EFTA00800508

221 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
to restrain fraudulent transfer of assets. You see 
that? 
A 
Yes. 
Q 
First, let's take a look at the last page. 
A 
Of this exhibit or of the motion? 
Q 
Of the motion. 
A 
Which is page 21 of the exhibit. 
Q 
I think it's page 19 of 41 at the top, 
right? 
A 
Okay. 
Q 
You see that's an electronic signature, 
right? 
A 
Yes. This is what typically was on -- the 
electronic signature that we would use when I would 
authorize filings. That's what I was talking about 
earlier. 
Q 
And you see this one includes Paul Cassell, 
right? 
A 
Yeah, I do. 
Q 
Now, let's go back to page four of 41. 
A 
He drafted this motion, so I know 
Q 
He drafted it? 
A 
Yeah. 
Q 
But you put your name on it and filed this, 
right? 
Palm Beach Reporting Service, Inc. 
EFTA00800728

222 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
A 
Of course. And I agreed with it. 
Q 
So let's take a look. This motion was on 
behalf of plaintiff Jane Doe? 
A 
Right. 
Q 
And you represented Jane Doe 
A 
Yes. 
Q 
-- while you were at Mr. Rothstein's firm. 
And this was filed while you were at Mr. Rothstein's 
firm, right? 
A 
It was. 
Q 
Look at the first paragraph on page five. 
It says, "Epstein is a billionaire, who recently has 
been fraudulently transferring his assets overseas." 
Do you see that? 
A 
Yes. 
Q 
What evidence -- admissible evidence -- did 
you have of that statement before you made it in this 
pleading? 
A 
I had information that he was doing this from 
sources, including sources close to him. I had 
evidence that he had placed significant assets into at 
least one other person's name, as well as properties 
that were placed in the names of corporations or other 
companies, as I remember, that was already going to 
make it difficult on the collection end. 
Palm Beach Reporting Service, Inc. 
EFTA00800729

223 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Q 
So what I'm asking is about your statement 
here, sir, which is, that I would like to know the 
evidence that you had that he was fraudulently 
transferring his assets overseas. What evidence do 
you have -- or did you have at the time? 
MR. SCAROLA: That's the question that 
was just asked and just answered. 
MR. LINK: He didn't answer it. 
MR. SCAROLA: I disagree with you. 
MR. LINK: Okay. 
BY MR. LINK: 
Q 
Will you answer the question for me 
specifically on transferring his assets overseas? 
You told me about titling them, you told me about 
things, but you didn't tell me about the evidence for 
transferring his assets overseas. 
A 
I told you that we had a very good source of 
information that had given us this information that was 
a longtime associate of Mr. Epstein's. 
MR. SCAROLA: Are you disregarding the 
affidavit attached to the motion? Are you 
asking for information apart from the 
affidavit attached to the motion? 
MR. LINK: I'm asking what evidence he 
had of this happening. 
Palm Beach Reporting Service, Inc. 
EFTA00800730

224 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
MR. SCAROLA: But there's an affidavit 
attached to the motion. 
MR. LINK: I know there is, and it 
doesn't answer this question. 
MR. SCAROLA: Well, respectfully, I 
disagree. 
MR. LINK: Okay. We disagree a lot 
today. It's okay. 
BY MR. LINK: 
Q 
Mr. Scarola wants you to look at the 
affidavit. Who signed the affidavit? 
MR. SCAROLA: Mr. Scarola wants to know 
whether your question is excluding the 
affidavit. 
BY MR. LINK: 
Q 
Take a look at the affidavit and tell me 
who signed it. 
A 
Paul Cassell. 
Q 
And he's a lawyer, right? 
A 
Yes, he's a lawyer. 
Q 
And he's a lawyer involved in this case, 
right? 
A 
He was a lawyer --
Q 
Was he going to get on the stand as the 
lawyer involved in this case and testify about 
Palm Beach Reporting Service, Inc. 
EFTA00800731

