EFTA01089004.pdf

Page 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL 1 CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA 2 INDEX CASE NO. SO 2009CA040100,0000,18 AO 3 Cow/ilex Litigation, Fla.R.Civ.Pro. 1201 4 JEFFREY EPSTER4, EXAMINATION DIRECT CROSS REDIRECT Plaintiff, VOLUME I OF II BRADLEY J. EDWARDS, ESQUIRE SCOTT ROTHSTEIN, individually, BY MR. CRITTON 5 BRADLEY 1. EDWARDS, 8 individually, and L.M. individually, 9 10 Defendants. 11 EXHIBITS 12 13 VIDEOTAPED DEPOSMON OF BRADLEY 1. EDWARDS, ESQUIRE 14 EXHIBIT DESCRIPTION PAGE Tuesday, March 23,20010 15 I 000 - 5:07 p.m PLAINTIFFS EX. I ALFREDO RODRIGUEZ 211 16 CRIMINAL COMPLAINT 2139 Pahn Beach Likes, Boulevard PLAINTIFFS EX. 2 COMPLAINT 239 West Palm Beach, Florida 33401 17 PLAINTIFF'S EX 3 JULY 22,2009 276 FACSMILE 18 Reported By: 19 Cynthia Hopkins, RPR, FPR 20 Notary Public, State of Florida Prose Court Reporting 21 Job No.: 1333 22 23 24 25 Page 2 Page 4 1 APPEARANCES: 1 PROCEEDINGS 2 On behatt of the Plaintiff: ROBERT D CRITTON, JR., ESQUIRE 2 BURMAN, CRAYON, LUTTEER & COLEMAN, LIP 3 Deposition taken before Cynthia Hopkins, 4 303 Banyan Boulevard Suite 400 4 Registered Professional Reporter and Florida West 33401 5 Professional Reporter, and Notary Public in and for Phone: 6 6 the State of Florida at Large, in the above cause. 7 and 7 8 JACK ALAN GOLDBERGER. ESQUIRE ATTERBURY, GOLDBERGER & WEISS, PA 8 THE VIDEOGRAPHER: We are now on video 9 250 Manahan Menus South 9 record. This is Media Number One in the Suite 1400 10 West laia' 33401.5012 10 videotaped deposition of Bradley Edwards in the Phone 11 matter of Jeffrey Epstein versus Scott 11 12 and 12 Rothstein, Bradley L Edwards, and L.M. 13 On behalf of the PlairtifE 13 Today is Tuesday, March 23rd, 2010 at 14 ALAN M. DERSHOWITZ, ESQUIRE HARVARD LAW SCHOOL 14 10:00 a.m. We're here in the law offices 15 Hausa 520 15 of Searcy, Denney, Scarola, Barnhart Sr Cambe id Massaclimem 02138 16 Phone 16 Shipley, 2139 Palm Beach Lakes Boulevard, 17 On behalf of the Defendant: 17 West Palm Beach, Florida. 18 JACK SCAROLA, ESQUIRE SEARCY, DENNEY, SCAROLA, 18 My name is Joe Kozak. I am the 19 BARNHART & SHIPLEY, PA. 19 videographer. The court reporter is Cindy 2139 Palm Beach Lakes Boulevard 20 West PUN. 33409 20 Hopkins from Prose, Prose Court Reporting Phone 21 Agency, 21 22 ALSO PRESENT: 22 Will counsel please introduce 23 Jeffrey Epstein 23 yourselves, and then the court reporter 24 Joseph Kozak, Videographer Prose Recoiling Smuts 24 will swear in the witnesses. 25 25 MR. CRITTON: Bob Critton on behalf of the 1 (Pages 1 to 4) IMMI PROSE COURT REPORTING AGENCY, INC. EFTA01089004  Page 5 Page 7 1 Plaintiff, Jeffrey Epstein. 1 A. I don't understand the question. 2 MR. GOLDBERG: Jack Goldberger on behalf 2 Q. For whom do you work at the current time? 3 of the Plaintiff, Jeffrey Epstein. 3 Are you an employee? 4 MR. DERSHOWITZ: Alan Dershowitz on behalf 4 A. I am a partner in the law firm of Fanner, 5 of the Plaintiff, Jeffrey Epstein, of counsel. 5 Jaffe, Weissing, Edwards, Fistos & Lehrman. 6 MR. SCAROLA: The record should reflect 6 Q. Is that a professional association? 7 that Mr. Epstein is also personally piesent. 7 A. Yes. 8 My name is Jack &tarok I am counsel on 8 Q. And you said you're a partner. Do you 9 behalf of the Defendant/Counter-Plaintiff; Brad 9 have your own P.A. or is the only the Farmer -- what 10 Edwards. 10 was the second name, Jaffe? 11 Thereupon, 11 A. Contd. 12 (BRADLEY J. EDWARDS, ESQUIRE) 12 Q. And I will refer to it as Fanner, Jaffe, 13 having been first duly sworn or affirmed, was 13 if that's all right with you. Is Fanner, Jaffe 14 examined and testified as follows: 14 itself a P.A.; that is, are you a partnership of 15 THE WITNESS: Yes. 15 P.A.'s? 16 DIRECT EXAMINATION 16 A. Yes. 17 BY MR. CRITTON: 17 Q. Do you have your own professional 18 Q. Would you please tell us your Tull name 18 association? 19 and home your home address. 19 A. Yes. 20 A. Bradley James Edwards, 1109 Northeast Second 20 Q. Okay. What's it called? Street, Hallandale Beach, Florida, 33009. 