EFTA01126110.pdf

Page 3 IN THE CIRCUIT COURT OF THE INDEX 15TH JUDICIAL CIRCUIT, IN AND WITNESS: Page FOR PALM BEACH COUNTY, FLORIDA BRADLEY EDWARDS CASE NO.: 5021109CA040800XXXXMBAG Direct Examination by MR. HADDAD 4 EXHIBITS JEFFREY EPSTEIN, PLAINTIFFS: Plaintiff, EXHIBITS: Description Page vs. No. l pan of Farmer, Jaffe, Weissing Web site 93 SCOTT ROTHSTEIN, individually, No. 2 from the Web site 93 and BRADLEY J. EDWARDS, No. 3 from the Web site 93 individually, No. 4 from the Web site 93 Defendants. No. 5 from National Trial Lawyers Web site 93 / No. 6 from AVVO, A-V-V-O 93 No. 7 from the Farmer, Jaffe, Weissing Web site 93 No. 8 from lawyers.com 93 VIDEOTAPE DEPOSITION OF BRADLEY EDWARDS No. 9 from for 40 under 40 93 No. 10 & II interrogatories directed to 93 May 15th, 2013 Mr. Edwards and responses 10:00 A.M. - 12:20 P.M. No. 13 transcript of the sentencing proceedings 93 for Alfredo Rodriguez 401 East Las Olas Blvd., Suite 1400 No. 14 plea agreement between the United States 93 Fort Lauderdale, FL and Alfredo Rodriguez. Stenographically Reported By: WENDY ROBERTS, RPR Notary Public, State of Florida Empire Legal Support, Inc. Fort Lauderdale Office Phone: (954)241-1010 Page 2 Page 4 APPEARANCES: 1 Videotape Deposition taken before Wendy Roberts, ATTORNEY(S) FOR MR. EPSTEIN: IONIA HADDAD COLEMAN. ESQUIRE 2 Registered Professional Reporter and Notary Public in Tonja Haddad. PA 3 and for the State of Florida at Large, in the above 315 SE 7th St Ste 301 Fon Laudeidak, Florida 333013158 4 cause. Phonc 5 Fax: E-Mail: 6 THE VIDEOGRAPHER: We are now on the video FRED H 7 Fred Haddad PA record. Today's date is May 15th, 2013. The time I Financial PH Ste 2612 8 is 10:17 M. This is the video deposition of Fon Lauderdale, Florida 333940061 Piton 9 Bradley Edwards taken in the matter of Jeffrey Fax: 10 Epstein v. Scott Rothstein, Case E-Mad: JACK GOLDGERGER, ESQUIRE 11 No. 502009CA040800XXXXMBAG. Atterbury Goldberger Et Al 12 We're located at 401 East Las Olas Boulevard, 250 S Australian Ave Ste 1400 Wear Palm Bead, Acrid, 334015015 13 Fort Lauderdale, Florida. The court reporter is Phone: 14 Wendy Roberts, the videographer is Anthony Estevez, Fax: E-Mail: 15 both with Empire Legal. ATTORNEY FOR BRADLEY EDWARDS: 16 Would counsel please state their appearances WILLIAM KING. ESQUIRE Searcy Denney Scarola Et Al 17 for the record. 2139 Palm Beach Lakes Blvd 18 MR. KING: William King. Searcy Denncy Scarola West Palm Beach. Ronda 334096601 Phone: 19 Bamhan & Shipley for Mr. FAwards. Fax: 20 MR. HADDAD: Fred Haddad on behalf ofleff 21 Epstein. ALSO PRESENT: JEFF EPSTEIN, PLAINTIFF 22 MR. GOLDBERGER: Jack Goldberger, Atterbury, DEBRA FEIN, LAW CLERK 23 Goldberger & Weiss on behalf of Jeffrey Epstein. 24 MS. HADDAD COLEMAN: Tonja Haddad Coleman on 25 behalf ofJeffrey Epstein. 1 (Pages 1 to 4) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96817a7-3aa9-4fcc-b5a9-1e7a13379799 EFTA01126110  Page 5 Page 7 1 THE COURT REPORTER: Would you raise your hand 1 division? 2 to be sworn in, please. Do you solemnly swear the 2 A Not long. I don't remember. 3 testimony you are about to give in this case will 3 Q You left to go with which firm? 4 be the truth, the whole truth and nothing but the 4 A Kubicki Draper. 5 truth, so help you God? 5 Q Where are they located? 6 THE WITNESS: Yes. 6 A Fort Lauderdale. 7 Thereupon: 7 Q What kind of work did you do? 8 BRADLEY EDWARDS 8 A Insurance defense. 9 having been first duly sworn or affirmed, was 9 Q And how long did you stay with them? 10 examined and testified as follows: 10 A A couple years. 11 DIRECT EXAMINATION 11 Q All right. Then you went out on your own? 12 BY MR. FIADDAD: 12 A Correct. 13 Q State your name, please. 