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A 
No, it wasn't that long. It was within the 
first -- at least six, eight months of the lawsuit 
beginning. 
Q 
So then how did you create your time for 
the first six to eight months? 
A 
It could have been a month, then. You know, 
it could have been six months. 
Q 
I understand. 
A 
That's what I said. But then you said, How 
did you create it for the first six to eight months? I 
mean, there was a period of time that I had to go back 
and look at the documents that had been filed, what 
part -- what role I played in drafting those documents, 
those types of things that you would always do to go 
back and figure out how much time that you spent on 
anything. 
Q 
Well, if you're taking contemporaneous time 
records -- you're making contemporaneous time 
records, you don't have to do that. 
A 
And there came a point in time where I was 
keeping contemporaneous time records. 
Q 
You remember that point where you asked me 
to let you finish? 
A 
Yeah. 
Q 
Okay. Same deal, all right. 
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A 
Got it. 
Q 
So if you were keeping contemporaneous time 
records, you wouldn't have to go back and recreate 
your time, because it would be there day-to-day. 
A 
Agreed. 
Q 
So if you started 
you said, six to eight 
months. Let's say between one month and eight 
months -- the way you went back to recreate your time 
is to look at everything you did day-to-day and wrote 
down time for that, I take it. Is that right? 
A 
If you could just show me my time records, I 
will tell you exactly what I did to -- and I will 
probably be able to tell you when I started keeping 
contemporaneous time records 
Q 
I'm asking if you remember. 
A 
-- because it would be on a more regular 
basis. 
Q 
I'm asking you if you remember how you 
recreated the time, what you did? 
A 
Yeah. Sure. I would look at a docket. Pull 
up the pleading that had been filed, and say, Okay, I 
did -- I drafted this pleading. I know what work went 
into drafting that pleading. Probably took me two 
hours, I would say it's a .5. I will underestimate 
Q 
So you reduced your time? 
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A 
I would not exaggerate my time. 
Q 
I didn't say that. I asked if you reduced 
it. You said I spent two hours and I put down a .5. 
A 
I would make sure it was conservative, yeah. 
Q 
So when I look at your timeline here, you 
actually spent more time than you would have billed 
for? 
A 
I have spent so much more time on dealing 
with Jeffrey Epstein than I have put on any time 
record, yes. 
Q 
And in 2009, did you have any clients that 
paid you on an hourly-rate basis? 
A 
I don't remember. 
Q 
In 2010 did you have clients that paid you 
on an hourly-rate basis? 
A 
I just don't remember. 
Q 
Have you ever had a client pay you on an 
hourly-rate basis? 
A 
Yes. 
Q 
When was that? 
A 
I have clients right now that pay me on an 
hourly basis. 
Q 
When is the first one that you can remember 
that paid you on an hourly-rate basis? 
A 
Oh, God. I don't know. 2007. 
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Q 
And how much did they pay an hour? 
A 
I don't remember that. 
Q 
Do you remember how much you billed when 
you were at Kubicki Draper -- hourly rate? 
A 
I don't. 
Q 
What hourly rate -- do you have clients 
that pay you hourly rate now? 
A 
Yes. 
Q 
What rate do they pay you? 
A 
Varying, but up to 500 an hour. 
Q 
What's the lowest amount you are being 
paid? 
A 
I believe 350. 
Q 
How long ago did the client that is paying 
you 550 (sic) an hour retain you? 
A 
I said 500. And if I didn't say 500, then I 
mean --
MR. SCAROLA: You did say 500 --
BY MR. LINK: 
Q 
Maybe I misheard it. 
MR. SCAROLA: -- and it was misstated 
as 550, I'm sure inadvertently. 
THE WITNESS: What was your question 
then? How long ago? 
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BY MR. LINK: 
Q 
Yeah. How long ago did this client hire 
you and agreed to the $500 an hour? 
A 
Within the last year. 
MR. LINK: Let's go ahead -- are they 
going to bring the food here? 
BY MR. LINK: 
Q 
While we take our break, I will mark these 
and show them to you. We will do them as a composite 
exhibit. These are the November news articles we 
talked about. 
A 
Okay. 
(Plaintiff's Composite Exhibit Number 5 
was marked for identification.) 
THE VIDEOGRAPHER: The time is 
1:06 p.m. We are going off the record. 
(A recess was had.) 
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IN THE CIRCUIT COURT OF THE 
FIFTEENTH JUDICIAL CIRCUIT, IN 
AND FOR PALM BEACH COUNTY, FLORIDA 
Case No. 502009CA040800XXXXMB 
JEFFREY EPSTEIN, 
Plaintiff, 
vs. 
