EFTA00800508

101 
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 by November 6, at least, this article is 
mentioning the word Ponzi. 
A 
Somebody is calling it a Ponzi by then 
Q 
So do you now agree with me that there were 
stories in the press in early November 2009 
discussing the Ponzi scheme perpetrated at RRA? 
A 
I agree 
MR. SCAROLA: Again, assuming the 
authenticity of this online printout, I will 
agree that this online printout says what it 
says and makes reference to the Ponzi scheme 
imploding. 
THE WITNESS: I will agree to the same 
thing. 
BY MR. LINK: 
Q 
The reason I'm showing you this article is 
because when I asked you if that part of the sentence 
of paragraph six was accurate, you said, I don't 
remember whether the word Ponzi was used in the 
articles in November or whether it was December. 
A 
Exactly. 
Q 
So I am showing these to you now to confirm 
that, in fact, in early November the Ponzi scheme was 
being discussed in the press. 
A 
I will agree that it appears that the New 
Palm Beach Reporting Service, Inc. 
EFTA00800608

102 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Times used the word Ponzi on November 6th of 2009. I 
don't think that we are disputing at all that this was 
a Ponzi scheme. Everybody knows what it was, so --
Q 
It's not whether -- I'm not disputing with 
you whether it was. We know that it was. I'm asking 
you whether the statements in this affidavit -- the 
factual statements so far -- we are on paragraph six 
only -- were accurate. 
So the statement that I was focused on was 
that in early November 2009, that the Ponzi scheme 
perpetrated at the firm, meaning RRA, was in the 
press and on the news. You agree that it was? 
A 
I agree that this article on November 6 of 
2009 said the word Ponzi. It could have very well been 
in a bunch of articles by then. It could have very 
well been on the news. I'm not disputing it being 
there. I just don't remember the timing of when 
everybody decided what it was. 
Q 
And you see on page two, that's a picture 
of Mr. Epstein, right? 
A 
Yes. 
Q 
And underneath his picture it says, 
"Epstein was bait." You see that? 
A 
I do see that. 
Q 
Was Mr. Epstein used as bait by the RRA 
Palm Beach Reporting Service, Inc. 
EFTA00800609

103 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
firm to attract potential investors? 
A 
I don't see that sentence. 
Q 
I'm asking you. 
MR. SCAROLA: Excuse me. I'm going to 
object, unless a predicate is laid with 
regard to Mr. Edwards' personal knowledge. 
MR. LINK: He has or he doesn't. He 
can answer the question. 
THE WITNESS: Are you referring to a 
specific sentence in this article? 
BY MR. LINK: 
Q 
Do you see the words under his picture? 
A 
Yes. It says, "Epstein was used as bait." 
Q 
Read the sentence. It says, "One way he 
did it --" talking about Mr. Rothstein -- "was by 
tricking investors into believing that his firm was 
representing numerous underaged girls who had sex 
with Palm Beach billionaire and convicted child 
sex-offender Jeffrey Epstein, sources have 
confirmed." 
A 
I see that sentence, too. 
Q 
And I asked you whether Mr. Epstein was 
used as bait to attract potential investors. 
MR. SCAROLA: And I have objected, 
unless a predicate is laid with regard to 
Palm Beach Reporting Service, Inc. 
EFTA00800610

104 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
Mr. Edwards' personal knowledge. 
THE WITNESS: I would have no way of 
knowing that. 
BY MR. LINK: 
Q 
And do you see the next sentence says 
this is November 6 -- "On top of that, Rothstein 
claimed that he had flight logs showing that Epstein 
flew extremely prominent people, including former 
President Bill Clinton, on his private jet with some 
of the plaintiffs." 
A 
I see that sentence. 
Q 
The person who obtained the flight logs 
from Mr. Epstein for his airplanes during the RRA 
period of representing the three investors (sic) was 
you, correct? 
A 
I was one of numerous attorneys who took 
pilot depositions. And as a consequence of a subpoena 
duces tecum, the pilot brought the flight logs to the 
deposition. So I was one of several lawyers who had 
access to flight logs as a result of that deposition 
that we took in the legitimate cases where we 
represented 
and Jane Doe, who were actual 
underaged victims of Jeffrey Epstein's child 
molestation. That's what happened. 
Q 
Did any of those three folks that you 
Palm Beach Reporting Service, Inc. 
EFTA00800611