21 A. Law Office of Brad Edwards, LLC. 22 Q. Date of birth, please. 22 Q. You are the sole member of that LLC? 23 A. 11/16/75. 23 A. Yes. 24 Q. Mr. Edwards, have you ever had your 24 Q. And then your LLC is a partner of the 25 deposition taken before? 25 Fanner, Jaffe firm? 1 Page 6 Page 8 1 A. No. 1 A. Correct. 2 Q. Okay. But you've counseled, you've 2 Q. And do you hold yourself out to the public 3 obviously taken a number of depositions both as a 3 as being a partner of that firm; that is you 4 Plaintiff and as a Defendant. You're familiar with 4 individually? 5 all the rules? 5 A. What do you mean by hold myself out to the 6 A. I know the rules. 6 public? 7 Q. All right. Again if I ask you a question 7 Q. If I got your letter would your letter 8 you don't understand, if you would ask me or if you 8 say, if I received a letter from you would it say 9 want me to rephrase it, I will be happy to do that. 9 Brad Edwards, partner, or something to that effect? 10 A. Yes. 10 A. I don't think so. 11 MR. SCAROLA: Mr. Edwards, Mr. Edwards, 11 Q. Okay. What does your card say? Do you 12 knows the rules. You can drip the 12 have a business card? 13 preliminaries. 13 A. I do. 14 MR. CRITTON: Is that a form objection? 14 Q. Okay. What does your business card- 15 MR. SCAROLA: No. 15 A. Attorney. 16 MR. CRITTON: Just a talk. 16 Q. — reflect? And when you introduce 17 MR. SCAROLA: It's a, it's a request that 17 yourself to clients or other attorneys for the first 18 you not waste our time. 18 occasion, do you introduce yourself as a partner of 19 MR. CRITTON: I am not wasting your time. 19 that firm if asked? 20 And if we hadn't gone through that, we would 20 A. If asked are you a partner; is that your 21 have been done with them, Jack. 21 question? 22 BY MR. CRITTON: 22 Q. Correct. 23 Q. Mr. Edwards, are you currently employed? 23 A. Would I say yes? The answer is yes. 24 A. Yes. 24 Q. When did you start — I want to strike 25 Q. And by whom are you currently employed? 25 that. Do you consider yourself an employee of the 2 (Pa es 5 to 8) PROSE COURT REPORTING AGENCY, INC. EFTA01089005  Page 9 Page 11 1 partnership? 1 Q. She's your current secretary/paralegal, or 2 A. What do you mean by that? 2 do you have a secretary as well? 3 Q. Do you understand what an employee is? 3 A. I don't understand your question. 4 A. 1 work for the firm. 4 Q. Do you have — is Beth Williamson your 5 Q. You are certainly not -- 5 paralegal? 6 A. I am employed there, so, yes. 6 A. She's a paralegal at the law firm ofFanner, 7 Q. When did you start your association with 7 Jaffe, Weissing, Edwards, Fistos & Lehrman. 8 the Framer, Jaffe firm? 8 Q. Does she primarily work for you? 9 A. Sometime during the month ofNovember, 2009. 9 A. No. 10 Q. And is that when the firm was incorporated 10 Q. Do you have a secretary as well? 11 as a professional association? 11 A. The law firm? Yes. 12 A. I believe so. 12 Q. The secretary who works primarily for 13 Q. The attorneys who are in the current firm, 13 you — 14 are they all former Rothstein Rosenfeldt Adler 14 A. No. 15 attorneys; that is, the professional staff? 15 Q. You just use whoever is available from a 16 A. Yes. 16 secretary standpoint? 17 Q. Is there anyone — Let me strike that. 17 A. No. 18 Do you have paralegals as well that 18 Q. Who do you primarily use for secretary 19 work there? 19 services? 20 A. Yes. 20 A. There is nobody who could fall into the 21 Q. Are any of the paralegals former, and if I 21 category of who I primarily use. 22 refer to Rothstein Rosenfeldt Adler as RRA, or RRA, 22 Q. Ms. Williamson, who, by whom, who, who was 23 is that all right with you? 23 the attorney at RRA with whom she primarily worked? 24 A. I understand what you mean. 24 A. I believe it was several attorneys, and I 25 Q. Are there any other, arc any of the 25 can't tell you who the attorneys were that she worked Page 10 Page 12 1 paralegals that are currently employed by Fanner, 1 for or with. 2 Jaffe in any capacity whether they are independent 2 Q. Did she work with you at all at RRA? 3 contractors — well, let me strike that. 3 A. In some limited capacity, maybe. 