EFTA01100749.pdf

Page 1 Page 2 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL APPEARANCES: CIRCUIT IN AND FOR PALM BEACH COUNTY. FLORIDA CASE NO. 50 2009CA040800XXXX/45 AG 2 On behalf of the Plaintiff: Complex Litigation. Fla.R.Civ.Pro. 1201 3 ROBERT D. CRITTER, JR., ESQUIRE BURMAN, CRII1XNI, LAPITIER 4 COLEMAN. LLP 4 303 Banyan Boulevard Suite 400 JEFFREY EPSTEIN, 5 Nest im 33401 Phone: Plaintiff, 6 VOLUME I OF II 7 and JACK AWt GOLEBERGER. ESQUIRE SCOTT ROTHSTEIN, individually. ATTERBURY, GOLEBERGER 4 WEISS. BRADLEY J. EDWARDS. 9 250 Australian Avenue South Individually, and L.N. individually. Suite 1400 10 West Palm Raze rl ride 33401-5012 Defendants. Phone: 11 12 and VIDEOTAPED DEPOSITION OF BRADLEY J. EOSARDS, ESQUIRE 13 On behalf of the Plaintiff: 14 ALAN M. ECASHOWIT2, ESQUIRE Tuesday. March 23. 20010 HARVARD IA/I SCHOOL 10:00 - 5:01 p.m. 15 Hauser 520 Cashridiass iatts 02138 16 Phone: 2139 Palm Beach Lakes, Boulevard West Palm Beach, Florida 33401 17 On behalf of the Defendant: 18 JACK SCAROLA, ESQUIRE SEARCY, DENNEY, SCAROLA, 19 BARNHART a SHIPLEY, P.A. 2139 Palm Beach Lakes Boulevard Reported By: 20 West Pa de 33409 Cynthia Hopkins, RPR, PPR Phone: Notary Public, State of Florida 2) Prose Court Reporting Job No.: 1333 22 ALSO PRESENT: Jeffrey Epstein 24 Joseph Kozak. Videographer Prose Reporting Services 25 PROSE COURT REPORTING AGENCY.INC. PROSE COURT REPORTING AGENCY, INC. Page 3 Page 4 PROCEEDINGS 2 INDEX 3 3 Deposition taken before Cynthia Hopkins. 4 4 Registered Professional Reporter and Florida 5 EXAMINATIOR DIRECT CROSS REDIRECT 5 Professional Reporter, and Notary Public in and for 6 6 the State of Florida at Large, In the above cauee. BRADLEY J. EDWARDS, ESQUIRE 7 7 - - - BY MR. CRITTER 5 8 B THE VIDEOGRAPHER: We are now on video 9 9 record. This is Media Nusber One in the 10 10 videotaped deposition of Bradley Edwards in the 11 EXHIBITS 11 matter of Jeffrey Epstein versus Scott 12 12 Rothstein, Bradley J. Edwards, and L.M. 13 13 Today is Tuesday, March 23rd. 2010 et 14 EXHIBIT DESCRIPTICei PAGE 14 10:00 a.m. We're here in the law offices 15 15 Of Searcy, Denney, scarola, Barnhart 4 PLAINTIFF'S EX. 1 /JARED° RODRIGUEZ 211 16 CRINIIL11.02MPLAIM 16 Shipley, 2139 Palm Beach Lakes Boulevard, PLAINTIFF'S EX. 2 COMPLAINT 239 11 PLAINTIFF'S EX. 3 JULY 22. 2009 276 17 West Palm Beach, Florida. FRCS/OLE 18 18 Hy name is Joe Kozak. I am the 19 19 videographer. The court reporter is Cindy 20 20 Hopkins from Prose. Prose Court Reporting 21 21 Agency. 22 22 Will counsel please introduce 23 23 yourselves, and then the court reporter 24 24 will swear in the witnesses. 25 25 KR. CRITTER: Bob Critton on behelf of the PROSE COURT REPORTING AGENCY. INC. PROSE COURT REPORTING AGENCY, INC. EFTA01100749  Page 5 Page 6 1 Plaintiff, Jeffrey Epstein. 1 A. No. 2 I . GOLDBERG: Jack. Goldberger on behalf 2 O. okay. But you've counseled, you've 3 of the Plaintiff. Jeffrey Epstein. 3 obviously taken a number of depositions both as a MR. DERSHOWITZ: Alan Dershowits on behalf 4 Plaintiff and as a Defendant. You're familiar with S Of the Plaintiff, Jeffrey Epstein, of counsel. 5 all the rules? 6 MR. SCAROLA: The record should reflect 6 A. I know the rules. 7 that Mr. Epstein is also personally present. O. All right. Again if I ask you a question My name is Jack Sterol.. I am counsel on 8 you don't understand, if you would ask me or if yOu 9 behalf of the Defendant/Counter-Plaintiff, Brad 9 want me to rephrase it, I will be happy to do that. 10 Edwards. 10 A. Yes. 11 Thereupon, 11 NR. SCABOLA: Mr. Edwards, Mt. Edwards, 12 'BRADLEY J. E0WMDS, ESQUIRE' 12 knows the rules. You can skip the 13 having been first duly sworn or affirmed, was 13 preliminaries. 