SCOTT ROTHSTEIN, individually; 
BRADLEY EDWARDS, individually, 
Defendants/Counter-Plaintiffs. 
VOLUME II 
VIDEOTAPED DEPOSITION 
OF 
BRADLEY EDWARDS 
Taken on Behalf of Plaintiff 
Friday, November 10th, 2017 
10:02 a.m. - 6:16 p.m. 
2139 Palm Beach Lakes Boulevard 
West Palm Beach, Florida 33409 
Examination of the witness taken before 
Sonja D. Hall 
Palm Beach Reporting Service, Inc. 
1665 Palm Beach Lakes Boulevard, Suite 1001 
West Palm Beach, FL 33401 
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THE VIDEOGRAPHER: The time is 
1:45 a.m. We are back on the record. 
BY MR. LINK: 
Q 
Mr. Edwards, take a look at Exhibit 6, 
which is the Razorback complaint. We were talking 
about it 50 minutes ago, before we broke. And I 
would like you to turn to page nine in the complaint, 
paragraph 25. 
A 
Okay. 
(Plaintiff's Exhibit Number 6 was marked 
for identification.) 
BY MR. LINK: 
Q 
During the six months that you worked at 
Mr. Rothstein's firm, were you aware that he owned an 
87-foot yacht? 
A 
I knew he had a boat. I knew he had a yacht, 
but I didn't know it was 87 feet. I had been to his 
house one time. 
Q 
I'm going to get to his house. Had you 
been on his yacht? 
A 
No. 
Q 
Had you seen it? 
A 
It was in the backyard of his house the time 
I went over. 
Q 
So you saw the 87 -- you didn't know it was 
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87 feet. However many feet the yacht was, you saw 
it. 
A 
I saw a boat back there, yeah. I mean, there 
was a canopy that was kind of blocking what I could see 
and what I couldn't, but yeah. 
Q 
And which house was it that you went to? 
A 
I only knew of one house, so I don't know. 
It was in Fort Lauderdale. 
Q 
It was in Fort Lauderdale. 
You see here it says he owned 16 different 
real estate properties, paragraph 25? 
A 
Yes. 
Q 
The house you went to was in Fort 
Lauderdale? 
A 
Yes. 
Q 
Did you go there during the time that you 
were employed by Mr. Rothstein? 
A 
Yes. 
Q 
What was the purpose of going to his house? 
Was there a function? 
A 
Yeah, it was a function. 
Q 
For employees, or was it a fundraiser? 
A 
No, it was a fundraiser of some sort. 
Q 
Do you remember for whose benefit the 
fundraiser was? 
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A 
He had his hands in so many things. 
Hospitals and -- you know, heart associations and 
whatever it was. But I don't remember which one it 
was. He had things at his house all the time. This is 
the only one I went to, but I don't remember what it 
was. 
Q 
Big house? 
A 
Oh, yeah, it was a big house. 
Q 
You see here it mentions 25 cars. Were you 
aware he had multiple cars? 
A 
I think I knew he had two. 
Q 
Which ones? 
A 
I don't remember. The one I can picture was 
either a Bentley -- I think it was a Bentley. 
Q 
Were you aware that he owned interest in 
some of the restaurants in town? 
A 
I knew he owned Bova. 
Q 
What was Bova? 
A 
It was the restaurant downstairs of the law 
firm. 
Q 
I know you had mentioned before that there 
was security -- somewhere I read that there was 
security in Mr. Rothstein 
in the offices? 
A 
There was. 
Q 
Everywhere? I never went to his offices, 
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so I don't know. 
A 
So there were uniformed, armed police 
officers on every floor. Actual, police officers. 
BSO, Fort Lauderdale police officers all the time, 
every single floor, all day, every day from the day 
that I first got there until the last day. 
Q 
Did you think that was odd? 
A 
Well, I thought it was different, for sure, 
because you don't see police officers walking around 
here. But it was actual police. It wasn't, like, the 
mob dressed as police. It was police. 
Q 
I understand. 
A 
If anything, it was -- it's crazy -- has more 
security. I did ask somebody about it one time and 
they said that a lawyer had been murdered, before I got 
there, that was a partner at that firm, and that 
Rothstein's feeling was that he doesn't want that to 
ever happen again. So if he has the money for 
additional security, why not hire Fort Lauderdale 
police and secure everybody, which was the response I 
got. 
Q 
Had you ever been in an office before or 
since that had armed police security guards? 
A 
Not like that. Maybe I have been to a bank 
and there's been one police officer there, but 
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Q 
I am talking a law firm. Any other law 
firms? 
A 
No. 
Q 
And the bank has usually one armed police 
officer. 
A 
Right. 
Q 
Bank where they keep money and stuff like 
that? 