13 Q And then you started a plaintiffs' firm, 14 A Brad Edwards. 14 correct? 15 Q All right. And is that your practicing name 15 A Yes. 16 or your legal name? 16 Q And I know the whole story, when you met 17 A My practicing name. 17 Russell Adler, et cetera, at the gym and all of that so 18 Q All right. You're Bradley Edward, what's your 18 we don't need to go through that again, you ended up 19 middle name? 19 with RRA for a period of time, correct? 20 A Bradley James Edwards. 20 A True. 21 Q Okay. You're how old? 21 Q All right. And of course this is old home 22 A M 22 week here in this building. as a matter of fact, I 23 Q Okay. You were admitted to practice when? 23 forgot, correct? 24 A 2002. 24 A The same building. 25 Q All right. So that's 13 years you have been 25 Q Same building. All right. And then one day Page 6 Page 8 1 practicing -- no, II years? 1 in October of -- was it 2009? 2 A Yes. 2 A Yes. 3 Q All right. And my recollection is you gave a 3 Q Halloween weekend, correct? 4 deposition in 2010, correct? 4 A Yes. 5 A Correct. 5 Q All right. You were advised that the firm had 6 Q A couple hundred pages of depositions? 6 no longer the ability to function. 7 A Correct. 7 A Correct. 8 Q All right. And I am not here to reinvent the 8 Q Yourself, I know Gary Farmer was with you at 9 wheel or reinvent the deposition. I know what you said 9 RRA, was Man Weissing there too? 10 then. \Ve've had three years elapse since that time so I 10 A Yes. 11 just want to catch up a little bit to start with. You 11 Q And who else, Scott Lehrman, is that his name? 12 spent some time in the State Attorney's Office, correct? 12 No, not that one. Who else was there with you? Let me 13 A Correct. 13 do it that way, it's easier. 14 Q How many years? 14 A I think there were 60 lawyers there with me. 15 A Roughly three. 15 Q No, no, lam talking about in your unit of 16 Q All right. And when you left the State 16 torts lawyers, that you can recall? 17 Attorney's Office, were you a division prosecutor, 17 A In my unit it was Russ Adler -- 18 special units prosecutor? 18 Q Right 19 A Division prosecutor. 19 A -- myself, Scott Goldstein. 20 Q Which division were you in when you left, if 20 Q That's it. Okay. 21 you recall? 21 A Seth Lehrman, Tami Wolfe. I think there were 22 A Judge Gates. 22 others, I can't really remember. 23 Q Okay. And were you the lead? 23 Q All right. Farmer was not part of the firm at 24 A Yes. 24 the time? 25 Q And how long had you had the lead in that 25 A He was part of the firm but he wasn't a 2 (Pages 5 to 8) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts eilleel7a7-3aa9-4fice-b5a9-leaf3379799 EFTA01126111  Page 9 Page 11 1 personal injury tort lawyer. He did mainly qui tam and 1 A You are asking me a bunch of questions. 2 class action, which was a separate division of RRA. 2 Q Nevermind, let me just -- 3 Q All right. Now, you left that firm obviously 3 A But I think we all know -- 4 for the obvious reason, there was no firm, and you guys 4 Q Yeah, let me just go from there. All right. 5 started your own firm; would that be fair? 5 Let's start — let's go backwards from 20 -- let's start 6 A I started my own firm with some of the other 6 backwards. It's now 2013, correct? 7 people that were previously at RRA, correct. 7 A Yes. 8 Q All right. And my recollection is you arc an 8 Q Do you have any active cases involving Jeffrey 9 association of P.A.s, correct? 9 Epstein? 10 A Yes. 10 A Yes. 11 Q P.A., that's another association of P.A., am I 11 Q How many? 12 correct? 12 A This one that we're here for today. 13 A The current firm that I'm at? 13 Q No, I'm talking -- okay, yes, this one and 14 Q Yeah, yeah. 14 what else? 15 A Yeah. 15 A And another case that I would say involves 16 Q You arc Bradley Edwards, P.A., as part of the 16 him, in that he has intervened in the case and it's a 17 rest of the firm P.A., correct? 