105 
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 
represented tell you that they had sex on 
Mr. Epstein's plane? 
MR. SCAROLA: Excuse me. I'm going to 
object. That clearly calls for 
attorney-client privileged information. 
BY MR. LINK: 
Q 
And when they were asked that question 
during their depositions in the underlying cases, did 
any of them testify that they were on Mr. Epstein 
planes and had sex on them? 
A 
When they were asked what they told me? 
Q 
No. During their depositions -- not what 
they told you. When they were asked during their 
depositions. I am getting away from the 
attorney-client. It was a good objection. 
During their depositions they were asked 
whether they were on Mr. Epstein's plane and had sex 
with him. Did any of the three folks that the 
Rothstein firm represented say they were, in fact, 
on the plane and had sex with Mr. Epstein on his 
plane? 
A 
They were asked that question? 
Q 
Do you know whether they were, sir? 
A 
No, I don't remember whether they were. They 
were asked a lot of questions. 
Palm Beach Reporting Service, Inc. 
EFTA00800612

106 
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 
Q 
So if you don't remember, you don't 
remember. 
A 
I don't remember. 
Q 
Do you know who the sources are that have 
confirmed that the Rothstein firm used Epstein as 
bait? 
A 
No. 
Q 
You said there were several lawyers -- and 
let me make sure I understand that. I am talking 
about the lawyers at the Rothstein firm. I thought 
you told me that you were the lead lawyer for the 
three clients with claims against Mr. Epstein during 
the six months that you were employed at the 
Rothstein firm. 
A 
I did tell you that. 
Q 
And you, in fact, were the lawyer for the 
Rothstein firm that took the depositions of the 
pilots, true? 
A 
Right. 
Q 
And so you would have been the lawyer at 
the Rothstein firm that had received the flight logs 
from the pilots, true? 
A 
All right. Here is what I'm trying to tell 
you is -- so, Bob Josefsberg was prosecuting cases 
against Jeffrey Epstein on behalf of --
Palm Beach Reporting Service, Inc. 
EFTA00800613

107 
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 
Q 
Let me stop you. 
MR. SCAROLA: No. I'm sorry. 
MR. LINK: I don't want to 
interrupt him if he's 
Jack, he's answering my question. 
THE WITNESS: I am. 
MR. SCAROLA: Well, that's fine. You 
can move to strike the response, but you 
can't interrupt him. 
MR. LINK: Actually, I can. 
MR. SCAROLA: No, you cannot. 
MR. LINK: My question was really 
simple. 
MR. SCAROLA: Well, whether it's simple 
or not, he's going to answer the question 
and complete his response. If you find it 
to be unresponsive, you can move to strike. 
But he's permitted to complete his answer. 
MR. LINK: He's actually not. He's not 
permitted to answer a question I haven't 
asked. And you know that. 
MR. SCAROLA: Continue, if you would 
with your response. 
BY MR. LINK: 
Q 
Mr. Edwards, answer question, please. 
Palm Beach Reporting Service, Inc. 
EFTA00800614

108 
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 
I am answering question. 
Q 
You are? 
A 
Yes. 
Q 
So my question was really simple. 
MR. SCAROLA: No, I'm sorry. You are 
not going to ask another question until 
Mr. Edwards has had a chance to respond to 
the question that you already asked when you 
interrupted him in the middle of his answer. 
You may not like the answer. You may 
think it's unresponsive. You can move to 
strike it. But he gets to finish it. So 
continue if you would, please. 
BY MR. LINK: 
Q 
So before you continue it --
MR. SCAROLA: No, not before he 
continues --
BY MR. LINK: 
Q 
You are going to answer my question? 
That's what you were going to do? 
A 
Yes, I'm going to answer your question. 
Q 
Then answer my question. 
A 
So, Bob Josefsberg represented a volume of 
girls, who, when they were underaged, were molested by 
Jeffrey Epstein. Adam Horowitz represented six or 
Palm Beach Reporting Service, Inc. 
EFTA00800615

