EFTA00800508

161 
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 
firm does not represent. It's phony, and in order to 
show that what he is doing is real, he uses the real 
Jane Doe lawsuit that you're in charge of and lets 
them look at boxes. That's the way I read it. Do 
you agree with that? 
A 
I mean, I would say it differently than you, 
but I think we don't disagree too much. 
Q 
Was there ever a pre-suit settlement of 
$30 million with Mr. Epstein? 
A 
No. 
Q 
Did Mr. Epstein offer $200 million as it 
reports in paragraph four to settle the claims? 
A 
No. This has to do with a story that 
Rothstein was making up, apparently. 
Q 
Right. I understand that. But there are 
some parts of his story that weave in the reality of 
what you were doing, right. You were, in fact, 
representing Jane Doe in a lawsuit against Epstein? 
A 
Right. Girls that were actually molested by 
Jeffrey Epstein, yes, that's what I was doing. 
Q 
There were, in fact, banker's boxes of the 
actual case files for Jane Doe within the Rothstein 
offices, right? 
A 
Yes. 
Q 
Those actual banker's boxes were used by 
Palm Beach Reporting Service, Inc. 
EFTA00800668

162 
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 to show potential investors? 
A 
Invest in my story over here. And in case 
you're not believing it, look, there's an actual 
file -- these are legitimate cases and you can look it 
up on Pacer, and it's really happening. He really is 
that bad person they say he is. I think that that is 
actually what happened. 
Q 
Got it. 
A 
Yeah. 
Q 
You see here, that I said he was weaving 
some of the reality into his story --
A 
Make his story more believable, it looks 
like. 
Q 
He talks about -- he talked about -- and 
according to the Razorback complaint, the 
high-profile witnesses and the private jet. You see 
that in the middle of --
A 
Point me to it. 
Q 
-- page 13? 
A 
Okay. 
Q 
"Rothstein claimed that his investigative 
team" -- we talked about who those investigators were 
earlier right? 
A 
Right. 
Q 
-- "discovered" -- the team did --
Palm Beach Reporting Service, Inc. 
EFTA00800669

163 
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 
"discovered that there were high-profile witnesses 
onboard Epstein's private jet where some of the 
alleged sexual assaults took place, and showed D3" 
the potential investors -- "copies of a flight log 
Right? 
A 
Yeah. 
Q 
-- "purportedly containing names of 
celebrities, dignitaries and international figures." 
A 
Right. 
Q 
Did the flight log in fact contain names of 
celebrities? 
A 
Epstein's flight log does contain names of 
celebrities. Those are the people he hung out with. 
Q 
And dignitaries? 
A 
What's the definition of dignitary? I think 
so. 
Q 
Good enough for me. 
And international figures. 
A 
Yes. 
Q 
So there is some truth that Rothstein is 
weaving in, based on documents, the flight log that 
was obtained by you as the lead trial lawyer in the 
pending lawsuits? 
A 
There is some truth in the pending lawsuits? 
Q 
No. I'm saying that what Rothstein was 
Palm Beach Reporting Service, Inc. 
EFTA00800670

164 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
doing -- we all --
A 
He used actual evidence to support a 
fabricated story. 
Q 
And the actual evidence that was referred 
to here are these flight logs that you as the lead 
lawyer obtained and brought back to the Rothstein 
firm, right? 
A 
I maintain the evidence for all of my cases 
at the Rothstein firm where I worked, yes. 
Q 
That's all I was confirming. 
A 
Does it appear that Rothstein gained access 
to it and used it to support his fairytale? It does. 
Q 
It does, right? And you agree with that. 
A 
Yes. 
Q 
So paragraph 41. 
A 
Yes. 
Q 
In this case, Razorback -- this is not 
Mr. Epstein's suit, right? This is Bill Scherer 
representing the Razorback client that he represented 
suing Rothstein is making these allegations? 
A 
Yes. 
Q 
Right? Okay. 
So Mr. Scherer -- do you know Mr. Scherer? 
A 
I know him now better than I did then. I 
didn't know him at all then. 
Palm Beach Reporting Service, Inc. 
EFTA00800671