17 Federal Court matter relating to some of the victims 18 A You have the right idea. 18 that he molested that is directly against the United 19 Q Huh? 19 States Government. 20 A You have the right idea. 20 Q And that is your victims' rights case? 21 Q Thank you. 21 A That's one way to characterize it for sure. 22 MR. GOLDBERGER: He's an LLC. 22 Q Okay. Well, that's what you -- you filed a 23 MR. HADDAD: Huh? 23 lawsuit, correct, against the United States? 24 MR. GOLDBERGER: He's an LLC, that's what he's 24 A Under the Crime Victims' Right Act, correct. 25 trying to tell you. 25 Q Okay. And that lawsuit is still pending? Page 10 Page 12 1 A Yeah, but you are on the right track, I got 1 A Yes. 2 you, we understand each other. 2 Q Is it being actively litigated? 3 MR. HADDAD: We are the same, Jack. You know, 3 A Yes. 4 us poor sole practitioners don't get along with 4 Q And is there any other co-plaintiffs in that 5 that sort of thing, you know. We are from the old 5 case, if that's the right word, besides yourself? 6 school, we don't need to keep books. 6 A I'm not a plaintiff in the case. 7 BY MR. HADDAD: 7 Q Well, an intervener, are there any other 8 Q So at any rate, you became with that firm, 8 co-interveners or 9 correct? 9 A I'm not an intervener. 10 A Yes. 10 Q What are you? 11 Q All right. Now, you brought with you, and I'm 11 A An attorney representing the plaintiffs. 12 not going through all of this other stuff, the Epstein 12 Q Okay. How many plaintiffs are there? 13 cases, correct? When you went to RRA, that was part of 13 A In that case there are two. 14 the reason Russell was asking you to come in? 14 Q Are there any other cases that you are 15 MR. KING: I'm going to object because this is 15 involved with or sharing information with, without 16 repetitious. 16 getting into what's being shared, and lawsuits pending 17 MR. HADDAD: I understand that. 17 against Jeffrey Epstein at this time? 18 MR. KING: It was all done in his first depo. 18 A Other than what I just described, no. 19 I'm giving you a little leeway here so -- 19 Q Okay. And those suits have been pending for 20 MR. HADDAD: Yeah, I understand. I'm just 20 how long? 21 trying to lead into this. I am not trying to go 21 A This one has been pending since November 2009, 22 into that all over again. 22 I believe. 23 BY MR. HADDAD: 23 Q Okay. 24 Q It's just from more of a pointing chip for the 24 A And that lawsuit has been — the Crime 25 deposition, correct? 25 Victims' Rights Act lawsuit has been pending since the 3 (Pages 9 to 12) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96.17a7-3aa9-4fcc-b5a9.107a13379199 EFTA01126112  Page 13 Page 15 1 summer of 2008. I don't know the exact month. 1 for relief in your complaint, correct? 2 Q All right. And is it near resolution? 2 A Correct. 3 A I don't know. 3 Q What does your prayer for relief seek? 4 Q Is -- can you tell me the style of the case? 4 A Do you have the document to show me, maybe 5 A Yes, it's Jane Doe I and Jane Doe II versus 5 that would refresh my recollection, I mean I think that 6 United States of America. 6 we have filed many pleadings and in one we asked for 25 7 Q All right. And the purpose of that lawsuit is 7 prayers of relief. I can't recite them all for you. 8 to do what? 8 Q I don't ask you to recite them word-for-word. 9 A Hold the United States Attorney's Office and 9 Give me a synopsis. You must have an idea since you are 10 Government responsible for violating the rights of the 10 the plaintiffs' lawyer and have been doing this stuff 11 victims in that particular case. 11 for 10 or I I years, give me some idea of what you are 12 Q By entering into a settlement agreement with 12 seeking. 