IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, ## PART 8 v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. #### PLAINTIFF/COUNTER-DEFENDANT JEFF DOCUMENTS IN SUPPORT OF II1S REVI EIN'S APPENDIX OF BUS MOTION IN LIMINE Plaintifl7Counter-Defendant Jeffrey E in support of his revised Omnibus Motio : tein") files this Appendix of Documents Co s | No. | Date | Document | | --- | ------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 1 | 1/5/11 | Epstein's Motion to Amend Complaint (D.E. 195) | | 2 | 4/9/09 | Plaintiff's Motion to Strike References to Non-Prosecution Agreement or, in the Alternative, to Lift Protective Order Barring Jane Doe's Attorneys from Revealing Provisions in the Agreement (D.E. 32); Jane Doe v. Jeffrey Epstein ; S.D. Fla. Case No. 9:08-cv-80893-KAM | | 3 | 4/17/09 | Plaintiff's First Amended Complaint (D.E. 38)
Jane Doe v. Jeffrey Epstein ; S.D. Fla. Case No. 9:08-cv-80893-KAM | | 4 | 4/30/09 | Jeffrey Epstein's Deposition Transcript Excerpts (pp. 148, 151-152); E.W. v. Jeffrey Epstein ; 15 th Judicial Circuit Case No. 50-2008-CA-028058-XXXX-MB | | No. | Date | Document | | --- | ------------------ | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 5 | 6/19/09 | Plaintiff's Motion for Injunction Restraining Fraudulent Transfer of Asserts, Appointment of a Receiver to Take Charge of Property of Epstein, and to Post a \$15 Million Bond to Secure Potential Judgment (D.E. 165); Jane Doe 2 v. Jeffrey Epstein ; S.D. Fla. Case No. 08-cv-80119-MARRA/ [REDACTED] | | 6 | 11/5/09 | Order Denying Plaintiff's Motion for Injunction, etc. (D.E. 400) Jane Doe 2 v. Jeffrey Epstein ; S.D. Fla. Case No. 08-cv-80119-MARRA/ [REDACTED] | | 7 | 7/22/09 | Letters from [REDACTED] re depositions | | 8 | 7/27/09 | Complaint (D.E. 1)
L.M. v. Jeffrey Epstein ; S.D. Fla. Case No. 9:08-cv-81092-KAM | | 9 | N/A | Court Docket
L.M. v. Jeffrey Epstein ; S.D. Fla. Case No. 9:08-cv-81092-KAM | | 10 | 8/11/09
8/24/09 | Re-Notices of Taking Videotaped Deposition of Donald Trump
Jane Doe v. Jeffrey Epstein ; S.D. Fla. Case No. 9:08-cv-80893-KAM | | 11 | 8/10/09 | Plaintiff's Request for Entry Upon Land (D.E. 143)
E.W. v. Jeffrey Epstein ; 15 th Judicial Circuit Case No. 50-2008-CA-028058-XXXX-MB | | 12 | 8/24/09 | Epstein's Motion for Protective Order Regarding Depositions of Lawrence Visoski and David Hart Rogers (D.E. 159)
L.M. v. Jeffrey Epstein ; 15 th Judicial Circuit Case No. 50-2008-CA-028051-XXXX-MB | | 13 | 11/3/09 | Article: South Florida Sun-Sentinel - Scott Rothstein's investment deals seemed too good to be true | | 14 | 11/6/09 | Article: New Times Broward-Palm Beach - Scott Rothstein: The Jeffrey Epstein and Bill Clinton Ploy | | 15 | 11/9/09 | Verified Complaint for Forfeiture In Rem (D.E. 1)
United States of America v. Scott W. Rothstein (Forfeiture Action); S.D. Fla. Case No. 0:09-CV-61780-WJZ | | 16 | 11/12/09 | Article: South Florida Sun-Sentinel - FBI doubts Rothstein ran a Ponzi scheme alone | | No. | Date | Document | | --- | ------------------------------ | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 17 | 11/20/09 | Complaint (without exhibits) (D.E. 3)
