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I don't think he was there when I first got there, 
but I could be wrong about that. 
Actively involved in any of the -- Paul 
Cassell, who was not even at that firm, was the 
other person that I communicated with the most on 
those cases about what was actually going on and 
strategy and things like that. 
Q 
I want to focus on for the six months you 
were at Rothstein, okay. That's what I'm focused on. 
For the three clients that had lawsuits pending 
against Mr. Epstein, I'm just trying to have you tell 
me which lawyers -- we are focused on lawyers for the 
moment -- we've already covered investigators --
which lawyers worked with you, were part of your 
team. You said Bill Berger. 
A 
It's the work with you. Bill Berger did 
things. He went to hearings and things like that. 
Q 
Did you not consider that him working with 
you? 
A 
I did. He's in that category. 
Q 
Who else? 
A 
There were other people, like -- there was a 
former FBI agent. I don't remember her last name, but 
I think her name is Cara. She was a lawyer. And I 
would communicate with her about different aspects of 
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the investigation. Did she work with me? I don't 
think that she did anything. She could have attended a 
deposition. If she did, I don't necessarily remember. 
Q 
Let me pause for one second. Was she 
working as an investigator or as a lawyer when you 
would communicate with her? 
A 
A lawyer. 
Q 
Do you remember her last name? 
A 
No. 
Q 
Was it Holmes? 
A 
Than doesn't help to jog my memory. Sorry. 
Q 
Did she communicate with you about the 
claims against Mr. Epstein? 
A 
At times I believe she did. 
Q 
Did you discuss with her how to maximize 
the recovery against Mr. Epstein? 
A 
That's not something I would communicate to 
her. That could be something she might communicate to 
me. But I don't know about that. 
Q 
Tell me why she would do that. Why would 
she communicate to you as the lead lawyer for these 
A 
She may not. I mean, I'm just saying. I 
don't do that, hey, talk to somebody who doesn't -- who 
doesn't know as much as me about the case and say, How 
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do we maximize recovery. I would know that. That's 
what my job was. 
Q 
So you wouldn't need Cara to tell you how 
you should or how you could maximize recovery against 
Mr. Epstein? 
A 
I didn't need anybody to tell me how to do 
anything. But at that firm, there were a lot of 
lawyers with a lot of experience, and taking 
information from them that's helpful on any case -- as 
it still is today how I practice how you probably 
practice -- it's no different. 
Q 
So other than Mr. Berger and Cara --
somebody with a last name 
was there anyone else 
that was part of the team? 
MR. SCAROLA: At RRA or working 
together with --
MR. LINK: Yes. 
MR. SCAROLA: Just at RRA? 
MR. LINK: Just at RRA. Same topic we 
have been on. 
THE WITNESS: The team is me and any 
lawyer who wants -- any lawyer there who 
knows about the case who wants to tell me 
anything about their own opinions about the 
case. 
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BY MR. LINK: 
Q 
I guess let's try it a different way. Who 
drafted the papers that would get filed on behalf of 
the three clients while you were at RRA? 
A 
Ninety-eight percent of them would be me or 
Paul Cassell, if not 100 percent. I can't remember 
anybody else drafting anything, but I could be wrong. 
Q 
So if I look at papers that were filed 
during the period of time that you were with RRA in 
the three lawsuits against Mr. Epstein, 98 percent of 
those documents were probably drafted by you and/or 
Mr. Cassell, or the two of you together? 
A 
Yes. And probably more by Mr. Cassell doing 
the drafting than me. But yes. I mean, that's --
Q 
So if you wanted to hire a -- let me try 
that again. 
If you wanted to assign an investigator at 
RRA work to do on the Epstein matter, how would you 
do that? Who would you talk to? Was there a 
process involved? 
A 
I don't know what the initial process was. I 
don't remember that. But once I was introduced to Mike 
Fisten, I would just talk to Mike. I mean, that's who 
I talked to. Mike, this is what I think that we need 
to do next. Mike would say, Okay, let's get it done, 
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or think about this. 
Q 
So any of the decisions that were made 
during the six months that you were at Rothstein were 
made, from a strategic standpoint, by you as the lead 
lawyer? 
A 
Yes. By me or by Paul Cassell. I mean, I 
think there was a time where we had pretty equal say in 
what we were doing next. 
Q 
Mr. Cassell was not an employee of 
Rothstein? 
A 
Right. 
Q 
You were the sole employee of Rothstein's 
firm that made decisions -- strategic decisions for 
the three clients? 
A 
Yes. 
Q 
Did you make the strategic decision to file 
the fourth lawsuit in federal court? 