109 
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 
seven girls who were victims of Jeffrey Epstein's 
molestation. I represented three girls who were 
victims of Jeffrey Epstein's molestation. 
Mr. Scarola's firm represented females who were victims 
of Jeffrey Epstein's molestation, and so did Sid 
Garcia, and so did Spencer Kuvin. 
There were so many girls that Jeffrey 
Epstein molested while they were underaged that 
there were many lawyers involved. 
When we took depositions of anyone, all of 
the plaintiffs' lawyers would decide together whose 
deposition we were taking, what the objective was, 
and what evidence that we could obtain from them. 
With respect to the pilots, the subpoena 
duces tecum required for the pilot to bring the 
flight logs. The flight logs were produced at the 
deposition, and produced so that all of the 
plaintiffs' lawyers would have them. 
So to say that I'm the one who got them 
from the pilot, maybe I was. Maybe it was Jack, 
maybe it was Bob. But they were copied. And I had 
access to them for sure. Bob had access to them for 
sure. All of the plaintiffs' lawyers did at the 
same time. It wasn't me out on some vigilante 
mission that got these flight logs. 
Palm Beach Reporting Service, Inc. 
EFTA00800616

110 
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 
That's the only clarification that I'm 
trying to make for you. I think that we are not 
necessarily on a different page with what you want. 
Q 
And you think that answer is responsive to 
my question? 
A 
Yes. Was I the person who got the flight 
logs? That's your question. 
Q 
No. I said were you the lawyer at the 
Rothstein firm -- only asked you about the Rothstein 
firm. I don't care about Mr. Scarola. He wasn't 
even at the deposition. I don't care about 
Mr. Josefsberg, unless you are telling me he gave the 
flight logs to somebody at the Rothstein firm, and 
then I will ask Bob if that's true. 
A 
It wouldn't be to me. 
Q 
That's was my question. Was there somebody 
other than you that would have had possession of 
bringing those flight logs back to the Rothstein firm 
while you were an employee? 
A 
From wherever I got it from, right. No. 
Q 
Just you, right? 
A 
Yes. 
Q 
Okay. That was my question. 
And --
A 
Apparently I didn't understand it. Sorry. 
Palm Beach Reporting Service, Inc. 
EFTA00800617

111 
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 
Q 
I tried to ask it again, but Mr. Scarola 
insisted that you give me your speech, and that's 
okay. 
MR. SCAROLA: Objection. Move to 
strike. Argumentive. 
BY MR. LINK: 
Q 
Did the flight logs that you took back to 
the Rothstein firm have information about Bill 
Clinton, for example, being on the plane? 
A 
The flight logs did indicate that Bill 
Clinton was one of the passengers with Jeffrey Epstein 
and his co-conspirators on his airplane, yes. 
Q 
Do you know whether Mr. Scarola or 
Mr. Josefsberg or any of the other lawyers that you 
mentioned when you were discussing the flight logs 
would have provided that information to 
Mr. Rothstein? 
A 
I wouldn't think that anyone provided that 
information to Mr. Rothstein. 
Q 
I'm asking about the lawyer you mentioned. 
Mr. Scarola, your lawyer here, who you represented 
A 
I don't think so. 
Q 
You don't think he gave it to 
Mr. Rothstein, do you? 
A 
No. 
Palm Beach Reporting Service, Inc. 
EFTA00800618

112 
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 
Q 
You don't think Mr. Josefsberg did, do you? 
A 
No. 
Q 
You don't think Mr. Kuvin did, do you? 
A 
No. 
Q 
You don't think Ted Leopold did, do you? 
A 
No. I don't believe anyone did. 
Q 
Let's take a look at this next one. 
(Plaintiff's Exhibit Number 4 was marked 
for identification.) 
BY MR. LINK: 
Q 
Are you on any medication today for your 
anxiety? 
A 
No. 
Q 
Have you ever been on medication for 
anxiety --
A 
No. 
Q 
Let me just finish. 
Have you ever been on medication for 
anxiety since December 2009? 
A 
No. 
Q 
This is an article dated November 12. This 
is an article in the Sun Sentinel. "FBI doubts 
Rothstein ran a Ponzi scheme alone." Do you see 
that --
A 
Yes. 
Palm Beach Reporting Service, Inc. 
EFTA00800619