A 
I go to the same kind of banks you do, so 
yes. 
MR. SCAROLA: You walked right past our 
security guard when you came in today. 
MR. LINK: And I was intimidated. I'm 
sure I saw him -- him, her. Just one? 
MR. SCAROLA: Just one. At the front 
door. 
MR. LINK: I saw the lions. But that's 
not the security guard. 
THE WITNESS: They transform. 
BY MR. LINK: 
Q 
The security -- in addition -- how many 
armed guards on each floor? Two? Multiple? 
A 
Multiple. 
Q 
Other than multiple armed guards on each 
floor --
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A 
Police officers. 
Q 
Police officers. 
A 
Right. 
Q 
On-duty police officers. 
A 
Appeared to be, yes. Uniformed. 
Q 
Uniformed -- okay, got it. 
Multiple on-duty, uniformed police 
officers in the building. There was also electronic 
security and cameras and stuff like that? 
A 
I think there was signage that said that 
there was cameras. Whether there was actually cameras, 
I just can't remember anymore, but I think so. 
Q 
Everywhere? 
A 
I just don't remember anymore. I don't know. 
But if you could imagine what looks like the most 
secure place, that is what the law firm looked like. 
I say that -- I remember the signage --
because I remember there being a sign that said 
there's video or audio surveillance on one of the 
doors -- one of the main doors to the building. And 
there might have actually been or there might have 
been fake cameras or something. I don't know. 
Q 
But as far as you could tell, and the 
sign --
A 
I believe there was surveillance everywhere. 
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Q 
So you worked at a law office that had 
surveillance everywhere and armed uniformed police 
guards on every floor? 
A 
The perception of surveillance everywhere, 
and yes, police officers on every floor. 
Q 
Did you ever go into Mr. Rothstein's -- as 
I understand it, he had a personal office on his own 
floor, and more secure than any banks that you and I 
go into. 
A 
Yes. There were multiple levels of security 
to ever get into his office. 
Q 
Did you ever go into his office? 
A 
I did. I had a back surgery sometime that 
summer in 2009. And because I needed time off for the 
back surgery, I went in there that time. 
Q 
To ask --
A 
To tell him, look, I need a couple weeks off 
because I'm having back surgery. That's the time I 
remember talking to him. 
Q 
He said okay? 
A 
Yeah. 
Q 
So you said multiple levels. How would I 
get to him? What did you have to go through? 
A 
I remembered it better then than I do now. 
Let me think about this. He had somebody sitting 
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outside of doors, kind of like would be normal --
probably like your offices, there's a secretary or 
paralegal or somebody there. 
That person would have -- if you didn't 
have an appointment with that person, whoever that 
person was, you could not get past that level. 
Q 
So that's the first level, the scheduling 
person? 
A 
Yeah. And that's kind of, like, normal. 
Like most -- then there was a door. I think it had --
I think you needed a key or -- like a fob to get into. 
That just got you into a hallway. It didn't really 
lead you anywhere. If you only got past that first 
level, you are just stuck for life. 
Q 
Let me make sure I've got this. I get past 
the typical reception-type person. I then, with a 
fob, get into the hallway. 
A 
Hallway. 
Q 
Then what happens? 
A 
There's another double set of doors. Looks 
like that, but just bigger doors. Looks like the doors 
that you come in through here. 
Q 
So that the jury will understand, you are 
pointing to typical wood doors -- double doors going 
into a conference room. 
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A 
And behind that would be his office. 
Q 
And what was in front of the doors? How 
did you get to those doors? Do you remember? 
A 
I think you could just walk. 
Q 
But from the hallway -- you're in the 
hallway 
A 
Yeah, I mean -- you know, it's kind of like 
you're in a corridor that's, from recollection, 12 feet 
by 15 feet. And if you walked straightforward 15 feet 
and his doors were unlocked, you could open the doors 
and you could walk in. 
Q 
And you could walk in? 
A 
Yes. 
Q 
And there he was? 
How big was his office? 
A 
As big as this room or -- yeah, as big as 
this room. 
Q 
So we're sitting in Mr. Scarola's library 
conference room. I don't know the dimensions of it, 
but maybe 30 by 30ish. Close? 
MR. SCAROLA: Thirty by 20. 
THE WITNESS: Thirty by 20. 
BY MR. LINK: 
Q 
At least that size? 
A 
From my recollection, that's pretty accurate. 
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I mean, it was big. 
Q 
Biggest law office you have been in for an 
individual lawyer? 
A 
I don't know. Top of my head 
you know. I 
think so. As big any I have been in. 
Q 
Bigger than the office you had? 
A 
Oh, yeah. Cubbyhole. 
Q 
Bigger than Mr. Scarola's office? 