165 
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 
Q 
What was his reputation in Fort Lauderdale 
in 2009? 
A 
He owned a law firm that had been around a 
while. 
Q 
A long time, right? 
A 
Yeah. 
Q 
So Mr. Scherer prints here in his Razorback 
suit, as an example of how they were trying to lure 
investors in the Ponzi scheme, that RRA relentlessly 
pursued flight data and passenger manifests regarding 
flights Epstein took with other famous individuals, 
knowing full well that no underage women were onboard 
and no elicit activities took place. Do you see 
sentence? 
A 
Yes. 
Q 
How is it that Mr. Scherer is aware of that 
information at the time? Do you know? 
A 
That information is false, so he's not aware 
of anything. 
Here is the problem with the whole thing. 
Mr. Epstein knows that information is false. 
Q 
He knows what information is false? 
A 
It says, "RRA relentless pursued flight data 
and passenger manifests regarding flights Epstein took 
with other famous individuals knowing full well that no 
Palm Beach Reporting Service, Inc. 
EFTA00800672

166 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
underaged women were onboard." There were underage 
women onboard. Epstein knew that. So he knows this to 
be false. "And no elicit activities took place." 
Epstein knows elicit activities took place on his 
airplane, so he knows that to be false. 
He can't just adopt what Bill Scherer says 
and say, Oh, that forms the basis of something I 
believe. It can't possibly form the basis of what 
he believes, because he knows it to be false. 
Q 
Okay. So did any of the three clients that 
you represented while you were at Mr. Rothstein's 
testified that they went on Mr. Epstein's plane? 
A 
They were not three of -- they were not on 
Mr. Epstein's plane. They were not the victims on the 
plane. 
Q 
So the clients that you represented -- you 
individually while at the Rothstein firm -- your 
three clients testified or admitted that they never 
traveled on Mr. Epstein's plane, correct? 
A 
If they testified truthfully, they would say 
that. I just don't remember if they were asked that 
question. 
Q 
But you know the question is 
A 
I do know the answer to that question for 
sure. 
Palm Beach Reporting Service, Inc. 
EFTA00800673

167 
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 
Did you know that in 2009. 
A 
Of course. 
Q 
Did you know that the three clients that 
you were representing had never had sex with a 
dignitary or had been molested by a dignitary? 
MR. SCAROLA: Excuse me. The only way 
that Brad would have knowledge with regard 
to those matters would be as a consequence 
of attorney-client privilege communications. 
I think you can get the same 
information by rephrasing your question as 
to what they have testified to, but you 
can't get it that way. 
MR. LINK: Well, the reason I asked it 
that way is he doesn't really remember what 
they testified to. 
BY MR. LINK: 
Q 
Right? 
A 
Not every question. 
Q 
I got it. 
So was there any testimony from your three 
clients that anyone of the three of them had sex 
with a celebrity that's associated with Mr. Epstein? 
A 
No. 
Q 
Had sex with a dignitary associated with 
Palm Beach Reporting Service, Inc. 
EFTA00800674

168 
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. Epstein? 
A 
No. 
Q 
Had sex with an international figure 
associated with Mr. Epstein? 
A 
No. 
Q 
Touched, fondled, inappropriate activity in 
any shape, form or way with a celebrity, dignitary or 
international figure associated with Mr. Epstein? 
A 
There was not, and that's why we never made 
such allegations. 
Q 
When you were utilizing the investigators 
at the Rothstein firm, what would you have to do to 
get payment in order pay them? 
Wayne Black, as an example, you said was 
an independent person that had to be paid. What 
would you do? 
A 
Wayne Black. I think that I would just tell 
Russ Adler, Hey, I have hired this investigator. 
That's what I recall doing with Wayne Black. 
And I remember this better because I 
remember Wayne Black coming to me saying, Look, I'm 
still not getting paid, and me saying, You're 
talking to the wrong guy. Talk to Russ, because he 
is kind of the head of the tort division, for lack 
of a better word. So I'm not the guy to pay you. I 
Palm Beach Reporting Service, Inc. 
EFTA00800675