113 
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 
Q 
-- is the headline. Take a minute and take 
a look at it. 
A 
Yep. 
Q 
Do you know Mr. John 
I'm probably saying 
this wrong -- John Gillies 
A 
No. 
Q 
-- the head of the FBI in South Florida? 
When he said, "I do not believe that this was a 
one-man show." You see that statement? 
A 
I do. 
Q 
You see that Mr. Rosenfeldt, at the bottom, 
said that he had no clue about what was going on? 
A 
I see a statement in this article that says, 
Rothstein's partner, Stuart Rosenfeldt, has said he 
had, quote, no clue, end quote, about the alleged 
fraud. 
Q 
Was that Mr. Rosenfeldt's position during 
the last few days of the Rothstein firm while you 
were employed there? 
A 
I don't know that I gathered his position 
about anything. 
Q 
You're aware that he filed, on behalf of 
the law firm, a preemptive lawsuit to appoint a 
receiver. You knew that? 
A 
I do remember it was filed. Those kind of 
Palm Beach Reporting Service, Inc. 
EFTA00800620

114 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
details aren't totally fresh in my mind. I don't know 
that he filed it as opposed to somebody. I don't know. 
Q 
Wasn't it a big deal when you learned out 
that the firm you were working for had committed a 
massive 1.some-billion-dollar Ponzi scheme? 
MR. SCAROLA: Excuse me. I'm going to 
object to that question. It assumes facts 
not in evidence, and that is that the firm 
committed a Ponzi scheme. 
BY MR. LINK: 
Q 
Go ahead? 
A 
This was big news to everybody, yes. 
Q 
How did you find out? 
A 
I remember going to a meeting on -- I believe 
it was a Monday -- like down in, like, a 
cafeteria-style -- the bottom floor of the building 
that the firm was located in. I don't remember exactly 
what was told to us, but somebody came in and said 
Rothstein's in Morocco, trust funds are missing, the 
firm's closing down. I don't think I stayed for much 
more than that. 
Q 
It was a pretty horrific day, I would 
guess. 
A 
Yeah, it was a bad day. 
Q 
Is there any doubt in your mind that in 
Palm Beach Reporting Service, Inc. 
EFTA00800621

115 
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 
early November 2009, that the press and the news 
covered the implosion of RRA --
A 
No. 
Q 
-- and covered the Ponzi scheme perpetrated 
at that firm? Right? 
A 
No. There's no doubt. 
Q 
And so this first sentence is a true, 
factual sentence from paragraph six 
A 
What exhibit are we on? 
Q 
We are on Exhibit Number 1, which would be 
affidavit -- the sworn statement by Mr. Epstein. 
A 
Okay, first sentence. 
Q 
Is there anything that you would say is 
inaccurate or untrue about the first sentence of 
paragraph six? 
A 
"In early November 2009, stories in the 
press, on the news, and on the Internet were legion 
about the implosion or RRA, the Ponzi scheme 
perpetrated at that firm, and the misuse in the Ponzi 
Scheme of certain civil cases then being litigated 
against me by RRA partner, Edwards." 
To the extent that it's saying that the 
press was -- the press was -- that I was involved in 
the Ponzi scheme, that's not true. 
Q 
Does this sentence say you were involved in 
Palm Beach Reporting Service, Inc. 
EFTA00800622

116 
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 Ponzi scheme, sir? 
A 
Well, it says, "The Ponzi scheme perpetrated 
at the firm, and the misuse in the Ponzi scheme of 
certain civil cases then being litigated against me by 
RRA partner, Edwards." It's trying to imply that. 
Q 
Okay. But does it say that? 
A 
It implies that. It's not perfectly written. 
Q 
Were Mr. Epstein's files being used as part 
of the Ponzi scheme? 
A 
You showed me an article that says that --
Q 
They were? 
A 
Yeah. "One way he did it was by tricking 
investors into believing that his firm as representing 
numerous underaged girls who had sex with Palm Beach 
billionaire and convicted sex offender Jeffrey 
Epstein." 
That doesn't say that the cases against 
Epstein -- it doesn't say anything about the 
legitimate cases against Epstein. 
Q 
I didn't say it did, did I? 
All I'm asking you is, isn't it a fact 
isn't it a true fact that these articles say that 
Scott Rothstein used the Epstein litigation in order 
to attempt to entice investors to make the 
investment? 
Palm Beach Reporting Service, Inc. 
EFTA00800623