225 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
personal knowledge that Mr. Epstein transferred 
assets overseas? Was he going to do that? 
MR. SCAROLA: Was he going to do that 
in this case? 
BY MR. LINK: 
Q 
Was he going to do it then? 
A 
You will have to take Mr. Cassell's 
deposition and ask him that question. 
Q 
So did you have -- did you and Mr. Cassell, 
when you filed this injunction paper in federal 
court, have evidence -- not sources -- I mean you 
were a prosecutor. You know the difference between 
sources and evidence, right? 
There's lots of information out there. 
Doesn't mean we get it in evidence, right? You know 
that, as a trial lawyer. 
A 
Okay. 
Q 
You agree with me? 
A 
I agree with you. 
Q 
What evidence did you have? 
MR. SCAROLA: Excuse me. May he finish 
the answer to the question that you asked 
before you ask the next question? 
THE WITNESS: This case was a little 
different than most in this sense. If I get 
Palm Beach Reporting Service, Inc. 
EFTA00800732

226 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
information in a case, such as this, I can 
then take Mr. Epstein's deposition and say, 
Is it true that you are transferring assets 
here, there and everywhere? And if he tells 
me the truth, he's going to tell me, Yes, 
and then I will have that evidence. 
He restricted our ability to gain 
evidence on many subjects, not only by 
claiming the Fifth himself, but having his 
co-conspirators claim the Fifth, and then 
having the next tier of associates show up 
with lawyers who were paid by him, which 
restricted our ability to gain the 
testimonial evidence that we would need to 
support many of our -- many of the things 
that we knew about the case. 
In this case, on this particular 
subject, we had good sources, reliable 
sources. And as this affidavit indicates, 
other plaintiff lawyers and I -- speaking on 
behalf of Paul Cassell -- have been greatly 
concerned that Epstein might attempt to 
transfer many of these assets overseas with 
the intent to defeat any judgment. 
This was one of the topics -- one of 
Palm Beach Reporting Service, Inc. 
EFTA00800733

227 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
the many topics that, amongst plaintiffs' 
counsel, we discussed as the way in which 
Epstein intended to ultimately defeat these 
cases, which would ultimately prove his 
serial sexual molestation of minors. 
BY MR. LINK: 
Q 
So is your concern something that's 
evidence? 
A 
And we had a source telling us our concern 
was true. 
Q 
I understand. 
A 
Okay, so --
Q 
I have heard about the source. I am asking 
you about evidence. You told me you had concerns. 
Okay, I don't know that a federal judge cares about 
your personal concerns. I doubt that a federal judge 
cares that you have a source who won't get on the 
stand. 
So whenever I have filed a motion for 
injunction, I intend to put evidence on in front of 
the court. And I'm asking you, sir, what evidence 
did you have in this federal proceeding to prove 
your statement that Mr. Epstein was fraudulently 
transferring his assets overseas? 
MR. SCAROLA: Excuse me. I'm going to 
Palm Beach Reporting Service, Inc. 
EFTA00800734

228 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
object to Counsel's speech about Counsel's 
experience. Move that it be stricken. 
And the question as to what evidence 
did Mr. Edwards have 
MR. LINK: Yes. 
MR. SCAROLA: -- is a question that has 
been asked and answered repeatedly. 
BY MR. LINK: 
Q 
So would you agree you had no admissible 
evidence at the time that you filed this pleading? 
A 
Hold on one second. So --
Q 
Yes, sir. 
A 
-- this is evidence. 
Q 
What is it? 
A 
In request for admission I asked 
Mr. Epstein 
Q 
Yes. 
A 
-- admit you are moving financial assets 
overseas outside of the direct territorial reach of the 
US and Florida courts. 
Question 22, you were making asset 
transfers with the intent to defeat any judgment 
that might be entered against you in this case or 
similar cases. 
Twenty-three, do you currently have the 
Palm Beach Reporting Service, Inc. 
EFTA00800735