14 examined and testified as follows: 14 MR. CRITTCN: Is that a form objection? 15 THE WITNESS: Yes. IS MA. SCAROLA: No. 16 DIRECT E)U1IIINATICII 16 MR. CRITTON: Just a talk. 17 BY MR. CRITTON: 17 red. SCAROLA: It's a. it's a request that 18 O. Would you please tell us your full nave 18 you not waste our time. 19 and ix" your home address. 19 HR. CRIT70N: I am not wasting your tine. 20 A. Bradley James Edwards, 20 And if we hadn't gone through that, we would 21 21 have been done with them. Jack. 22 O. Bete of birth, please. 22 BY M. CRITTON: 23 A. 23 O. Mr. Edwards, are you currently employed? 24 O. Mr. Edwards, have you ever had your 24 A. Yes. 25 deposition taken before? 25 O. Md by whom are you currently employed? PROSE COURT REPEOTING AGENCY. INC. PROSE COURT REPORTING AGING,, INC. Page/ Page 8 1 A. I—don't understand the question. 1 Correct. 2 O. For whom do you work at the current time? 2 And do you hold yourself out to the public 3 Are you an employee? 3 as being a partner of that fire; that Is you 4 I as a partner In the law firm of Farmer, 4 individually? 5 Jaffe, Weissing, Edwards, Fistfni I Lehrman. 5 A. What do you mean by hold myself out to the 6 O. Is that a professional association? 6 public? 1 A. Yes. 7 O. If I got your letter would your letter 8 O. Md you said you're a partner. DO you say. if I received a letter from you would It say 9 have your own P.A. or Is the only the Farmer -- what 9 Brad Edwards. partner, or something to that effect? 10 was the second name. Jaffe? 10 A. I don't think so. II A. Correct. 11 Okay. What does your card say? DO you 12 O. And I will refer to it as Former, Jaffe. 12 have a business card? 13 if that's all right with you. Is Farmer, Jaffe 13 1 do. 14 itself a P.A.; that is, are you a partnership of 14 Okay. O. Mar doss your business card-- 15 P.A.'s? 15 A. Attorney. 16 A. Yes. 16 O. -- reflect? And when you introduce 1? Q. Do you have your own professional 17 yourself to clients or other attorneys for the first 18 association? 18 occasion, do you Introduce yourself as a partner of 19 A. Yes. 19 that firm if asked? 20 O. Okay. What's it called? 20 A. If asked are you a partner; is that your 21 A. Law Office of Brad Edwards, LLC. 21 question? 22 O. You are the sole member of that LW? 22 O. Correct. 23 A. Yes. 23 A. Mould 1 say yes? The answer is yes. 24 O. Md then your LLC is a partner of the 24 When did you Start -- I want to strike Q. 25 Former. Jaffe firm? 25 that. DO you consider yourself an employee of the PROSE COURT REPORTING AGENCY, INC. PROSE COURT REPORTING Aar', INC. EFTA01100750  Page 9 Page 10 1 partnership? 1 paralegals that are Currently employed by Farmer, 2 A. What do you mean by that? 2 Jaffe in any capacity whether they are independent 3 Q. Do you understand what an employee Is? 3 contractors -- well. let me strike that. 4 A. I work for the firm. 4 As employee's, 1 probably should ask 5 O. You are certainly not -- this question: Does the firm. Farmer, Jaffe have 6 I am employed there, to. yes. 6 employees -- 7 0. When did you start your esaociation with 7 A. Yea. the farmer. Jaffe firm? O. -- separate and apart from the partners? 9 A. Sometime during the month of November, 2009. 9 A. Yea. 10 O. And IS that when the firm was incorporated 10 O. And they are actually employed by the 11 as a professional association? 11 P.A., correct? 12 A. I believe so. 12 A. Correct. 11 Q. The attorneys who are In the current firm, 13 Q. Does the firm have any paralegals that 14 are they all former Rothstein Rosenfeld[ Adler 14 came over from the BAA firm, RM? 15 attorneys: that 1s, the professional staff? 