4 As employee's, I probably should ask 4 Q. Did she ever work on any of the -- you 5 this question: Does the firm, Farmer, Jaffe have 5 have three cases that you ever filed -- or let me 6 employees — 6 strike that. 7 A. Yes. 7 There are three cases that are in 8 Q. — separate and apart from the partners? 8 existence at the current time. One is Jane Doe 9 A. Yes. 9 versus Mr. Epstein which is, is a federal court case 10 Q. And they are actually employed by the 1o and the Plaintiffs name is Jane Doe. That is one 11 P.A., correct? 11 of your cases, correct? 12 A. Correct. 12 A. Correct. 13 Q. Does the firm have any paralegals that 13 Q. Or one of the firm's cases at the current 14 came over from the RRA firm, RRA? 14 time? 15 A. Yes. 15 A. Correct. 16 Q. Who are they? 16 Q. There is another case versus L.M. Versus 17 A. Maria and Beth. 17 Jeffrey Epstein and a third called E.W. versus 18 Q. Does Maria have a last name? 18 Jeffrey Epstein, correct? 19 A. Yes. 19 A. Yes. 20 Q. What is it, please? 20 Q. And as a result all three of those cases 21 A. I believe it's pronounced Kelljian. 21 currently now are firm cases, the Fanner, Jaffe firm 22 Q. Can you spell it? 22 cases? 23 A. I can give it my best shot, K-E-L -L -J-I-A-N. 23 A. Yes. 24 Q. And Beth's last name is what, please? 24 Q. Did Mrs. Williamson work on any of those 25 A. Williamson. 25 cases? 3 (Pages 9 to 12) PROSE COURT REPORTING AGENCY, INC. EFTA01089006  Page 13 Page 15 1 A. In what time period? What's your question? 1 substitution of counsel. Did you, were the 2 Q. I'm sorry. During the time that you were 2 substitution of counsel's filed the exact date that 3 associated with RRA, did Mrs. Williamson work on 3 you started with RRA? 4 those cases? 4 A. 1don't remember. 5 A. Without you needing to ask 20 different 5 Q. When did your association with RRA 6 questions to get to your answer, l will tell you her 6 terminate or end? 7 involvement was that after federal motions were drafted, 7 A The end of October 2009 or the beginning of 8 she was the person to literally file the motion. That 8 November 2009. 9 is her only involvement with the cases while at RRA 9 Q. And how did it terminate? How did your 10 Q. She basically filed them through the Pacer 10 relationship with RRA terminate? 11 system? 11 A. The firm closed. 12 A. Exactly. 12 Q. Did you get, notification -- when you say 13 Q. Prior to you working at Fanner, Jaffe by 13 closed, meaning what? 14 whom were you employed? And by employed I mean in, 14 A. Meaning what everybody in this entire room 15 in a broad sense. You could have been an 15 knows is that the firm went from operating to no longer 16 independent contractor. You could have been a 16 operating. 17 partner. You could have been an employee. 17 Q. And how did you receive notice; that is, 18 A. The law femur of Rothstein Rosenfeldt Adler. 18 did you receive some sort of notice that told you 19 Q. When did you start working for RRA? 19 that RRA now is a defunct firm? Did you receive 20 A. I believe April of 2009. 20 notification that was in bankruptcy? What, if 21 Q. Beginning of April? 21 anything, did you receive? 22 A. Yes. 22 A. 1 didn't receive anything. 23 Q. I saw a pleading that was filed yesterday 23 Q. And then how did your relationship with 24 and it was either E.M., I am song, L.M. or E.W. 24 RRA end? 25 that looked like there was a change of -- I'm sorry, 25 A Came to work on a Monday morning. and there Page 14 Page 16 1 notice of appearance or something by RRA Would 1 was a meeting that was held informing all the employees 2 that, in any way, if I asked you to assume that 2 including myself that the firm no longer was financially 3 that's correct, would that refresh your recollection 3 able to survive and therefore would be immediately 4 that it may have been at the end of March? 