A 
Mr. Scarola has a very nice office, too, 
but --
Q 
It's not that big. I have been in it, too. 
A 
Right. 
Q 
And I remember reading somewhere about 
there's a private elevator or some special elevator. 
A 
I didn't know that until after the news 
article and something came out. I never saw the 
private elevator. 
Q 
But you know what I'm talking about? 
A 
I heard about it. I think that afterwards 
there was something on the news where Kendall Coffey 
was talking about there being a private elevator, and 
that's where I learned it. 
Q 
Turn to page 12, if you would, please. 
So I apologize, but I don't think that I 
mentioned that we are looking at Exhibit Number 6, 
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which is the Razorback Funding versus Rothstein 
lawsuit filed November 20th, 2009. 
A 
Now I am on page 12. 
Q 
Now you are page 12, yes, sir. 
We are looking -- this is November 20th --
so the Razorback -- putting this in context for the 
jury, the Razorback Funding lawsuit against 
Rothstein was filed November 20th, 2009. Do you see 
that? 
box? 
A 
Where do you see --
Q 
Look at the very first page. You see the 
A 
Yeah. Okay. 
Q 
November 20th, 2009? 
A 
Yes. 
Q 
And the lawsuit that Mr. Epstein filed 
against Mr. Rothstein and you was filed December 7th, 
2009. 
A 
Taking your word for it. 
Q 
I will show you my copy. We are going to 
mark it. But you see in the middle, December 7? 
A 
Yeah, says December 7. That's when it's 
stamped into the clerk. 
Q 
So before Mr. Epstein's lawsuit, first came 
the Razorback lawsuit against Mr. Rothstein 
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chronologically? 
A 
Correct. 
Q 
If you turn -- you're on page 12, paragraph 
40. Do you see that in the Razorback lawsuit, 
paragraph 40, page 12, it talks about the Ponzi 
scheme and how one of the settlements that was being 
offered to potential investors related to Jane Doe 
versus Jeffrey Epstein pending in the Southern 
District of Florida? Do you see that? 
MR. SCAROLA: Excuse me. 
THE WITNESS: I read the paragraph. 
That's not that it says, though. 
BY MR. LINK: 
Q 
What does it say? 
A 
Well, it says, "In incertain instances, the 
purported settlements" -- talking about the Rothstein's 
fraudulent settlements -- "were based on actual cases 
being handled by RRA. For example, one of the 
settlements involved herein was based upon facts 
surrounding Jeffrey Epstein, the infamous billionaire 
financier. In fact, RRA did have inside information 
due to its representation of one of Epstein's alleged 
victims in a civil case styled Jane Doe versus Jeffrey 
Epstein pending in the Southern District of Florida." 
Q 
Keep reading up to the next -- you didn't 
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finish the paragraph where it says --
A 
I was still reading, though. 
Q 
Okay. 
A 
"Representatives of D3 were offered, quote, 
the opportunity, end quote, to invest in a pre-suit 
$30 million court settlement against Epstein arising 
from the same set of operative facts as the Jane Doe 
case, but involving a different underaged female 
plaintiff." 
Q 
Keep going, please. 
A 
Keep going? 
Q 
Yeah. Where it starts with, "To augment." 
A 
There's an attachment, too. 
But, "To augment his concocted story, 
Rothstein invited D3 to his office to view the 13 
banker's boxes of actual case files in Jane Doe in 
order to demonstrate that the claims against Epstein 
were legitimate and that the evidence against 
Epstein was real." 
Keep going? 
Q 
No. I just -- the statement that I made --
that I thought you disagreed with -- was that the 
actual Jane Doe lawsuit that you were the lead lawyer 
for was used by Rothstein to try and induce folks to 
make an investment in his Ponzi. 
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A 
I guess where we are having a disagreement is 
the word used. To me that's an implying that Rothstein 
is selling something related to the legitimate cases. 
It's pretty obvious or clear from this that what 
Rothstein was doing was using the fact that real 
legitimate cases against Epstein were actually being 
litigated in his law firm to, as this says, concoct a 
story about some other situation, and ask investors to 
buy into some made up fictitious story. 
Q 
I think we are saying the same exact thing. 
A 
Right. So we are not in disagreement. 
Q 
I think we are saying the exact same thing. 
The way I read Razorback, I believe, is the way you 
read it, which is that, yes, there are real -- three 
real lawsuits. 
A 
Right. 
Q 
That you are in charge of. 
A 
Yes. 
Q 
And those --
A 
They say one. But you are right, three. 
Q 
I know, three. 
A 
Yes. 
Q 
The three real lawsuits that you are in 
charge of, that Rothstein, to raise money, makes up 
additional information about other clients that the 
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