15 A. Yes. 16 A. Yes. 16 Q. WhO are they? 17 Q. Is there anyone -- Let me strike that. 17 Marla and Seth. 18 Do you have paralegals as well that 18 O. Does Maria have a last name? 19 work there? 19 A. Yes. 20 A. Yes. 20 O. What is it. Please? 21 Are any of the paralegals former, and if 1 21 A. I believe it's pronounced Kelljian. 22 refer to Rothstein Roaenfeldt Adler as AM. or PRA, 22 Q. Can you spell it? 23 is that all right with yov? 23 I can give it my best shot. 24 . A. I understand what you mean. 24 Q. And Beth's last name is what, please? 25 Q. Are there any other, are any of the 25 A. Willlamson. PROSt cOURT IMPORTING AGENCY. INC. MOLE COURT REPORTING AGENCY, INC. Page 11 Page 12 1 O. She's your current eecretery/paralegal, or 1 for or with. 2 do you have a secretary as well? 2 Did she work with you at all at BRA? 3 A. I don't understand your question. 3 A. In some limited capacity. maybe. 4 O. Do you have -- is Beth Williamson your 4 Q. Did she ever work on any of the -- you 5 paralegal? 5 have three cases that you ever filed -- or let me 6 A. She's a paralegal at the law firm of garner. 6 strike that. 1 Jaffe, weissing, Edwards, ?limos a Lehrman. 7 There are three cans that are in 8 Q. Does she primarily work for you? 8 existence at the current time. One is Jane 00* 9 A. No. 9 versus Mr. Epstein which is, is a federal court case 10 Do you have a Secretary as well? 10 and the Plaintiff's name is Jane Doe. That is one 11 The law firm? Yes. 11 of your cases, correct? 12 The secretary who works primarily for 12 A. Correct. 13 13 Q. Or one of the firm's cases at the Current II 14 time? 15 O. You jest use whoever is available from a 15 Correct. 16 secretary standpoint? 16 There le another case versus L.M. Versus 11 A. No. )7 Jeffrey Epstein and a third called C.M. versus 18 Q. Who do you primarily use for secretary IS Jeffrey Epstein. correct? 19 services? 19 A. Yes. 20 A. There is nobody who could fall into the 20 0. And as a result all three of those cases 21 category of who I primarily use. 21 currently now are firm , the farmer, Jaffe firm 22 Q. Ma. Williamson. who, by whom, who, who was 22 cases? 23 the attorney at AAA with wham she primarily worked? 23 A. Yes. 20 A. I believe it was several attorneys, and 24 Q. Did Mrs. Williamson work on any of those 25 can't tell you who the attorneys were that she worked 25 cases? PROSE COURT ILEICItTING AGCMCY, INC. PROSE COURT ItUVRTING AGENCY, INC. EFTA01100751  Page 13 Page 14 1 A. In what time period? What's your question? notice of appearance or something by RIM would 2 Q. I'm sorry. During the time that you were 2 that. in any way, If I asked you to assume that 3 associated with KM. did Mrs. Williamson work on 3 that's correct, would that refresh your recollection 4 those cases? 4 that it may have been at the end of March? S A. Without you needing to ask 20 different 5 A. I don't understand that question at all. 6 question to pet to your answer, I will tell you her 6 Q. I paw a pleading that was filed or -- involvement was that after federal motions were drafted, 7 Yesterday you said. 0 she was the person to literally file the motion. That -- a paper that was filed. 1 was looking 9 is her only involvement with the cases while at RIM 9 at a pleading filed in either E.M. or L.M., and 1 10 She basically filed them through the Pacer 10 saw a paper that was basically a notice of 11 system? 11 appearance on behalf of RM And it looked like it 12 A. Exactly. 12 was dated around march 30 of 2009. 13 0. Prior to you working at Farmer, Wee by 13 A. Okay. 14 whoa were you employed? And by employed I mean In. 14 Q. Is it possible that you started your 15 in a broad sense. You could have been an 15 association with BRA at an earlier date than April 16 independent contractor. You could have been a 16 of '09? 