A 
It wasn't my idea initially, but I quickly 
agreed with the idea. That was Paul's idea, and he was 
right on it, so I didn't -- I didn't come up with the 
idea, but I should have. 
Q 
It was Mr. Cassell's idea to file the 
federal court complaint for Plaintiffillill? 
A 
Right. 
Q 
Were there -- did you consider filing 
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federal court complaints for the other two plaintiffs 
that you represented? 
A 
Well --
MR. SCAROLA: Excuse me. Let me 
interrupt here for just a moment. 
Obviously, what Mr. Edwards considered, 
his mental processes, are clearly attorney 
work product. I am more than happy to have 
him answer that question, but I don't want 
him to answer that question if the argument 
is going to be made that, by responding to 
this particular question, he has broadly 
waived work-product privilege. 
If we can agree that the answer to this 
question will not constitute a waiver of 
attorney work-product privilege, generally I 
don't have a problem with his responding to 
it. 
MR. LINK: I will agree with that. 
MR. SCAROLA: And for shorthand 
purposes, there may be other questions that 
fall into the same category, and I will just 
say, can we have the same agreement as to no 
waiver, and you will know what I'm talking 
about, okay? 
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MR. LINK: You're giving me more credit 
than I'm due, but I think I will figure it 
out. 
THE WITNESS: So, I believe your 
question was did we consider filing federal 
lawsuits for the other clients, that 
being -- other than 
BY MR. LINK: 
Q 
Yeah. While you were employed at RRA. 
A 
Got it. 
So Jane Doe, we filed in federal court 
already. So her case was already in federal court. 
However, there was a time, during this 
same time, that we weren't -- we weren't completely 
satisfied with the way we had pled it, so -- and for 
the same reason that I'm going to tell you as to why 
we filedilill But there wasn't the need to file on 
the other cases that we saw coming up 
case. 
I'm trying to figure out the best way to 
say this without invading the attorney-client 
privilege. Let's -- let me back up and explain it 
this way. 
The non-prosecution agreement 
Q 
Let me just stop you, because I think I 
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asked you a really simple question. I thought my 
simple question was did you consider doing it? And 
you haven't told me yes you did or no you haven't. 
And Mr. Scarola made an objection. I don't want you 
to just give a speech, and I don't think Mr. Scarola 
does. 
A 
In general terms, we thought about it being 
the best idea in general. 
Q 
Did you draft, in fact, while you were at 
Mr. Rothstein's firm, a federal complaint for the 
other state court plaintiffs? 
A 
We either did or we conceptually agreed that 
we were going to. We agreed that we should. 
Q 
Okay. While you were at Mr. Rothstein's 
firm, you and Mr. Cassell agreed that you would file 
a second complaint on behalf of one of your clients 
that was in state court, and that complaint would be 
filed in federal court, just like the 
complaint 
was? 
MR. SCAROLA: Same agreement. 
MR. LINK: Same agreement. 
THE WITNESS: I believe so. We may 
have actually drafted it. 
BY MR. LINK: 
Q 
And that complaint was not filed, true? 
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A 
Which complaint? 
Q 
The one that we just talked about. 
A 
Q 
Yes. So the 
complaint was drafted 
A 
We didn't file a separate 
Q 
So what you and Mr. Cassell decided 
while you were at Rothstein you would do 
was never 
filed, right? 
A 
We never filed a separate complaint for 
in federal court. 
Q 
And once you left Mr. Rothstein's firm, you 
didn't file a federal case on behalf of 
, right? 
A 
I did not. 
Q 
And you did not serve Mr. Epstein after you 
left the Rothstein firm with the 
lawsuit, did 
you? 
A 
I have come to know from hearing over the 
years that it was never served, but I don't recollect 
whether it was served or not. I do remember at some 
point in time saying we should serve this. I don't 
remember it never being served or it being served. I 
know that it was dismissed at the same time as the 
other cases were settled. 
Q 
Let me ask it this way. Do you know --
MR. GOLDBERGER: Excuse me, Scott. The 
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videographer says he has five minutes. 
THE WITNESS: We have five minutes. 
MR. LINK: Yeah. I think I can finish 
this up. 
BY MR. LINK: 
Q 
The 
. federal lawsuit -- like the 
lawsuit -- was, in fact, drafted while you were with 
Rothstein's firm. 
A 
We just went there through this. I don't 
remember whether it was drafted. I remember believing 
it should be drafted. 
Q 
And making the decision with Mr. Cassell to 
do that? 
MR. LINK: No waiver. 
MR. SCAROLA: Thank you. We could do 
this. Just give me a continuing agreement 
that there's no waiver, and I will let him 
continue to answer questions about this 
federal lawsuit. 