169 
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 
know I brought you in, but you have to talk to him. 
And I know that it was tough for Wayne to get paid. 
Q 
So who is Russ? 
A 
Russ Adler. 
Q 
Mr. Adler was the head of the practice 
group you worked for? 
A 
Yes. 
Q 
Mr. Adler was convicted of some crime as 
well? 
A 
Political campaign contribution something. 
Q 
And in order for you to pay an 
investigator, you had to go to Mr. Adler and ask him 
to submit a check request? 
A 
That's just overbroad. 
So Wayne Black, specifically, because he 
is outside, when it was -- I need to be hired (sic), 
I would tell Russ, Hey, this is the investigator 
that I want -- that I want to hire for this case, 
and then Russ dealt with him however it was for him 
to get paid. 
The problem was that whatever they worked 
out for him to get paid, Wayne didn't get paid, so 
Wayne came back to me saying, Hey, I'm still not 
getting paid. Nobody has paid my invoice. I would 
just pass that on to Russ. 
Palm Beach Reporting Service, Inc. 
EFTA00800676

170 
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 
Q 
What would Russ say -- Mr. Adler? 
A 
It's getting paid. 
Q 
But it never did? 
A 
I don't know. I think it did eventually get 
paid. I'm not sure that it didn't. But there was --
it was longer than I would ever go to pay my bills. I 
would pay -- he didn't pay it. 
But the other investigators -- your 
question was just overbroad -- the other 
investigators were employees of the firm, so I 
didn't go to them -- I didn't go to anybody about 
Mike Fisten or Pat Roberts, how they were going to 
get paid. They were just employees on salary, I 
believe. 
Q 
I thought that I asked it if they were not 
employees. But I may not have, so I appreciate it. 
A 
Just clarifying. 
Q 
Mr. Fisten, I read he was 
he would 
attend the meeting with the investors on the Epstein 
case? 
A 
I don't believe that. 
Q 
You don't believe that's true. 
A 
No. 
Q 
But you have seen that said? 
A 
I have seen that said somewhere. I don't 
Palm Beach Reporting Service, Inc. 
EFTA00800677

171 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
know if it's in the context of this lawsuit I have seen 
it said, or I have seen it said somewhere else. But I 
find that very, very hard to believe. 
Q 
But you know that allegation was out there? 
A 
Right. Like I am saying, I don't know if it 
was an allegation that was thrown out there by 
Epstein's defense team or by somebody else, but 
the 
first time I have heard that is not right now. 
Q 
Understood. 
Take a look, if you will, at Exhibit 7, 
please. 
(Plaintiff's Exhibit Number 7 was marked 
for identification.) 
THE WITNESS: What about Exhibit 7? 
BY MR. LINK: 
Q 
Exhibit Number 7, which is the 
versus 
Jeffrey Epstein Complaint filed January 24th, 2009. 
A 
Okay. 
Q 
This is a complaint that you drafted? 
A 
Like I told you, I think Paul drafted much 
more of this, if not the entire document. I don't know 
how much --
Q 
Take a look at the last page. This 
complaint is 234 pages long. I only see one lawyer 
submitting this complaint. 
Palm Beach Reporting Service, Inc. 
EFTA00800678

172 
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 
What do you see? 
A 
No, I submitted the complaint for sure. I'm 
the Florida lawyer. 
Q 
I have seen other pleadings that you've 
submitted and it has Mr. Cassell's name on it, has 
Mr. Howell's name on it. 
A 
Yes. 
Q 
In fact, both of them were on the state 
court complaint that you filed for 
, true? 
A 
Sure. 
Q 
But on this one, on the 234-page complaint, 
the only name on it is Bradley Edwards, Rothstein, 
Rosenfeldt & Adler, true? 
A 
That's true. 
Q 
Is that your signature? 
A 
No. 
Q 
Whose signature is that? 
A 
I don't know. I don't know. That's not my 
signature. 
Q 
Who did you authorize to sign this to file 
it? 
A 
I would have told one of the paralegals to 
file it. 
Q 
And sign your name on a federal court 
Palm Beach Reporting Service, Inc. 
EFTA00800679