17 partner. You could have been an employee. IT A. Misusing that what you said is true, if that 10 A. The law firm of Rothstein Rosenfeldt Adler. 18 document says that, then it's possible that is an 19 0. When did you start working for RM? 19 accurate reflection of when I beam. 20 A. 1 believe April of 2009. 20 Did you start working with RM before you O. 21 O. Beginning of April? 21 filed any documents representing that RRA or that 22 A. Yes. 22 you had now an affiliation with RRA? 23 O. 1 saw a pleading that was filed yesterday 23 No. 24 and it was either E.N., I am sorry, L.M. or E.N. 24 Q. where the -- again, I don't remember. . 25 that looked like there was a change of -- I'm sorry, 25 whether there was a notice of additional counsel or PROSE COM' REPoRTING AGENCY. INC. MEM COuRT ItteoliTim AGENCY, INC. Page 15 Page 16 1 substitution of counsel. Did you, were the 1 was a meeting that was held informing all the employees 2 substitution of counsel's filed the exact date that 2 including myself that the firm no longer was financially 3 you started with RRA? 3 able to survive and therefore would be immediettly 4 A. I don't remember. 4 doming down. 5 O. When did your association with MA 5 Q. Mho was the spokesperson at the meeting, 6 terminate or end? 6 the min individual who advised those assembled in 7 A. The end of October 2009 or the beginning of the room that that's what was going to occur? 8 November 2009. 8 A. I don't remember. 9 O. And Now did it terminate? Now did your 9 O. Was it -- did Rosenfeldt speak at all at 10 relationship with RM terminate? 10 that meeting? 11 The fine closed. 11 I, I can't remember. 12 Q. Did you get, notification -- when you say 12 0. Do you remember the date Of the meeting? 13 closed. meaning what? 13 A. I remember that it was a Monday. 71 A. Meaning what everybody in this entire roan 14 O. Do you temealier it being in October or 15 knows Is that the firm went from operating to no longer 15 November? 16 operating. 16 Either the very end of October or the very 17 Q. And how did you receive notice: that is. 17 beginning of November. le did you receive some sort of notice that told you 18 Did anyone -- well, let me strike that. Q. 19 that MA now is a defunct firm? Did you receive 19 Do you remember whether the person -- let me strike 20 notification that was in bankruptcy? What, if 20 that. 21 anything, did you receive? 21 At the meeting who was present, and I 22 1 didn't receive anything. 22 don't mean individual names. Who did it, by groups, 23 And then how did your relationship with 23 who did it include? 24 RM end? 24 A. The meeting was held in a cafeteria type room 25 A. Came to work on a Monday morning, and there 25 in the building where RRA maintained its offices. And PROSE COURT REPORTING AGENCY, INC. PROSE COURT REPORTING AGENCY. INC. EFTA01100752  Page 11 Page 16 1 the room was completely full to capacity with as many 1 what I heard was, tins is closing down. That's all I 2 employees of the Rothstein. Ronnfeldt Adler firm as 2 needed to hear and I left. 3 were in attendance at work that day. 3 O. Did you subsequent -- well, let me strike Q. And included lawyer.. paralegals, support 4 that. Did you, were you able to gain. pain access 5 staff. investigators? 5 to the building that day? 1 am sorry, access to 6 A. Literally -- 6 your, to the offices of the Rothstein firm that day? 1 O. everyone, 1 mean everyone who obviously 7 A. Yes. showed up at the meeting? 6 Q. And were you able to access any of your 9 A. I don't know. 9 files or your e-mail at that time? 10 Q. Did you see other lawyers there? 