13 Mr. Epstein? 13 A Yeah, I mean, we want a declaration that the 14 A It has nothing to do with Mr. Epstein. He 14 rights were violated, we want some apology-type 15 voluntarily intervened into the case, had something to 15 information coming from the Government. 16 do with discovery that we were trying to get. 16 Q Right. 17 Q All right. 17 A Ultimately, if we got everything that we 18 A I think Roy Black represents him in that. 18 wanted -- I can tell you what my clients want, they want 19 Q Okay. And that's for the -- okay, I will let 19 the non-prosecution agreement, the immunity agreement -- 20 it go at that for just a minute. 20 Q Umm-hmm. 21 The ultimate result of what you are seeking in 21 A -- overturned and for that to allow for 22 it that suit is what? 22 Mr. Epstein to be prosecuted for the crimes that he 23 A Something that compensates the victims. 23 actually commit -- committed against them and that -- 24 Q Financially or otherwise? 24 for which they cooperated with the Government. 25 A I don't believe the Crime Victims' Rights Act 25 Q Okay. And that's been the goal that you have Page 14 Page 16 1 allows for financial recovery. 1 been pursuing since you filed it, in essence, isn't it? 2 Q What -- what recovery does it allow? 2 A That is their main goal, but then, you know, 3 A Well, that's pan of -- that is what that 3 at this point, there are many other possibilities. 4 lawsuit is about, I mean, I think that we have proven 4 Q Does the -- I'm sony, does the successful 5 that there was a violation, now we're at a stage where 5 prosecution, as it were, by you of that case allow for 6 there is an attempt to uncover what Judge Marra believes 6 attorney's fees? 7 is the appropriate remedy for the violation. 7 A I don't believe so. 8 Q All right. 8 Q All right. So are you being compensated for 9 A And I don't know what his result is going to 9 that at this time? 10 be. 10 A Not at all. 11 Q All right. 11 Q You are doing that completely pro bono? 12 A It's going to be a judge-made decision. 12 A Absolutely. 13 Q I'm sony. That lawsuit has been pending 13 Q All right. How many hours would you say since 14 since 2008, you said, correct? 14 2008 you have donated or devoted to that case? 15 A That was the first of all of the lawsuits that 15 A A lot. 16 was filed. 16 MR. KING: I'm going to object, because now I 17 Q All right. 17 think the question of relevancy and materiality of 18 A Yes. 18 this line of questioning is -- is -- 19 Q And like you said, there is still Jane Doe I 19 MR. HADDAD: He has made a -- he has made a 20 and Jane Doe II are still pending? 20 claim for lost time, inability to work, et cetera, 21 A In that case? 21 et cetera, et cetera and his claims for punitive 22 Q Yeah. 22 damages as well as for claims for damages for 23 A Yes. 23 malicious prosecution and for abuse of process. If 24 Q All right. And what does your -- I guess 24 you read his prayers for relief and his answers to 25 since you represent the plaintiffs, you filed a prayer 25 interrogatories and his ability to not work because 4 (Pages 13 to 16) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96e17a7-3aa9-4fcc-b5a9-1e7af3379799 EFTA01126113  Page 17 Page 19 1 of this lawsuit and because of the suit that was 1 A I haven't kept my hours on that case. 2 filed, I think it's totally relevant. 2 Q All right. You have no independent idea of 3 MR. KING: Well, I -- I -- 3 whether it's one hour, a thousand hours? 4 MR. HADDAD: If you want to instruct him not 4 A It's more than one, less than a thousand. 5 to answer, we can take it up before a judge. S Q Okay. How many hearings would you approximate 6 MR. KING: Right. I disagree. 