173 
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 
pleading? 
A 
No. I would not have told them to do that. 
I think that typically when that is done, it's an 
electronic signature that's --
Q 
You think this is an electronic signature? 
A 
No, no, I don't think that. I'm saying when 
we file cases in federal court. 
Q 
You know what an electronic signature looks 
like, right? 
A 
I wasn't saying that. 
Q 
Okay, good. Because you just said 
typically. 
This is a real signature, agreed? 
A 
Right. 
Q 
So who signed a federal court, 234-page 
complaint for you? 
A 
I don't know whose signature that is. I just 
told you that. 
Q 
Does that signing -- having somebody else 
sign this for you, that you don't know who it is, 
comply with your Rule 11 obligations? 
A 
I did not have somebody else sign this for 
me. 
Q 
You just said it's not your signature. 
A 
It's not my signature. 
Palm Beach Reporting Service, Inc. 
EFTA00800680

174 
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 
Q 
Then who signed it for you? 
A 
I don't know who signed this. 
Q 
Okay. 
A 
I wanted it filed. I mean --
Q 
You were in such a hurry to file it that 
you couldn't sign it yourself? 
A 
Until right now I believed I signed it 
myself. I would have signed it myself. 
Q 
But you didn't? 
A 
That's not my signature. No, I didn't. But 
I wanted this filed. I'm not saying I didn't want this 
filed. I wanted this filed. I'm glad that it was 
filed. It should have been filed. 
Q 
You can't tell me who signed it for you? 
A 
No. 
Q 
Did you authorize somebody to sign this 
complaint on your behalf? 
A 
No. 
Q 
Then did you fulfill --
A 
I authorized someone to file it. I 
authorized someone to file the complaint. 
Q 
I authorize my legal assistant and 
secretaries to file things that I sign all the time. 
I assume that's what you're talking about. 
A 
Yes. 
Palm Beach Reporting Service, Inc. 
EFTA00800681

175 
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 
Q 
If I file a federal court lawsuit, 234 
pages, it will have my signature on it. 
A 
Okay. 
Q 
Isn't that what you do? 
A 
Typically. If -- yes, I would think so. 
Q 
I would hope so. 
A 
That's not necessarily true. I file 
pleadings and other lawyers in my firm file pleadings 
for me -- or sign signatures for me. 
Q 
They sign your name? 
A 
No, not sign my name. 
Q 
Somebody signed your name here? 
A 
Nobody signed my name. That doesn't say my 
name. But I agree with you that somebody signed above 
where it says my name. 
Q 
This isn't a significant block that says 
Scott Link and Kara Rockenbach and one of us signs 
for the two of us. This only has one name on it, 
Bradley Edwards. At the very least it should say 
"for." 
A 
Sure. I agree with you that this should say 
somebody is signing for me. 
Q 
So do you think it's compliant with your 
Rule 11 obligation to have somebody sign this 
234-page complaint to say, Juliette Smith for Bradley 
Palm Beach Reporting Service, Inc. 
EFTA00800682

176 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
J. Edwards complies with your obligations? 
A 
Until right now, this second, I didn't know 
that anyone else other than me signed this complaint. 
I believed that I either signed it or that it was 
electronically -- my electronic signature was on this 
complaint. 
Q 
I got it. But you see now 
A 
I see it. 
Q 
-- that it's not true. And I'm asking you 
does it comply with your Rule 11 obligations to have 
a 234-page complaint filed in federal court with a 
signature on it that's not yours and not somebody you 
authorized? 
A 
I don't know if it does or not. But I would 
sign this document. 
Q 
I understand you would. But you didn't. 
A 
And I agree with it being signed. 
Q 
And it was filed with some name that you 
don't even know who it is, do you? 
A 
Right. But I'm not running from the 
document. I agree this document should have been 
signed. It's as if -- you can treat it like I signed 
the document. 
Q 
I agree, but is that what a federal judge 
would say to you? 
Palm Beach Reporting Service, Inc. 
EFTA00800683