4 closing down. 5 A. I don't understand that question at all. 5 Q. Who was the spokesperson at the meeting, 6 Q. I Saw a pleading that was filed or — 6 the main individual who advised those assembled in 7 A. Yesterday you said. 7 the room that that's what was going to occur? 8 Q. — a paper that was filed. I was looking 8 A. I don't remember. 9 at a pleading filed in either E.W. or L.M., and I Q. Was it -- did Rosenfeldt speak at all at 10 saw a paper that was basically a notice of 10 that meeting? 11 appearance on behalf ofRRA And it looked like it 11 A. I, I can't remember. 12 was dated around March 30 of 2009. 12 Q. Do you remember the date of the meeting? 13 A. Okay. 13 A. I remember that it was a Monday. 14 Q. Is it possible that you started your 14 Q. Do you remember it being in October or 15 association with RRA at an earlier date than April 15 November? 16 of '09? 16 A. Either the very end of October or the very 17 A. Assuming that what you said is true, if that 17 beginning of November. 18 document says that, then it's possible that is an 18 Q. Did anyone -- well, let me strike that. 19 accurate reflection of when I began. 19 Do you remember whether the person -- let me strike 20 Q. Did you start working with RRA before you 20 that 21 filed any documents representing that RRA or that 21 At the meeting who was present, and I 22 you had now an affiliation with RRA? 22 don't mean individual names. Who did it, by groups, 23 A. No. 23 who did it include? 24 Q. Where the — again, I don't remember, 24 A. The meeting was held in a cafeteria type roan 25 whether there was a notice of additional counsel or 25 in the building where RRA maintained its offices. And 4 (Pages 13 to 16) PROSE COURT REPORTING AGENCY, INC. EFTA01089007  Page 17 Page 19 1 die room was completely full to capacity with as many 1 A. I don't believe so. 2 employees of the Rothstein, Rosenfeldt Adler firm as 2 Q. Okay. Was anyone preventing you from 3 were in attendance at work that day. 3 taking anything? 4 Q. And included lawyers, paralegals, support 4 A. No. 5 staff, investigators? 5 Q. Okay. Did you print out any documentation 6 A. Literally — 6 from your saver or from the firds server that day 7 Q. — everyone, I mean everyone who obviously 7 to take with you? s showed up at the meeting? 8 A. Not that I recall. 9 A. I don't know. 9 Q. Do you recall taking anything from 10 Q. Did you see other lawyers there? 10 RRA'office that day, that day being that same 11 A. Yes. 11 Monday? 12 Q. Did you see staff there? 12 A. No. 13 A. Yes. 13 Q. Obviously Scott Rothstein was not there? 14 Q. Did you see paralegals there? 14 A. Correct. 15 A. Yes. 15 Q. Have you ever spoken, excuse me, have you 16 Q. Did you see investigators there? 16 ever seen Mr. Rothstein since that Monday at the 17 A. I can't necessarily remember whether or not 1 17 meeting? 18 saw investor -- investigators there. 18 A. What do you mean have I seen him? 19 Q. And did more than one person speak at the 19 Q. Seen him in person, I'm sorry. 20 meeting? 20 A. No. 21 A. I don't remember. 21 Q. Okay, have you spoken with him at any time 22 Q. Okay. What else were you advised at the 22 since the Monday meeting at which time you were 23 meeting, if anything? 23 advised that the firm was shutting down? 24 A. It was — I stayed for very little of that 24 A. No. 25 meeting. I don't know what was advised to others, but 25 Q. Have you spoken on any, with anyone on his Page 18 Page 20 1 what I heard was, firm is closing down. That's all I 1 behalf; that is, who purports to represent 2 needed to hear and I left. 2 Mr. Rothstein since you left the firm that day? 3 Q. Did you subsequent — well, let me strike 3 A. No. 4 that. Did you, were you able to gain, gain access 4 Q. Do you know Mr. Nurik? 5 to the building that day? I am sorry, access to 5 A. Yes. 6 your, to the offices of the Rothstein fnm that day? 6 Q. Do you recog -- are you aware that he 7 A. Yes. 7 represents Mr. Rothstein? 