6 you have attended in front of Judge Marra? 7 MR. HADDAD: It's up to you, Mr. King. 7 A Since 2010, you said? 8 MR. KING: I disagree. 8 Q Yeah, let I'm going to let -- go over 9 MR. HADDAD: That's why we have judges. 9 everything in your prior deposition since 2010. 10 MR. KING: I will allow you some -- some 10 A I believe that the answer to that is one or 11 leeway there, but then I'll evaluate it as you go 11 two. I can't remember for sure, but I believe it's only 12 along. 12 one or two hearings that have taken place since my last 13 MR. HADDAD: Can you give me his answers 13 deposition. 14 per diem? 14 Q And representing the Government is whom? 15 BY MR. HADDAD: 15 A It was Marie Villafana and Dexter Lee. 16 Q So I will ask the question again, how much 16 Q And who's doing it now? 17 time — and see what the leeway is — how much time 17 A I don't know. 18 would you say roughly you devoted -- let's -- okay, 18 Q All right. Could you approximate for me the 19 let's call it since to 2010, since your last deposition 19 last time you had a hearing in this case? 20 'til today, approximately? 20 A I think it was 2011. 21 A I don't know. If you showed me the docket on 21 Q All right. 22 that case or something that would help me, then I could 22 A I'm not sure if there were any in 2012, I 23 approximate a little better, but I really don't know. 23 don't believe so. 24 Q All right. Just for -- in your answers to 24 Q All right. So the cast is just a pending 25 interrogatories, you have been obligated to divert — 25 advisement or ruling by Judge Marra, is it just sifting Page 18 Page 20 1 your response was: "To divert time, effort and attention 1 there, is it what? 2 from the productive practice of his profession to defend 2 A Judge Marra has many motions that have been 3 tortious misconduct of Epstein. Every minute the 3 fully briefed on his -- on the table right now and we're 4 verdict -- verdict from his professional pursuits 4 waiting for rulings. That's—.—.—. 5 impeded his ability to advance the claims and interest 5 Q All right. 6 of existing clients and precluded him from taking other 6 MR. HADDAD: Yes, sir (counsel confer outside 7 and additional responsibilities. Time records made 7 the hearing of the reporter.) 8 available in response to Epstein's response, request to 8 BY MR. HADDAD: 9 produce detail, at a minimum, the extent of the 9 Q In fact, there are motions pending right now, 10 diversion he is suffering." 10 correct, you are saying? 11 So you obviously must have been aware of these 11 A Correct. 12 when you produced these and filed these responses to 12 Q Actively pending. So that would stay the time 13 interrogatories. I'm just asking for an approximation. 13 for dismissal for lack of prosecution? 14 A Of what? 14 A I would think so. 15 Q Time spent. 15 Q Well, I think Federal rule is the same as 16 A I produced the time I spent on this case. 16 Civil and State, isn't it? 17 MR. KING: On this case. 17 A Right. 18 A I produced it. 18 Q You've got a certain amount of time to act 19 BY MR. HADDAD: 19 upon it. It was dismissed previously for lack of 20 Q I un -- on this case, I never -- I'm talking 20 prosecution, correct? 21 about the other case, the -- the -- the Federal case, 21 A I don't remember it being dismissed. I think 22 approximately how much time have you spent? 22 they filed a motion to dismiss. 23 A Show me a docket or something and I will help 23 Q Okay. 24 you out there. I just don't know. 24 A I don't really remember procedurally how that 25 Q No -- no, I'm just -- 25 really worked. 