just asked a bunch of different 
questions. Somewhere is there -- is that how I kept my 
time? Just one question and I will answer it. 
Q 
It was an amazing question if you piece 
them all together. Let's try it one by one. 
A 
Okay. 
Q 
Did you keep, starting in December 2009, 
daily time sheets? 
A 
I don't know that I started -- I don't think 
I started then. I think that it was subsequent to 
that. And I know because I remember where I was when I 
had a specific conversation that led me to begin 
keeping them contemporaneously. 
So I know that there was a period of time 
that passed before I started keeping them 
contemporaneously where I had to go back and try to 
figure out for a period of a month or six weeks or 
so the time that I had spent. 
Q 
It's my understanding that the tort group, 
which you mentioned at the Rothstein firm, did not 
keep daily time records. 
Palm Beach Reporting Service, Inc. 
EFTA00800646

140 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
A 
Okay. 
Q 
Did you keep daily time records when you 
were at the Rothstein firm? 
A 
I don't think that your statement that you 
just represented is true. I think that the tort group 
did keep daily time records. But if you say it's true, 
I will accept it. 
Q 
Let me just ask about you. Did you keep 
daily time records at the Rothstein firm? 
A 
We were required to put time in daily. And I 
believe I did every -- I don't know that I did every 
day, but I did for the most part. 
Q 
So when is it that you made the decision to 
start recording your time related to the Epstein 
matter on a daily basis? 
A 
I don't know exactly. 
Q 
You said you remembered the exact precise 
time that you did it. 
A 
I remember the location where I was standing. 
I don't remember the precise day that -- I was in the 
Palm Beach County courthouse. I can picture where I 
was standing. I don't know where in the course of this 
litigation that that occurred, like what time period. 
Q 
Do you generally remember? Was it weeks? 
Months? A year? Two years? 
Palm Beach Reporting Service, Inc. 
EFTA00800647