8 Q. And were you able to access any of your 8 A. Yes. 9 files or your e-mail at that time? 9 Q. Okay. Have you spoken with him since that 10 A. What time? 10 Monday? 11 Q. That same day, that Monday that you were 11 A. He called me on a morning before a hearing to 12 advised that the firm was shutting down. 12 ask me where Judge Crow's courtroom was. And I told 13 A. Yes. 13 him, and that was the extent of that conversation. 14 Q. And were you able to print documents? 14 Otherwise, I have had zero communication with Marc 15 Well, let me strike that. Were you able to take 15 Nurik. 16 documents relating to matters on which you worked 16 Q. With regard to the firm being advised that 17 from the firm? 17 the firm was shutting down on that Monday, did you 18 A. What do you mean by was I able to? 18 subsequently return to the firm's offices? Let me 19 Q. Were you able to access and take with you 19 strike that. How long did you stay at the firm that 20 documents that related to files on which you were 20 day? 21 working the preceding Friday when you were at RRA? 21 A. I don't remember. 22 A. I believe so. 22 Q. Did you stay all day? 23 Q. Did you take, did you actually remove 23 A. I believe so. 24 documents, papers that were related to files that 24 Q. Were you able to work on your files? 25 you had on which you were working from RRA that day? 25 A. I don't understand the question. 5 (Pages 17 to 20) PROSE COURT REPORTING AGENCY, INC. EFTA01089008  Page 21 Page 23 2. Q. Were you able to do legal work on the 1 entry to the office? 2 matters that wherein you represent individuals? 2 A. I don't know. 3 A. Was I able to? Yes, I was physically able to 3 Q. Well, who would, who would monitor whether 4 do that. 4 you came in or couldn't go into the office? 5 Q. Did you work on legal matters that day? 5 A. I don't know. 6 A. No. 6 Q. Was there someone there? 7 Q. Did you subsequently, after that date, did 7 A. Was there someone where? 8 you return to the RRA offices? 8 Q. The impression I got is that there was 9 A. Yes. 9 some limitation on your ability to access the RRA 10 Q. And where are those offices or where were 10 offices after the Monday at which time you were 11 those offices located? 11 advised that the firm was shutting down. Did I 12 A. Las Olas. 12 misunderstand you? 13 Q. The address, please? 13 A. No, that's correct. 14 A. I don't remember. 14 Q. Okay. Who then, if you know, or what, if 15 Q. With regard to the -- 15 it was an entity, placed any restrictions on your 16 A. 401. 16 access to RRA offices? 17 Q. Las Olas? 17 A. I don't know. 18 A. (Witness nods head.) 18 Q. When you would go to the office -- well, 19 Q. Did you, did you after that Monday did you 19 let me strike that. After how many days -- well, 20 return to the offices at 401 Las Olas, the RRA 20 let me strike that. 21 offices? 21 The very clay, the same day that you 22 A. Yes. 22 were advised that the office was closing down, were 23 Q. And did you return every day thereafter 23 there any individuals that were monitoring what, if 24 fora period of time? 24 anything, was to be removed or not removed from the 25 A. No. 25 office, like a security force, Broward County Page 22 Page 24 1 Q. Was there a point in time that you were 3. Police, U.S. Marshals. 2 prevented from entering your office or the offices 2 A. From my recollection there were at some point 3 of RRA? 3 in time, there were people in the office monitoring 4 A. Yes. 4 activity in the office. 5 Q. At what point in time were you prevented 5 Q. Was that the first week after the Monday? 6 from going into the offices? 6 A. I don't recall. 7 A. I don't remember. 7 Q. Did you ever, did you receive any 8 Q. How many days were you able to access the 8 guidelines either at the Monday meeting or 9 offices before you were prevented? 9 thereafter as to what you could or could not remove 10 A. I don't remember. 10 from the file, from the, I'm sorry from the RRA 11 Q. You don't know whether it was a day or 11 offices? 12 three days or five days that you were allowed to go 12 A. I believe so. 13 into the office? 