229 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
ability to post a $15 million bond to satisfy a 
judgment in this case without financial or other 
difficulty? 
Q 
Uh-huh. 
A 
If he told the truth, he would have said yes. 
And that is what the adverse inference requirement 
allows for us to draw when he says in response to those 
direct requests for admissions that he's invoking his 
Fifth Amendment right against self-incrimination, which 
is tantamount to an admission. So that is evidence. 
Q 
Okay. So you think that the adverse 
inference 
A 
That's going to happen in this case, too. 
Q 
Hang on. Let me just make sure I 
understand. 
You thought when you filed this that 
having an adverse inference to a question --
whatever question you asked -- because he raised the 
Fifth, makes it an admission? That's your 
understanding of an adverse inference in federal 
court? 
A 
I had an admission by Mr. Epstein in response 
to his question. 
Q 
That was it? You told me he pled the Fifth 
and didn't answer. All I'm asking is, was it your 
Palm Beach Reporting Service, Inc. 
EFTA00800736

230 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
belief that at the time in federal court that an 
adverse inference based on raising a Fifth Amendment 
privilege is an admission of your question? 
A 
If his answer to that --
MR. SCAROLA: I'm sorry. The question 
about what Mr. Edwards' belief was is 
clearly a question that invades the 
work-product privilege. 
MR. LINK: Okay. Fair enough. 
BY MR. LINK: 
Q 
But the only evidence you had that you can 
point to was your asking Mr. Epstein a question that 
he raised his constitutional privilege to and that 
you considered that an admission for purposes of 
federal court? 
MR. SCAROLA: Pardon me. That's 
compound. You can ask him what the evidence 
was. You cannot ask him what he considered. 
What he considered is an operation of his 
mind, and that is protected work product. 
BY MR. LINK: 
Q 
Do you remember on September 29, 2009, 
writing a memo saying it would be really nice if we 
can find evidence of a transfer? 
A 
Show it to me. I will see it. 
Palm Beach Reporting Service, Inc. 
EFTA00800737

231 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
(Plaintiff's Exhibit Number 15 was marked 
for identification.) 
BY MR. LINK: 
Q 
Take a look at Exhibit 15. This is an 
email from Mr. Edwards to Ken Jenne. You remember 
you told me earlier you weren't sure if Ken Jenne, 
who was the sheriff that had criminal issues, worked 
on the Epstein matter. You see his name there? 
A 
Yes. 
Q 
Who is Elizabeth Villar? 
A 
I don't remember her. 
Q 
Was she an investigator? 
A 
No. I don't think that there 
investigators that I remember. 
So this is on the subject of forensics. 
Q 
Yep. Do you see the sentence that says, 
"We need to be able to file a supplement to his 
were any female 
response, and it will be great to put in evidence of 
a transfer." 
So that you wanted to get a forensic 
report done at that time and were having trouble 
do you remember this -- you were having trouble 
getting the funding necessary to pay the forensic 
person to determine if there had been any transfers 
of assets? 
Palm Beach Reporting Service, Inc. 
EFTA00800738

232 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
A 
That's not true, the statement that you just 
made, having trouble getting the --
Q 
Okay. That statement that I just made is 
untrue and not supported by the files that have been 
produced in this case? Is that your testimony? 
A 
Right. You are basically implying that the 
Josefsberg firm and the Searcy firm -- and nobody could 
come up with money to do this. 
This is clearly talking about the checks 
that were coming from the other plaintiff's lawyers 
for the purposes of hiring the forensic accountant. 
Q 
Did Mr. Searcy -- did Mr. Scarola sign this 
injunction paper? 
A 
No. But now you're talking about two 
different things. 
Q 
Did Mr. Josefsberg sign this paper? 
A 
You are talking about different things. 
Q 
I'm asking you did they sign it. 
A 
You tell me. Did they sign it? 
Q 
I don't see it. 
A 
Okay, then they didn't. 
Q 
Did Mr. Scarola in his case file a federal 
injunction seeking a bond? 
A 
No. I did the work. 
Q 
Did Mr. Josefsberg? 
Palm Beach Reporting Service, Inc. 
EFTA00800739