MR. LINK: Agreed. 
THE WITNESS: Sorry. State that 
question again. 
BY MR. LINK: 
Q 
I just want to --
A 
We were talking about 
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Q 
I want to tie it together, all right? 
So a decision was made on behalf of 
by you and Mr. Cassell while you were an employee at 
RRA to bring a separate federal court action against 
Mr. Epstein. 
A 
And we did. 
Q 
And you did. 
Also while you were at RRA, you and 
Mr. Cassell made the decision that you would file a 
lawsuit in federal court for—, 
just like you had 
done for 
A 
Correct. 
Q 
After leaving the Rothstein firm, you never 
filed the federal lawsuit for 
A 
Correct. 
Q 
And after leaving the Rothstein firm, you 
never served Mr. Epstein with the 
federal case? 
A 
You're telling me that? 
Q 
Yes. 
MR. SCAROLA: I object to Counsel 
testifying. 
BY MR. LINK: 
Q 
Do you remember that being the case? You 
do not? 
A 
I don't remember it not being filed, but I 
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have heard that --
MR. SCAROLA: Served. 
THE WITNESS: Served -- but I have 
heard that enough to believe it to be true 
that it wasn't served on him. 
MR. LINK: Good place to take a break. 
THE VIDEOGRAPHER: The time is 
11:49 a.m. This concludes tape one. We are 
going off the record. 
(A recess was had.) 
THE VIDEOGRAPHER: The time is 
12:05 p.m. This is the beginning of tape 
two. We are back on the record. 
BY MR. LINK: 
Q 
Mr. Edwards, do you now have in front of 
you Plaintiff's Exhibit 1 --
A 
Yes. 
(Plaintiff's Exhibit Number 1 was marked 
for identification.) 
BY MR. LINK: 
Q 
-- which is the affidavit of Mr. Epstein? 
Have you seen this before? 
A 
I saw it when it was originally filed. 
Q 
Would you please --
MR. SCAROLA: For the record, we have 
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moved to strike this affidavit. We believe 
it to be inadmissible. It is violative of 
the sword-shield doctrine, and we object to 
its use. 
BY MR. LINK: 
Q 
You may look at the entire affidavit if you 
want, but I'm going to focus you on paragraph six at 
least to start with. Just take a moment to read 
paragraph six. 
A 
Okay, I read it. 
Q 
Looking at the first sentence, do you have 
any reason to believe that that first sentence is not 
true? 
MR. SCAROLA: I'm going to object. 
There are a wide variety of separate factual 
assertions contained within that first 
sentence, and therefore, the question is 
compound. 
THE WITNESS: This is -- purports to be 
statements made by Jeffrey Epstein, which is 
pretty interesting, given that he invokes 
his Fifth Amendment right against 
self-incrimination every time I've ever 
asked him anything that was on the record. 
So his statement in early November 2009 --
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this is his statement about what stories 
were in the press at the time. 
BY MR. LINK: 
Q 
I'm asking you if this factual assertion in 
the first sentence is -- do you agree it's a true 
statement or not? 
MR. SCAROLA: And my objection is, 
there is not a factual assertion, but a 
multiplicity of allegations included in that 
first sentence, so the question is compound. 
THE WITNESS: Let me just read it out 
loud then I will try to answer your 
question. 
"In early November 2009, stories in the 
press, on the news, and on the Internet were 
legion about the implosion of RRA." 
BY MR. LINK: 
Q 
Let's just break it down statement by 
statement. Is that a true statement? 
MR. SCAROLA: I am going to object to 
that question on the basis that it is vague 
and ambiguous, particularly with regard to 
what legion means. 
THE WITNESS: There were stories in the 
news about the implosion of RRA. That's 
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true. 
BY MR. LINK: 
Q 
Multiple stories? 
A 
Yeah. That's what the news cycle was about 
in Broward County at the time, was the implosion of 
RRA. 
Q 
Not just Broward, it was statewide news? 
A 
It was statewide news. 
Q 
It was national news? 
A 
The RRA implosion was --
Q 
Yes, sir. 
A 
-- was widespread news. I don't know --
yeah, I think it was national news. Certainly where we 
lived everybody knew about it. 
Q 
No question that in early November 2009 the 
press and the news was extensive relating to the 
implosion of the Rothstein firm? 
A 
Absolutely. 
Q 
And that press included information about 
the Ponzi scheme that was perpetrated at Rothstein, 
true? 
A 
I believe so. I mean, I don't know about 
November 2009, but at some point in time after --
pretty soon after 
it was -- there was news about it 
being a Ponzi scheme 
that Rothstein was running a 
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Ponzi scheme. It could have been December. It could 
have been January. I don't know. Right after. 