13 Q. And who put those guidelines out, do you 14 A. The period of time that I was able to go into 14 recall? 15 the office encompasses all of those things that you just 15 A. No. 16 said, one day, three days, five days, yes. I can 16 Q. Were they in a written form? 17 definitely say with certainty I was able to do that. 17 A. No. 18 Q. During the month of October were you 18 Q. Okay. Was given in what form, how did you 19 allowed to go into the office more than ten days? 19 learn what you could and could not take from the 20 A. Yes. 20 office? 21 Q. Did they put well, et me strike that. 21 A. More nimor than anything else is what I 22 Did someone put restrictions on what your access was 22 remember. 23 to the office, the RRA office? 23 Q. Did you discuss that with other 24 A. Yes. 24 individuals or other attorneys who were working at 25 Q. Oka Who put the restrictions on the 25 RRA? )•••••taltar.oauire 6 (Pages 21 to 24) PROSE COURT REPORTING AGENCY, INC. EFTA01089009  Page 25 Page 27 1 A. Possibly. 1 management system; that is, did you utilize the 2 Q. Did you ever attempt to remove something 2 software that was available? 3 from the office of the RRA offices and someone 3 A. Yes. 4 prevented you? 4 Q. And had you ever used a system like that 5 A. No. 5 before you came to the RRA firm, RRA? 6 Q. Did you ever — and when I say remove I 6 A. I don't understand. 7 mean in the sense of physically remove; that is, 7 Q. Okay. Had you ever used an electronic 8 take out boxes or take out files or something of 8 case management software system before you came to 9 that nature. 9 RRA? 10 A. I understand the definition of remove. 10 A. Yes. 11 Q. With regard to, there were also, l 11 Q. Was yews the system that you had used 12 understand you had an e-mail server at the office? 12 before was that were you able to integrate that with 13 A. Okay. 13 RRA, with the RRA file or system when you got there, 14 Q. Is that correct? 14 or did your files have to be put on the new RRA 15 A. Yes. 15 system? 16 Q. And I have seen something, there is 16 A. The latter. 17 something that's called Qtask. Are you familiar 17 Q. In addition, so we had the e-mail server, 18 with Qtask? 18 Qtask, and electronic case management system. Was 19 A. Yes. 19 there any other type of electronic storage or system 20 Q. And what do you understand Qtask or what 20 that was available for communication or storage at 21 did you understand that Qtask did; that is, as an 21 RRA? 22 electronic service? 22 A. Not that I recall. 23 A. A web based network to store files and other 23 Q. With regard to the e-mail system, well, 24 materials. 24 with regard to the e-mail system, Qtask, and 25 Q. In terms of electronic storage, or 25 electronic case management, did you require, was Page 26 Page 28 1 electronic data at the RRA firm, in addition to, 1 there a password required to use or access each one? 2 excuse me, the e-mail server was and Qtask, was 2 A. No. 3 there anything else from an electronic storage or 3 Q. Was there a password required to use any 4 communication means through RRA? 4 of the three? 5 A. Yes. 5 A. I don't believe so. 6 Q. What else was there? 6 Q. As I saw in an order that with the Qtask 7 A. That stored electronic materials? 7 system that there was some sort of access code that 8 Q. Right, or that you could communicate with 8 was required to get into Qtask. 9 someone else either inside or out of the firm. You 9 A. I saw that too. 10 had the server, e-mail server. You had Qtask. What 10 Q. Did you ever have, did you ever have such 11 else did you have? 11 a code or a password with regard to Qtask? 12 A. To communicate with others, e-mail and Qtask 12 A. I don't remember. 13 Q. And how about within the confines of the 13 Q. Has the receiver and/or it's, Mr. Seton or 14 finis, was there another electronic mail system or 14 his attorneys asked for you to provide any passwords 15 electronic system either for storage or for 15 or information to access any of your files? 