233 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
You did the work -- this is for 
Mr. Scarola's case? 
A 
No, but -- yes, the cases --
Q 
This is one of Mr. Scarola's cases? 
A 
The cases were combined. 
Q 
Let's look at the style. I just want to 
make sure I understand this. 
This motion you filed was to benefit 
Mr. Scarola's client; is that right? 
A 
No. What I'm saying is it was filed in Jane 
Doe No. 2, Jane Doe No. 3, Jane Doe No. 4, Jane Doe No. 
5, Jane Doe No. 6, Jane Doe No. 7, C.M.A., Jane Doe, 
Doe No. 2, Doe No. 101, Doe No. 102. 
So there was a motion filed in that case, 
filed by me. This was work that was done by me to 
freeze Mr. Epstein's money so that he could not move 
assets out of the country and defeat any judgment 
that I was to obtain. 
Q 
For your client, right? 
A 
Right. 
Q 
Mr. Scarola even filed a federal court 
action on behalf of his client? 
A 
No. You're showing me this email that's 
talking about -- an email that I sent about other 
firms' checks that relate to the forensic accountant. 
Palm Beach Reporting Service, Inc. 
EFTA00800740

234 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
That's why I'm telling you, you're talking about 
different things here. 
Q 
This says right here, right, "Epstein has 
to respond to the Judge as to why he's taking the 
Fifth on all asset transfer questions." 
You just read me asset transfer questions, 
true? 
A 
And if -- and if his answer to those 
questions was no, that obviously wouldn't incriminate 
him. He's not moving money overseas, okay, it doesn't 
incriminate him. So clearly the answer was going to 
incriminate him. 
Now it looks like -- I'm saying -- the 
Judge is going to make him respond as to why. 
What we need is to file a supplement. It 
would be great to have evidence of the transfer --
Q 
I agree --
A 
-- to file with our supplement. 
Q 
-- it would have been great. 
Did you have any evidence of the transfer? 
It's what I've been asking for. 
A 
We didn't have evidence that we could use at 
that time to support the transfer. What we had was a 
really good source, and we had evidence that Epstein's 
invocation of the Fifth was evidence that he had indeed 
Palm Beach Reporting Service, Inc. 
EFTA00800741

235 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
done those things. 
Q 
Is there any part of Rule 11 that says that 
you do not have to have an evidentiary support for 
your filings because a witness takes the Fifth 
Amendment? 
MR. SCAROLA: You know -- you know that 
Rule 11 requires a good faith basis. 
MR. LINK: I do. 
MR. SCAROLA: It does not require that 
you have evidence in your possession at the 
time of the filing. 
Complaints are filed on the basis of 
good faith with a view towards obtaining 
evidence all the time. 
MR. LINK: And that's okay. 
MR. SCAROLA: That's okay, as long as 
there's a good faith basis. 
MR. LINK: I agree with that. 
MR. SCAROLA: So you are talking about 
apples and oranges. You don't have to have 
evidence for filing. 
MR. LINK: This isn't a complaint. 
This is a motion for injunction, which is 
not --
MR. SCAROLA: You do not have to have 
Palm Beach Reporting Service, Inc. 
EFTA00800742

236 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
evidence at the time of the filing of the 
motion. You have to have a good faith 
belief that it's well-founded. 
MR. LINK: Okay. 
MR. SCAROLA: But you're arguing and my 
arguing about what about Rule 11 has to do 
with these pleadings has nothing to do with 
any of these issues in this lawsuit. But it 
has a lot to do with wasting time in this 
fourth section of Mr. Edward's deposition 
the fourth and last session of Mr. Edward's 
deposition. 
MR. LINK: I think it's really most of 
the first session, but that's okay. I 
understand your position. 
BY MR. LINK: 
Q 
All right, so let me just wrap this up real 
quick. All these Jane Does on here that you 
mentioned, Mr. Scarola, did he have any clients in 
this federal case that you are aware of? 
A 
I think he represented C.M.A. Although, you 
shake your head no, so maybe you know information that 
I don't. If you are telling me the truth, I will 
believe you. 
Q 
I'm not telling you anything, sir. 
Palm Beach Reporting Service, Inc. 
EFTA00800743

