EFTA01102277.pdf

Epstein Deposition Questions related to his lawsuit against L.M. Page 13; Lines 11-21 — answered he was suing L.M. as part of the conspiracy with Rothstein and Edwards creating fraudulent cases of a sexually charged nature in order to fleece unsuspecting investors out of millions of dollars Questions related to what Edwards did wrong that forms the basis of Epstein's suit against him Page 23; Lines 4-19 — answered that Edwards had used the media to gin up these allegations and engaged in discovery proceedings that bear no relationship to any case filed against Epstein by ant of Edwards' clients. Rothstein firm, that Edwards was a part of, was accused of forging a Federal Judge's name Page 25; Lines 9-25 — answered Edwards personally engaged with Scott Rothstein and shared 13 boxes of information about Epstein with other attorneys at the firm. He alleged multi-million dollars in damages to scam local investors. Accused of running a criminal enterprise] Questions related to Edwards going to the media Page 26; Lines 6-15 — answered that Edwards went to the Daily News in NY and other local media and that Edwards' investigator went to California, representing that he was a FBI agent, to harass people and gather information about Edwards' claims Page 28; Lines 14-25 — answered the investigator going to California was part of Edwards' plan to involve people who have nothing to do with the cases in order to go back to the media and gin up his stories and make false accusations Page 30; Lines 6-18 — answered Edwards created false stories to local media and press and made false statements regarding false claims made by his clients so that he and Rothstein could defraud local investors Page 33; Lines 1-3 — answered Edwards alleged to the Daily News that third parties had already been involved in allegations to do with sexual misconduct Page 34; Lines 7-22 — answered "gin up" means crafted multi-million dollar numbers put on cases to fleece investors and the allegations were made about Epstein Questions related to discovery proceedings Edwards engaged in which form the basis of Epstein's lawsuit Page 36; Lines10-25 — answered Edwards participated in discovery proceedings of bringing Epstein's attorneys to various different people that had nothing to do with any of Edwards' clients or lawsuits; for example Edwards tried to depose Bill Clinton as a means of getting EFTA01102277 publicity so that he and his firm could steal money from investors. Other various people include people in California and New York Questions related to the sharing of the 13 boxes of information as a basis of Epstein's lawsuit Page 38; Lines 1-22 — answered Edwards shared the information with the partners in his firm and investors. The boxes contained multiple cases that were fabricated to fleece investors out of their money Questions related to what Edwards did with regard to sending an investigator to California which justifies a legal claim against Edwards Page 48; Lines 13-25 — answered the use of illegal activities, wire taps, and methods by Rothstein firm while Edwards had basically been bringing these cases and the investigator represented himself as an FBI agent Questions related to Epstein's knowledge about Edwards being involved in an illegal wire tap Page 49; Lines 24-25; Page 50; Lines1-4 — answered that it has been widely reported in the newspaper Edwards and his firm were involved in illegal wire taps, eavesdropping, and hiring former FBI and law enforcement in order to fabricate cases Page 50; Lines 8-25 — answered he has no personal knowledge of this, but it has been widely reported, Mr. Sakowitz went to the FBI about it, and U.S. Attorney has accused the firm of RICO Questions related to Epstein's personal knowledge that Edwards was involved in egregious civil litigation abuse Page 52; Lines10-17 — answered it is widely reported in newspaper that Edwards' firm engaged in wild discovery processes, illegal activities, and illegal eavesdropping to defraud investors Questions related to the "hardworking and honest lawyers" Edwards wants to vindicate referenced in the complaint Page 59; Lines 11-25 — answered he wants to vindicate his attorneys, himself, and other clients abused by Edwards and the Rothstein firm Questions related to Rothstein and Edwards being a part of a criminal enterprise Page 63; Lines 4-25 — answered what he meant in his complaint was that the Rothstein firm and Edwards were part of a criminal enterprise, the largest in South Florida and part of the lawsuit should vindicate, set right. Part of the lawsuit will disclose the various techniques of attorney/client privilege, abuse of discovery, illegal wire taps, forging signatures engaged in by Edwards and his firm EFTA01102278  uestion- Have you ever socialized with Tommy Mottola? Page 90; Lines 10-15 — answered this type of question shows where people have nothing to do with the case have been brought in by Edwards in an attempt to simply imperil Epstein's relationship with social friends and serves as an example of why this case has been brought against Edwards and his firm Questions related to damages Epstein claims to have suffered as a consequence of any wrongdoing on the part of Edwards Page 116; Lines 8-15 — answered the cost of ridiculous litigation, the cost of having attorneys prepare responses to wildly irrelevant discovery in various locations at a minimum Page 120; Lines 16-24 — answered apart from money paid to lawyers, the stress and emotional damage of imperiling Epstein's friendships and business relationships with no relevance whatsoever to these cases, brought by the firm to harass Epstein's friends and social contacts to fleece investors out of millions of dollars Page 126; Lines 1-5 — answered as proportionate to the amount of damages, Epstein believes Edwards played a vital role. Epstein believes his partners potentially played a role EFTA01102279