Q 
Let's take a look at some of the November 
articles. 
A 
Okay. 
Q 
Let me show you what's marked Plaintiff's 
Exhibit 2. Are you familiar with the Legal Junkies? 
A 
No. 
(Plaintiff's Exhibit Number 2 was marked 
for identification.) 
BY MR. LINK: 
Q 
You see this is dated November 2nd, 2009? 
Upper left-hand corner. 
A 
Yes. 
Q 
Wall Street Journal Law Blog, do you see 
that? 
A 
Point me where. 
Q 
Upper left-hand corner. 
A 
Yes. 
Q 
Do you see that on November 2nd, that there 
was this article about the Rothstein law firm? 
A 
There was an article about the Rothstein law 
firm, yes. 
Q 
Including the investment scheme and the 
structured settlements. 
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A 
Let me read it and I will tell you what I 
think it's about. Do you want me to read the 
updated --
Q 
No. I just want to make sure -- this is 
November 2nd. The statement we looked at was in 
early November 2009. And I'm showing you some of the 
articles to confirm that this statement in this 
affidavit that we are focused on, this one aspect of 
it, was true. 
MR. SCAROLA: For purposes of this line 
of questioning, since there has been no 
predicate laid with this witness as to the 
authenticity of this document, we will 
accept your representation that it is 
authentic. But we don't know that 
independently. So we are making that 
assumption for purposes of allowing this 
further line of questioning. 
THE WITNESS: And consistent with any 
answer, this is an article that confirms 
what I said, which is, there was news about 
the implosion of RRA. 
At this point in time -- you have given 
me an article from 11/2/09 -- there's 
nothing that identifies whatever Scott 
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Rothstein was alleged to have done as a 
Ponzi scheme at this time. 
BY MR. LINK: 
Q 
In this one article? 
A 
In this one I don't see it yet. I'm not 
saying it didn't happen. It could have. But what 
you're showing me doesn't say that. 
Q 
We're going to get there. We're going to 
take a look at these. So this one comes out 
November 2nd. And I see that your name is on the 
second page. Bradley J. Edwards as a lawyer at 
Rothstein, Rosenfeldt & Adler. You see that? 
MR. SCAROLA: Help me. 
MR. LINK: About maybe 10 down from the 
column. 
THE WITNESS: It's on the fourth page. 
BY MR. LINK: 
Q 
Fourth page, there's a list of --
A 
Yeah, I was a lawyer at RRA, so yes it 
lists 
looks like it lists every lawyer at RRA. 
There's a list that goes on for two pages, so yes. 
Q 
So in this article --
A 
My name is there. 
Q 
-- your name is there. 
MR. SCAROLA: Excuse me. 
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MR. LINK: Yes sir. 
MR. SCAROLA: You are referencing that 
as being part of this article. It, in fact, 
appears to be a blog-posted comment to the 
article, as opposed to part of the article 
itself. 
MR. LINK: I will take that 
representation. 
MR. SCAROLA: Somebody in response to 
the article posted a list of the lawyers in 
the firm. Fair? 
MR. LINK: Fair. Fair enough. 
BY MR. LINK: 
Q 
This is the first time -- Mr. Edwards --
MR. SCAROLA: Can we also agree that 
whoever posted this isn't even identified? 
MR. LINK: We can agree it is what it 
is. Whatever it says, it says. 
THE WITNESS: It says unregistered 
guest. 
MR. SCAROLA: Unregistered guest. 
Whoever that is. 
MR. LINK: Whoever that is. Okay. 
BY MR. LINK: 
Q 
Mr. Edwards, I'm not sure I got an answer. 
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And if I did, I apologize. I didn't meant to ask it 
again. But in looking at Plaintiff's Exhibit 2, is 
this the first time that you have -- that you knew 
that your name was listed by somebody related to that 
article? 
A 
I don't know. I don't know one way or the 
other. 
Q 
Now, let's take a look at Exhibit 3. 
(Plaintiff's Exhibit Number 3 was marked 
for identification.) 
BY MR. LINK: 
Q 
This is a November 6 article. And the 
headline is "Scott Rothstein: The Jeffrey Epstein 
and Bill Clinton ploy." Do you see that? 
A 
Yes. 
Q 
Did you see this article when it came out 
November 6, 2009? 
A 
I don't remember. Like you said, there were 
a lot of articles. I don't know which ones I saw, 
which ones I didn't. 
Q 
Do you see that on the second page it talks 
about the Ponzi imploding? In the upper top, page 
two. 
A 
Yeah, I know. It's the end of a sentence. I 
am just reading the beginning. Yes. 
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