16 communication? 16 A. I don't think so. 17 A. To the best of my recollection, none for 17 Q. Do you understand that you have a 18 communication. Storage, yes. There were electronic 18 requirement or you're required to give the password 19 paperless storage case management systems in place. 19 if requested by Mr. Scion? 20 Q. And with regard to the electronic case 20 A. I don't know the password to give to anybody. 21 management system, were your files, including the 21 I never knew there was a password. 22 three cases involving Mr. Epstein, were those cases 22 Q. Did you -- 23 on the electronic case management system? 23 A. I don't believe. 24 A. Yes. 24 Q. Did you use Qtask? 25 Q. And could you access the electronic case 25 A. I have used Qtask. 7 (Pages 25 to 28) PROSE COURT REPORTING AGENCY, INC. EFTA01089010  Page 29 Page 31 1 Q. With regard to your, the files 1 either just before or just after I do believe I spoke 2 . specifically, specifically the -- well, let me 2 with one or maybe both of them on at least one occasion 3 strike that. During the time you were at RRA, of 3 before the disbandment of RRA 4 the three files, Jane Doe, L.M., and E.W. or in 4 And I know for a fact I signed each 5 addition to those three files, did you represent any 5 one of the clients up after the disbandment of RRA 6 other individuals who were potential claimants 6 I can't tell you with any degree of certainty 7 against Mr. Epstein? 7 whether they signed a fee agreement with RRA prior 8 A. I don't believe so. 8 to the disbandment. 9 Q. All right. I received notification from 9 Q. Have you been able to do any transfers of 10 you as to a Ms. N.R.? 10 your, of — let me strike that. With regard to the 11 A. N.R. 11 e-mail server at RRA, have you had ornision to 12 Q. N.R. and Ms. D.F. I believe is her name? 12 access that since that Monday; that is, the Monday 13 A. Correct. 13 meeting that you referred to in either late October 14 Q. Were either of those individuals, had 14 or early November of '09? 15 either of those individuals contacted you prior to 15 A. Yes. 16 leaving the RRA firm? 16 Q. All right. And have you had full access, 17 A. I don't believe so. 17 at some point did you get full access to all of your 18 Q. Is it your testimony then that none, 18 e-mail that, that existed at least, that you bad not 19 neither Ms. N.R. nor Ms. D.F. would have had a fee 19 removed — let me start again. 20 agreement or representation agreement with the RRA 20 Under an e-mail server you, you have 21 firm because they hadn't contacted you prior to your 21 the ability, obviously, to delete what you, what you 22 departure from that firm; is that correct? 22 choose, correct? 23 A. I'm not sure. 23 A. As do you. 24 Q. Is it possible that Ms., either Ms. N.R. 24 Q. As do I, right. And were you using like a 25 or Ms. D.F. contacted you before you left the RRA 25 Microsoft Outlook program? Page 30 Page 32 1 firm but you just didn't sign them up before you 1 A. I don't remember. 2 left? 2 Q. Okay. 3 MR. SCAROLA: Objection, calls for 3 A. I am now. 4 speculation. 4 Q. Well, with the program that you did have, 5 THE v✓ITNESS: Yes. 5 could you delete it and then you would have to go 6 BY MR. CRITTON: 6 into the delete it and further delete it to clean it 7 Q. Is there a reason that you would not have 7 out? 8 signed them up during the time you were with -- or 8 A. I don't remember. 9 let me strike that. Prior to the implosion, prior, 9 Q. You don't remember back to October or 10 prior to that Monday when you were advised that the 10 September of '09 at this point? 11 RRA firm was closing down, had you made any plans to 11 A. That's just not what I do. I mean, I don't 12 leave that firm, that is the RRA firm? 12 just delete e-mails. So I don't know what you had to 13 A. No. 13 do. You take me for somebody more e-mail savvy than I 14 Q. Okay. Had you discussed with any other 14 am about that. 15 attorneys in RRA departing from RRA or the RRA firm 15 Q. Do you basically save all your e-mails or 16 prior to that Monday meeting at which time you were 16 had you in the past when you were at RRA? 17 advised that the firm was shutting down? 17 A. I don't intentionally save or delete. They 18 A. No. 18 are just there. 