5 (Pages 17 to 20) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96617a7.3849-4fcc-b5a9-197af3379799 EFTA01126114  Page 21 Page 23 1 Q Was that the Government who filed it or was it 1 with you from RRA that were your cases besides the 2 someone intervening who filed it? 2 three, you know, LM and all of that stuff, those three, 3 A It wasn't someone intervening. It was either 3 and stuff that's pending in the case right now, which 4 the Government filing a motion or the Court sua sponte 4 would be five total -- four or five total cases, 5 issuing -- I don't remember it being an order, but I 5 correct? 6 remember seeing some notification that it was going to 6 MR. KING: Objection, relevancy, materiality. 7 be dismissed or something along those lines. 7 MR. HADDAD: I'm tying it up to his damages 8 Q All right. I think since I started with this, 8 claim for loss of reputation, et cetera. 9 with the diversion of time, effort, when you started the 9 MR. KING: Immaterial. 10 law firm in 2000 -- well, 2009 you started the law firm, 10 MR. HADDAD: You can instruct him not to 11 correct, October of 2009, your deposition was in 11 answer. You want -- 12 February of 2010; as I recall, correct? 12 MR. KING: Not yet. Not yet, but um -- 13 A Okay. I'm taking your word for it. 13 MR. HADDAD: Go ahead. 14 Q Well, do you think I would bull — I would 14 MR. KING: -- if you are going to try to get 15 make a misrepresentation to you? 15 into every case with him -- 16 A Not intentionally. 16 MR. HADDAD: Not -- not even remote -- not 17 Q Well, I just did because it was March 23rd. 17 even remotely, Mr. King. 18 A There we go. 18 MR. KING: Okay. 19 Q I apologize so—.—.—. I forgot we have a video 19 MR. HADDAD: I have been doing this a long 20 recording. I almost slipped and thought I was in 20 time too. All right. 21 trial — in criminal court. 21 Go ahead. 22 At any rate, March 23rd, so that would have 22 MR. KING: Go ahead. 23 been five months after you went into practice, correct? 23 A Tell me your question again. 24 A Five months after we started -- 24 BY MR. HADDAD: 25 Q You started the firm? 25 Q Yeah, how many cases did you take with you? Page 22 Page 24 1 A -- our current law firm. 1 A I don't remember. 2 Q All right. Now, when RRA imploded, you 2 Q All right. Would you -- well, let me look 3 started the current firm, were all the named partners in 3 here. One of your claims, I can't remember what I did 4 that firm members of RRA? 4 with them but I read them someplace. Oh, yeah, the 5 A Yes. 5 damage that you suffered is emotional distress, 6 Q Farmer, Jack. Matt Weissing had been over 6 embarrassment, mental anguish, humiliation, loss of 7 there? 7 reputation and standing in the community, loss of value 8 A Yes. 8 of time expended in defense of and responding to the 9 Q All right. And you all regrouped. Where are 9 abuse, correct? That's what you said in your answers to 10 your offices located now? 10 interrogatories; do you want to see them? 11 A Andrews Avenue. 11 A Sure. 12 Q Where? 12 MR. KING: Which number is that? 13 A 425. 13 A Yeah. It's an interrogatory signed May 26, 14 Q Andrews Avenue, north or south? 14 2011, served on me May 16th, 2011. And yes, I believe 15 A Just south of Maguire's, north of Broward. 15 that you read that accurately. 16 Trying to give you landmarks you may know. 16 BY MR. HADDAD: 17 Q No, nothing is better for you guys than that 17 Q Thank you. The nuns will be happy where I 18 law firm, that — I tell you, I used to be right next to 18 went to school. 19 Grady's. It was even better when I did it. All right. 19 Do you still maintain these as your damages 20 At any rate — 20 that you suffered? 21 A I figured you would appreciate the landmark. 21 A For the most part, that's about right. 22 Q Yeah, to say the least. Actually, Boyd's Bait 22 Q All right. What -- what's not right? 