10 What time? 11 A. Yes. 11 That same day, that Monday that you were 12 Q. Did you see staff there? 12 advised that the fine was shutting down. 13 Yes. 13 A. Yes. 14 Did you see paralegals there/ 14 O. And were you able to print documents? 15 Yes. 15 Well, let me strike that. Were you able to take 16 O. Did you see investigators there? 16 documents relating to matters on which you worked 1? A. 1 Can't necessarily remember whether or not I 17 from the firm? IS saw investor -- investigators there. 16 A. What do you mean by was I able to/ 19 O. And did more then one person speak et the 19 Were you able to access and take with you 20 meeting? 20 documents that related to files on which you were 21 A. I don't remember. 21 working the preceding Friday when you were at RRA? 22 Q. Okay. what else were you advised at the 22 A. I believe so. 23 meeting. If anything? 23 Did you take, did you actually remove Q. 24 It was -- I stayed for very little of that 24 documents, papers that were related to tiles that 25 meeting. I don't know what was advised to others, but 25 you had on which you were working from PRA that day? PROSE COURT REPoitnIC AGOICY. INC. PROSE COURT REPORTING AGENCY. INC. Page 19 Page 20 2 A. I don't believe so. • 1 behalf: that is, who purpOrte to represent 2 O. Okay. Mae anyone preventing you from 2 Mr. Rothstein since you left the firm that day? 3 taking anything? 3 A. No. 4 A. No. 4 O. DO you know Mr. Malt? 0• Okay. Did you print Out any documentation Yes. 6 from your server or from the flrn's server that day 6 O. Do you recog -- are you aware that he to take with you? 7 represents Mr. Rothstein? 0 A. Not that I recall. 0 A. Yea. 9 O. Do you recall taking anything free 9 Okay. have you spoken with him since that 10 RM•offin that day, that day being that same 10 Monday? 11 Monday? 11 Me called me on a morning before a hearing to 12 A. No. 12 ask me where Judge Crow's courtroom was. And I told 13 Q. Obviously Scott Rothstein was not there? 13 him, and that was the extent of that conversation. 14 A. Correct. 24 Otherwise. I have had tero communication with Marc 15 Rave you ever spoken, excuse me, have you 15 Pura. 16 ever seen Mr. Rothstein since that Monday at the 16 With regard to the firm being advised that Q. 1? meeting? 11 the firm was shutting down on that Monday. did you 10 A. What do you mean have I seen him? IS subsequently return to the firm's offices? Let me 19 Seen him in person, I'm sorry. 19 Stalks that. Now long did you stay at the fine that 20 A. No. 20 day? 21 Q. Okay, have you spoken with him at any time 21 A. 1 don't remember. 22 since the Monday meeting at which time you were 22 Did you stay all day? 0. 23 advised that the firm was shutting down? 23 I believe so. 24 24 Were you able to work on your files? 25 0. Have you spoken on any. with anyone on his 25 I don't understand the question. PROSE COAST Unwell.; AGENCY. INC. PROSE Ord REPORTING AGENCY, INC. EFTA01100753  Page 21 Page 22 1 0. Were you able to do legal work on the 1 O. Was there a point in time that you were 2 matters that wherein you represent individuals? 2 prevented from entering your office or the offices 3 Was 1 able to? Yes. I was physically able to 3 of AAA? do that. 4 yea. 5 Did you work on legal matters that day? 5 At what point in time were you prevented 6 A. No. 6 from going into the offices? 7 Did you subsequently. after that date, did 7 A. I don't remember. you return to the PRA offices? B O. Mow many days were you able to access the 9 A. Yes. 9 officer before you were prevented? 10 O. And where are those offices or where were 10 A. I don't remember. 11 those offices located? 11 O. YOu don't know whether it was a day or 12 Las Olas. 12 three days or five days that you were allowed to go 13 Q. The address, please? 