19 Q. You indicated it's possible that Ms. N.R. 19 Q. And when you, when you, at some point 20 or Ms. D.F. may have contacted you prior to your 20 after the Monday meeting, were you able to transfer 21 departure or prior to that Monday meeting. What 21 whatever e-mails you had from RRA to your current 22 makes you believe that? 22 program? 23 A. I don't remember exactly the timing of any 23 A. At Farmer, Jaffe, Weissing? 24 communications between myself and Ms. D.P. or Ms. N.R. 24 Q. Correct. 25 And it seems to me that it was around the time period 25 A. No. 8 (Pages 29 to 32) PROSE COURT REPORTING AGENCY, INC. EFTA01089011  Page 33 Page 35 1 Q. Were you at some point given access to all 1. paralegals, other staff at RRAT 2 your e-mails so it could be downloaded either on a 2 A. Yes. 3 disk, hard disc, floppy disk, or some other storage 3 Q. And would you see, receive, if it was 4 medium so that you had access m all your prior 4 something from one of the other partners at RRA 5 e-mails when you were at RRA? 5 would you receive; that is, did you get fum-wide 6 A. I don't know. 6 e-mails from time to time about specific topics? 7 Q. Did you ever make that request to someone, 7 A. Yes. 8 either the receiver or anyone else associated with 8 Q. All right. When you, during the time that 9 RRA? 9 you went back to RRA, did you printout, and up until 10 A. i don't remember if l made that request 10 the time you were denied access to the e-mail 11 Q. I thought you indicated earlier, 11 server, did you ever print, printout any e-mails or 12 Mr. Edwards, that you had access to some of your 12 transfer any e-mails that you can recall? 13 e-mails. 13 A. Not that I can recall 14 A. I had access to all ofmy e-mails on that 14 Q. All right. With regard to the Qtask 15 Monday of the meeting, on the next day, on that Tuesday, 15 system, have you been, since that Monday have you 16 right, the immediately following the meeting. 32:46 at 16 been able to use that system in any fashion? 17 some point in time it was cutoff and since that time, 3.7 A. What do you mean by that? 18 when it was cutoff, I don't believe I have ever had 18 Q. Have you been able to access Qtask either 19 access back to my entire e-mail system. 19 to look to see what was there or in the alternative 20 Q. Okay. Have you had access to portions of 20 pull information from so that you could printout 21 your e-mail system? 23. information from Qtask? 22 23 A. Not that I remember. Q. Have you attempted to obtain access or 22 23 A. i don't know. Probably. Q. Okay. Have you attempted since that 1 24 requested that you obtain access or information from 24 Monday — well, after that Monday meeting — let me 25 your e-mail, from the RRA e-mail saver? 25 strike that. Page 34 Page 36 1 A. I don't remember. 1 Since the meeting that occurred on 2 Q. You say you don't remember. Would there 2 that Monday at which time you were advised the firm 3 have been a reason that you either requested or 3 was shutting down, have you accessed Qtask for any 4 didn't request access to your prior e-mail? When I 4 reason? 5 say priori mean at RRA 5 A. I don't believe so. 6 A. Usually you read all of your e-mails and there 6 Q. What kind of — you said, you described 7 shouldn't be anything that I had not read. However, 7 earlier that Qtask was a web based network of files 8 there are some e-mails that you would like to keep 8 far files and other materials. And in what fashion 9 around. So there may have been reason for me to have 9 did you use Qtask during the time you were with RRA, 10 requested. However, I don't believe I was ever granted lo RRA? 11 access to those e-mails, and i can't specifically 11 A. Qtask is a project centric web-based program. 12 remember requesting the e-mails. 12 So projects could be cre