23 and Tackle is better. 23 A The diversion of time, clearly I diverted a 24 At any rate, so you started the law firm and 24 lot of time that should not have been diverted to 25 approximately how many cases did you have that you took 25 defending against frivolous ac -- accusations and I 6 (Pages 21 to 24) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Robe Electronically signed by Wendy Robe Electronically signed by Wendy Robe e96e1787-3aa9-4fcc-b5a9-telaf3379799 EFTA01126115  Page 25 Page 27 1 produced this time record. With respect to reputation, 1 you -- joined you as party or a -- 2 1 believe that over the course of the last three years I 2 A It didn't happen. 3 have done a pretty darn good job resurrecting any damage 3 Q -- defendant or anything? 4 that was done to my reputation in this community. 4 A That did not happen. 5 Q Well, let's -- lees start with that. You 5 Q Name one person, other than this lawsuit, 6 don't — you never had a reputation damage, did you? 6 which we'll get into later, other than this lawsuit. 7 MR. KING: Objection, form. 7 what newspaper article, what Daily Review article, what 8 BY MR. HADDAD: 8 any article accused you of being involved in the Scott 9 Q Okay. What damage, if any, did you initially 9 Rothstein debacle? 10 have done to your reputation by the filing of a lawsuit 10 A I can't recite them off of my head. 11 against you that suggested that you were so aggressive 11 Q Is there any? 12 as a lawyer someone was going to sue you? 12 A I believe that newspaper articles were written 13 A No, the lawsuit that was filed against me — 13 when the lawsuit was filed about me and Scott being 14 MR. KING: Object to form, argumentative. 14 accused of being some co-conspirator in a Ponzi scheme, 15 A The lawsuit that was filed -- 15 yes. 16 MR. HADDAD: I was paying a compliment. 16 Q All right. There were newspaper articles 17 MR. KING: Yes. 17 written quoting a pleading as opposed to someone 18 Go ahead. 18 suggesting you committed a criminal act; is that 19 A The lawsuit that was filed against me said 19 correct? 20 that I was part of some racketeering scheme, said that I 20 A I don't know the distinction that you are 21 was involved in a Ponzi scheme, that I was 21 trying to make. 22 co-conspirator of Scott Rothstein's and that I was 22 Q We'll worry about that later, I'm just asking 23 committing fraud and conspiracy to commit fraud. A 23 you, do you know whether or not it was someone quoting a 24 bunch of criminal actions were alleged against me. In 24 newspaper -- a -- a -- a legal pleading, or was it a 25 fact, I think the complaint was entirely crimes that I 25 individual making an accusation that you were a Page 26 Page 28 1 had committed as a lawyer, which is the exact opposite 1 criminal? 2 of the type of reputation that you want as a lawyer. 2 A The legal pleading made an accusation that I 3 With that being said, that complaint, the 3 was a criminal and that was reported on. 4 various motions making those allegations about me being 4 Q I'm asking you, was there anything other -- 5 some form of co-conspirator in a Ponzi scheme was 5 was there any person, reporter, anyone, any of the 6 repeatedly filed and stated on the record and in 6 people you had all of these thousands of e-mails with, 7 hallways over at the bankruptcy court, because every 7 anyone who suggested that you were a criminal, other 8 lawyer who was anybody in South Florida had something to 8 than the pleading filed that suggested because of 9 do with the bankruptcy proceedings over at the 9 Rothstein's inclusion of your cases as part of the basis 10 bankruptcy court. So I had to go over there 10 for his Ponzi scheme that you were involved, other than 11 continuously and fend off these lawyers who believed 11 that lawsuit? 