13 into the office? 14 A. I don't remember. 14 A. The period of time that I was able to go into 15 O. With regard to the -- 15 the office encompasses all of them things that you just 16 A. 401. 16 did. one day, three days, five days, yes. I can 17 O. Las Oles? 17 definitely say with certainty 1 was able to do that. 10 A. Oneness nods head.1 16 O. During the month Of October were you 19 O. Did you, did you after that Monday did you 19 allowed to go into the office more than ten days? 20 return to the offices at 401 Las Dlas. the RPA 20 A. Yes. 21 offices? 21 O. Did they put -- well, let me strike that. 22 Yes. 22 Did someone put restrictions on what your access was 23 And did you return every day thereafter 23 to the office, the MA office? 24 for a period of time? 24 A. Yes. 25 A. No. 25 0. Okay. Who put the restrictions on the PROSE COURT RESORTING AGENCY, INC. PAOSt COURT REPCeTne AGEACT. INC. Page 23 Page 24 1 entry to the office? 1 Police, U.S. Marshals. 1 don't know. 2 A. From my recollection there were at some point O. Well, who would, who would monitor whether 3 in time, there were people In the office monitoring 4 you came In or couldn't go into the office? 4 activity in the office. 5 I don't know. 5 O. Was that the first week after the Monday? 6 Q. Was there someone there? 6 A. I don't recall. 7 A. Was there someone where? 7 Did you ever, did you receive any O. O. The Ispression I got Is that there was guidelines either at the Monday meeting or 9 some limitation on your ability to access the PM 9 thereafter es to what you could or could not remove 10 offices after the Monday at which time you were 10 from the file, from the, I'm sorry from the Pith 11 advised that the firm was shutting down. Did 1 11 offices? 12 misunderstand you? 12 A. I believe so. 13 No, that's correct. 13 And who put those guidelines out, do you Q. 14 Okay. Wh0 then, if you know, Or whet, if 14 recall? 15 it was an entity, placed any restrictions On your IS A. No. 16 access to AAA offices? 16 O. Were they in a written form? 17 A. I don't know. 1? IS O. When you would go to the office -- well. 16 Okay. Was given in what fora. how did you 19 let as strike that. After how many days -- well. 19 learn what you could and could not take from the 20 let ne strike that. 20 office? 21 The very day, the same day that you 21 A. More rumor than anything else is what I 22 were advised that the office was closing down, were 22 remember. 23 there any individuals that were monitoring whit, if 23 O. Old you discuss that with other 24 anything, was to be removed or not removed from the 24 individuals or other attorneys who were working et 25 office, like a security force. Steward County 25 RIM? PROSE COURT REPORTING Meier. INC. PROSE COM/ REPORTING AGENCY. INC. EFTA01100754  Page 25 Page 26 1 A. Possibly. 1 electronic date at the RR. firm. in addition to, 2 Q. Did you ever attempt to remove something 2 excuse mom. the 6-mall server was and Octet. wee 3 from the office of the /MA offices and someone 3 there anything else from an electronic storage or 4 prevented you? 4 communication means through AM? 5 A. NO. 5 A. Yes. 6 Q. Old you ever -- and when 1 say remove I 6 O. What else was there? 7 mean an the sense of physically remove: that Is. 7 A. That stored electronic materials? I tate Oct boxes or take out files or something of 0. Pint. or that you could communicate with 9 that nature. 9 someone elm either Inside or out of the firm. YOu 10 A. 1 understand the definition of remove. 10 heel the server, e-mail server. You had Qtask. What 11 O. With regard tou there were also, 1 11 else did you have? 12 understand you had an e-mail server at the office? 