177 
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 
You can. 
Q 
Would a federal judge say that under Rule 
MR. SCAROLA: I am going to object to 
that question. It's argumentive. It calls 
for speculation. You don't have to answer. 
BY MR. LINK: 
Q 
You practice in federal court right? 
A 
Yes. 
Q 
You know what Rule 11 is, right? 
A 
I do. 
Q 
We have to sign under Rule 11 as lawyers? 
A 
I have never had Rule 11 sanctioned against 
me, so --
Q 
You don't know the obligations under Rule 
11 as a lawyer? Just because you haven't been 
sanctioned, that means you don't know what your 
obligations are? 
A 
I do. 
Q 
So what are your obligations? 
MR. SCAROLA: Excuse me. That question 
is argumentive. It's not relevant or 
material or reasonably calculated to lead to 
the discovery of relevant and material 
information. You don't need to answer. 
Palm Beach Reporting Service, Inc. 
EFTA00800684

178 
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 
BY MR. LINK: 
Q 
Can you please tell me, as the lawyer who 
authorized this to be filed, what your Rule 11 
obligations were in July 2009 about signing this 
pleading? 
MR. SCAROLA: Same objection. Same 
instruction. 
BY MR. LINK: 
Q 
Take a look at the civil cover sheet, last 
page. See where it says, "The above information is 
true and correct to the best of my knowledge. 
Signature of attorney of record"? Is that your 
signature, sir? 
A 
No. 
Q 
Do did you authorize that signature on this 
civil cover sheet for the federal case? 
A 
I authorized the case to be filed. That's 
all I authorized. 
Q 
Sir, listen, please. My question is really 
easy. Did you authorize somebody to sign this 
document as though they were you for this federal 
court civil cover sheet? 
A 
No. 
Q 
Let's mark this. I'll hand you Exhibit 8. 
(Plaintiff's Exhibit Number 8 was marked 
Palm Beach Reporting Service, Inc. 
EFTA00800685

179 
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 
for identification.) 
BY MR. LINK: 
Q 
Remember you mentioned earlier Cara, who 
was an attorney and former FBI agent who worked for 
Mr. Rothstein's firm, right? 
A 
Yes. 
Q 
So I'm showing you what's just been marked 
as Exhibit 8. Cara L. Holmes, is that the Cara you 
were referring to? 
A 
I think so. I didn't know another Cara, 
so --
Q 
And this is dated July 29th, 2009, right? 
A 
Right. 
Q 
About the same time that you filed the 
234-page federal court complaint, right? 
A 
Five days later. 
Q 
What does Ms. Holmes say to you about 
strategy relating to Mr. Epstein? 
A 
"I think our best bet is to go after those 
close to Epstein." 
Q 
So let's take a look at this next exhibit, 
Exhibit 9, which is the complaint filed on 
December 7th by Mr. Epstein against Scott Rothstein, 
Bradley Edwards and_ 
(Plaintiff's Exhibit Number 9 was marked 
Palm Beach Reporting Service, Inc. 
EFTA00800686

180 
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 
for identification.) 
THE WITNESS: Uh-huh. 
BY MR. LINK: 
Q 
I would like you to please identify the 
allegations in this complaint that cause your loss of 
reputation. 
A 
I would have to start basically reading the 
entire complaint into the record. 
Q 
Take your time. 
A 
You want me to read the complaint to the 
court reporter? 
Q 
No. I want you to read it to yourself 
just read it to yourself. The document is an 
exhibit. Read it, then we can go through it 
paragraph by paragraph and then you can answer my 
question. 
THE VIDEOGRAPHER: There's less than 10 
minutes left on the tape. 
BY MR. LINK: 
Q 
Why don't we take a break while you read 
the complaint, and you can -- maybe if you want to 
mark on there, why don't you mark each paragraph that 
you read that caused injury to your reputation? 
A 
How do you want me to mark it? 
Q 
Put a bracket around or a checkmark. 
Palm Beach Reporting Service, Inc. 
EFTA00800687