12 that there must be some merit to it, because somebody 12 A People believed that I was involved. 13 who has a lot of money is hiring lawyers who have a 13 Q Who expressed that to you? You're a young 14 pretty good reputation to say these things, there's got 14 lawyer, you're in the courthouse every day or almost 15 to be something to it. 15 every day, you're around town, correct? 16 BY MR. HADDAD: 16 A Yes. 17 Q Name one case in which you were impleaded 17 Q You go to different restaurants. Name one 18 because of your alleged involvement with Scott 18 person that came up to you and said, I can't believe you 19 Rothstein? 19 are not in jail, you area Ponzi scheme or you are 20 A I did not lose a single client. 20 anything, name one person -- 21 Q Name one -- no, name one person who impleaded 21 A There were lawyers over at the bankruptcy 22 you, one other person in bankruptcy court, whether it be 22 court, when I had to sit there listening to the things 23 the clawback scheme, whether it be Shears, whatever the 23 that were being said, that told me, you are going to be 24 hell he calls what he did, whatever you call any of that 24 a target of mine given this information that we -- 25 stuff, name one person that impleaded you or asked 25 that -- that is being told to us by Jeffrey Epstein and 7 (Pages 25 to 28) EMPIRE LEGAL SUPPORT, INC. (954) 241-1010 Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts Electronically signed by Wendy Roberts e96.1787-3aa9-41cc-bSa9-1e7af3379799 EFTA01126116  Page 29 Page 31 1 his lawyers. 1 obviously, that Scott preyed upon you, as it were. You 2 Q Let me ask you this as a lawyer. Let me ask 2 were one of Scott's victims. No -- no -- incredibly -- 3 you this as a lawyer. You are a prosecutor, correct? 3 not -- not incredibly because Scott would do that to 4 A Yes. 4 anybody, you were one of Scott's victims. He didn't 5 Q And I read in your deposition you didn't do 5 care two cents about using you; would you agree? 6 RICO cases and you didn't really do economic crimes, 6 A Clearly. 7 correct? 7 Q Obviously, he put you in that position, 8 A Right. 8 correct? 9 Q All right. Did you investigate cases? 9 A Clearly. 10 A Yes. 10 Q He brought you in and every single investor, 11 Q Okay. And you're aware that in the instance 11 whether they were criminal investors or not criminal 12 of this case that Mr. Rothstein used, and I mean it's 12 investors, were led to believe that Bradley Edwards was 13 hundreds of pages to your depo that I'm not going to 13 assisting him and using his cases to promulgate these 14 reinvent the wheel on or 10's of 20 pages that 14 settlements, correct? 15 Mr. Rothstein had your boxes and your cases included in 15 A I don't know that at all -- 16 a room right upstairs here where he brought in 16 Q All right. Well, you've heard that from 17 investors, correct? 17 Sheer-- 18 A I am aware of that. 18 A -- to be true. 19 Q And he used your cases, Bradley Edwards' cases 19 Q -- when he won his verdicts and his lawsuits, 20 to lure investors into his fraudulent schemes, you've 20 didn't you? I am just asking -- 21 testified to that in bankruptcy court and other courts, 21 A No. 22 haven't you? 22 Q -- if you familiarized yourself with -- 23 MR. KING: Objection, form. 23 A No. 24 MR. HADDAD: Oh, excuse me, you are right 24 Q — that tome that he filed that he called a 25 counsel, I'll try. 25 complaint? Page 30 Page 32 1 BY MR. HADDAD: 1 A Because of how long it was, I may have read 2 Q You are aware of that, correct? 2 10 pages of it. But it was 2,000 or 3,000 pages — 3 MR. KING: The same objection. 3 Q Did you find it t