12 A. To communicate with others, e-mail and Otask. 13 A. Okay. 13 O. And how about within the Confines of the 34 O. Is that correct? 14 firm, was there another electronic mail system Or 16 A. Yes. 15 electronic system either for storage or for 16 0. And I have seen something, there is 16 coamunication? 17 something that's called Otask. Ate you familiar 17 A. To the best of my recollection, none for Is with Qtask? la communicetion. Storage, yes. There were electronic 19 A. Yes. 19 paperless storage case management systems in place. 20 O. And what do you understand Otask or what 20 And with regard to the electronic case 21 did you understand that Otask did: that Is, as an 21 management system, were yOur files, including the 22 electronic service? 22 three cases involving Kr. Epstein, were those cases 23 A web based network to Stott files and other 23 on the electronic case management system? 24 matOOOOOO 24 A. Yes. 25 Q. In terms of electronic storage, or 25 Q. And could you access the electronic case PRIME Cain mmaTING AGENCY. INC. PROSE COURT RETORTING AGENCY. INC. Page 27 Page 28 1 wanegenent system: that is, did you utilize the there a password required to use or access each one? 2 software that was available? 2 A. No. 3 A. yes. 3 Q. Was there a password required to use any 4 O. And had you ever used a system like that 4 of the three? 5 before you came to the PM firm, PM? 5 A. I don't believe so. 6 A. I don't understand. 6 0. As 1 saw in an order that with the Otask 7 O. Okay. Mad you ever used an electronic system that there was some sort of access code that 8 case management software system before you cane to o was required co get into Qtask. 9 PM? 9 A. I saw that too. 10 A. Yes. 10 Q. Did you ever have, did you Over have such 11 O. Was yours the system that you had used 11 a code or a password with regard to Qtask? 12 before was that were you able to integrate that with 12 A. I don't remember. 13 ARA, with the BRA file or system when you got there, 13 O. Was the receiver and/or it's, Ns. Seton or 14 or did your files have to be put on the new AAA 14 hie attorneys asked for you to provide any passwords 15 system? 15 or information to access any of your filet? 16 A. The latter. 16 A. I don't think so. 17 O. In addition, so we had the e-mall server, 17 Q. DO you understand that you have a 18 Otask, and electronic case management system. Was 18 requirement or you're required to give the password 19 there any other type of electronic storage or system 19 If requested by Mr. Secon? 20 that was available for communication or 'torso, at 20 A. I don't know the password to elm to anybody. 21 ARA? 21 I never know there was a password. 22 A. Not that I recall. 22 O. Did you -- 23 O. With regard to the s-mall States. well, 23 A. I don't believe. 24 with regard to the e-mail system, Quist. and 24 O. Did you use Qtask? 25 electronic case management. did you require. was 25 A. I have used otaek. PROSE COURT REPORTING AGENCY, INC. PROSE COURT REPORTING AGENCY, INC. EFTA01100755  Page 29 Page 30 1 Q. With regard to your, the tiles 1 firm but you just didn't sign them up before you 2 specifically, specifically the -- well, let me 2 left? 3 strike that. During she time you were at RRA, of 3 MR. SCAROLA: Objection, calls for 4 the three files. Jane Doe, and C.Y. or in 4 speculation. 5 addition to those throe files, did yOu represent any 5 THE WITNESS: Yes. 6 other individuals who were potential claimants 6 AY MR. CIOTTON: 7 against Mr. Epstein? 7 O. la there a reason that you would not have 0 1 don't believe to. 8 signed them up during the time you were with -- or 9 All right. I received notification from 9