237 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
A 
You are shaking your head. 
Q 
Did Mr. Scarola have one of these Jane Doe 
clients? 
A 
You can't ask the question, then shake your 
head, which indicates an answer no, and then ask me to 
answer the question. 
If you're telling me the answer is no, I 
will agree with you. I assume you're telling me the 
truth. 
Q 
I'm not telling you any answer, sir. 
That's your job. 
A 
Why are you still shaking your head? Still. 
Right now you are still shaking your head. 
Q 
Maybe I have some kind of a twitch in my 
neck. I don't know. 
A 
So do know the answer to the question? 
Q 
I'm not here to answer the question, sir. 
A 
I don't know. 
Q 
Did Mr. Josefsberg have any plaintiffs in 
this federal action? 
A 
I believe so. 
Q 
Did Mr. Josefsberg authorize you to file 
the motion for injunction on his behalf -- of his 
clients? 
A 
He knew that it was being filed. 
Palm Beach Reporting Service, Inc. 
EFTA00800744

238 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Q 
You can file whatever you want for your 
clients. I get that. 
Did Mr. Josefsberg authorize you to file 
this motion on behalf of his clients? 
A 
No. That's not how we worked. 
Q 
All right. Take a look, if you would, 
please, at Exhibit Number 16. 
(Plaintiff's Exhibit Number 16 was marked 
for identification.) 
BY MR. LINK: 
Q 
Is my head still shaking no or --
A 
No, it's not. It's still now. 
Q 
Okay. Good. 
This is the order that the court entered 
on the motion for injunction, true -- see Judge 
Marra -- November 5th, 2009? 
A 
Yeah. 
Q 
And I want you look on page three. Do you 
see where it says, "Plaintiff's motion" 
A 
I'm going to read it. I will get there. 
Q 
Okay. 
A 
Yeah. 
Q 
Do you see where the federal district court 
judge says, "Plaintiff's motion is entirely devoid of 
evidence of defendants alleged fraudulent transfers"? 
Palm Beach Reporting Service, Inc. 
EFTA00800745

239 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
You see the court's statement? 
A 
Yes. I'm just reading it in the context of 
the rest of the order. 
Q 
Is there something in the context of the 
order that changes the court's words that the motion 
that you and Mr. Cassell filed was entirely devoid of 
evidence of Mr. Epstein's alleged fraudulent 
transfers? 
A 
No. I see that that is what the court says. 
And also in light of the defendant being a billionaire, 
the various retitling of vehicles in the view of the 
court was de minimis in relativity. 
So, yeah -- and there's a long string --
cite of cases indicating that prejudgment relief of 
this type is not easy to obtain. 
Q 
Mr. Edwards, I'm handing you what we just 
marked as Exhibit 17, which is the Fourth Amended 
Counterclaim that you filed against Mr. Epstein, 
correct? 
(Plaintiff's Exhibit Number 17 was marked 
for identification.) 
THE WITNESS: It appears like that's 
what this is. 
BY MR. LINK: 
Q 
Would you take a look, please -- and this 
Palm Beach Reporting Service, Inc. 
EFTA00800746

240 
1 
2 
3 
4 
5 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
is the operative pleading? Do you know? 
A 
Are we on the fourth amended -- I don't know. 
Are we on the fourth amended counterclaim? Not sure. 
Q 
Not sure. Okay. 
A 
I don't think so. Well, I only say that 
because count one is abuse of process. I don't know 
that we have an abuse of process in this case still 
left. I thought it was only malicious prosecution. I 
could be wrong. 
Q 
Let's take a look at paragraph five. This 
was filed on January 9th, 2013. Do you see that, the 
Fourth Amended Counterclaim? 
A 
Paragraph five? 
Q 
No, the entire counterclaim. Look at the 
first page of it. See the file stamp? 
A 
January 9, 2013. 
Q 
So as of January 13, 2000 -- January 9th, 
2013 -- look at the last sentence of paragraph five. 
Can you tell me on that day who are the victims 
seeking compensatory and punitive damages against 
Mr. Epstein that you represented? 
A 
Okay. 
MR. SCAROLA: If that information has 
not been publicly disclosed, then I instruct 
you that it is attorney-client privilege and 
Palm Beach Reporting Service, Inc. 
EFTA00800747