13.7 
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: Excuse me. 
THE WITNESS: So far you haven't shown 
me that. 
BY MR. LINK: 
Q 
Then let's go back and take a look at 
Exhibit Number 3 that we walked through and has 
Mr. Epstein's picture that says Epstein was bait. 
A 
Right. 
Q 
You see that? 
A 
Yes. 
Q 
So I want you to read that -- this article, 
and tell me if you agree that this article -- whether 
it was true or not -- that this article suggests that 
the cases that you were handling as the lead 
lawyer --
A 
Right. 
Q 
were being used by Rothstein as bait in 
order to lure investors. 
A 
Is there a part of the article that you want 
to point me to, or do you want me to read this whole 
article? 
MR. SCAROLA: Can we agree Mr. Edwards' 
name appears nowhere in this article? 
MR. LINK: What does that have to do 
with anything, Jack? 
Palm Beach Reporting Service, Inc. 
EFTA00800624

118 
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: You just asked him 
whether the article says that the cases that 
he was prosecuting were being used as bait. 
MR. LINK: Sure. 
MR. SCAROLA: Mr. Edwards' name is not 
referenced. There's no --
MR. LINK: I never said that it was, 
Jack. 
MR. SCAROLA: There's no reference in 
this article to the cases that Brad was 
prosecuting. 
MR. LINK: I never said it was. Is 
that an objection to the form? What is it? 
MR. SCAROLA: That's exactly what it 
is. You are --
MR. LINK: Then say, objection to the 
form. 
MR. SCAROLA: You are misrepresenting 
what the article says. It says what it 
says. It doesn't identify the cases that 
Brad was prosecuting. 
MR. LINK: You didn't hear my question. 
Listen, I have let you give a lot of 
speeches today, and they have been very 
informative and I have enjoyed them. But if 
Palm Beach Reporting Service, Inc. 
EFTA00800625

119 
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 have an objection, please just make it 
to form now. 
MR. SCAROLA: That's fine. 
MR. LINK: Thank you. 
THE WITNESS: Let me just read the 
article now. 
MR. SCAROLA: And while Brad is reading 
the article, could we have the question read 
back please. 
(Thereupon, the requested portion of the 
record was read back by the reporter as 
above duly recorded.) 
MR. SCAROLA: Do we agree that what you 
were asking was whether Brad's cases were 
being used to lure investors? 
MR. LINK: That's what I said. 
MR. SCAROLA: That's right. That's 
what I've objected to, because Brad's not 
referenced anywhere in the article. It 
doesn't say that. 
MR. LINK: I never said he was. Let's 
not argue about it. The question is what it 
is. You got your objection. It's one of my 
better questions of the day. 
THE WITNESS: So what this article says 
Palm Beach Reporting Service, Inc. 
EFTA00800626

120 
1 
2 
3 
4 
6 
7 
8 
9 
10 
11 
12 
13 
14 
15 
16 
17 
18 
19 
20 
21 
22 
23 
24 
25 
BY MR. LINK: 
Q 
Mr. Edwards, do you remember the question? 
A 
You can ask it again. 
Q 
So let me give you the question to help 
maybe clarify Mr. Scarola's comments. Were there any 
other lawyers at the Rothstein firm while you were 
there that represented any other plaintiffs, other 
than the three that we have been talking about, in 
lawsuits against Mr. Epstein? 
A 
Well, 
and Jane Doe were the only 
case at RRA. 
Q 
So the only cases at RRA were the cases 
that you were the lead lawyer for, correct? 
A 
The only legitimate cases against Jeffrey 
Epstein where the clients were actually molested by 
Jeffrey Epstein, I was the lead lawyer on. That's what 
this article is talking about, but yes. 
Q 
I just wanted to clarify, because I asked 
if the cases that you were the lead lawyer on, those 
three are the cases that this article is discussing 
that Mr. Rothstein was using? 
A 
I doesn't appear to be. What this article 
appears to be saying is that -- and this is from Bill 
Scherer -- saying he used Epstein cases as showpiece as 
Palm Beach Reporting Service, Inc. 
EFTA00800627