Razorback Funding, LLC v. Rothstein
17th Jud. Cir. Case No. 062009CA062943AXXXCE | | 18 | 11/23/09 | Amended Verified Complaint for Forfeiture In Rem (D.E. 14)
United States of America v. Scott W. Rothstein (Forfeiture Action);
S.D. Fla. Case No. 0:09-CV-61780-WJZ | | 19 | 11/23/09 | Article: South Florida Sun-Sentinel – You're in a town full of thieves | | 20 | 11/24/09 | Article: The Miami Herald – Feds: Scott Rothstein Ponzi scheme paid salaries at law firm | | 21 | 11/25/09 | Amended Complaint (without exhibits) (D.E. 12)
Razorback Funding, LLC v. Rothstein
17th Jud. Cir. Case No. 062009CA062943AXXXCE | | 22 | 12/1/09 | Information (D.E. 1)
United States v. Rothstein ; S.D. Fla. Case No. 0:09-cr-60331-JIC | | 23 | 12/7/09 | Complaint (without exhibits) (D.E. 5) | | 24 | 6/30/17 | Affidavit of Jeffrey Ep [REDACTED] (D.E. 931) | | 25 | 11/10/17 | Bradley J. Edwards' Deposition Transcript Excerpts (pp. 163-164, 166, 227-229, 259-260, 276-278, 321-322, 338-339) | | 26 | 3/23/10 | Bradley J. [REDACTED] Deposition Transcript Excerpts (pp. 112, 116-117, 123-125, 230-231) | | 27 | 10/10/13 | [REDACTED] J. [REDACTED] Deposition Transcript Excerpts (pp. 205) | | 28 | 7/26/09
8/13/09
10/23/09 | Email from Pricilla Nascimento to Scott Rothstein
Email from [REDACTED] J. [REDACTED] to Priscilla Nascimento
Email from Ken Jenne to Scott Rothstein | | 29 | 6/14/12 | Scott Rothstein's Deposition Transcript Excerpts (pp. 23-26, 52-53) | | No. | Date | Document | | --- | -------- | -------------------------------------------------------------- | | 30 | 12/12/11 | Scott Rothstein's Deposition Transcript Excerpts (pp. 59-62); | | 31 | 12/21/11 | Scott Rothstein's Deposition Transcript Excerpts (p. 2278) | | | | Razorback Funding. LLC v. Rothstein; 17th Jud. Cir. Case No. | | 32 | 3/17/10 | Jeffrey Epstein's Deposition Transcript Excerpts (pp 1 14, 19- | | | | 20, 23, 25-26, 28-34, 36-39, 48-55, 57, 59-60, 62-69, 6-80, | | 33 | 11/9/17 | Amended Exhibit List (D.E. 10 | | 34 | 11/15/17 | Epstein's Objections to A e ed Exhibit List | | 35 | 11/9/17 | Seventh Amended emental Witness List | | 36 | 1/25/12 | Jeffrey Epstein's Depv n Transcript Excerpts (pp. 19-21) | **CERTIFICATE OF SERVICE** I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on November 21, 2017, through the Court's e-filing portal pursuant to Florida Rule of Judicial Administration 2.516(b)(1). LINK & ROCKENBACH, PA\ 1555 Palm Beach Lakes Boulevard, Suite 301\ West Palm Beach, Florida 33401\ (561) 727-3600; (561) 727-3601 [fax] By: /s/ Scott J. Link\ Scott J. Link (FBN 602991)\ Kara Berard Rockenbach (FBN 44903)\ Angela M. Many (FBN 26680)\ Primary: Scott@linkrocklaw.com\ Primary: Kara@linkrocklaw.com\ Primary: Angela@linkrocklaw.com\ Secondary: Tina@linkrocklaw.com\ Secondary: Troy@linkrocklaw.com\ Secondary: Tanya@linkrocklaw.com\ Secondary: Eservice@linkrocklaw.com *Trial Counsel for Plaintiff/Counter-Defendant\ Jeffrey Epstein* **SERVICE LIST** | Jack Scarola
Searcy, Denny, Scarola, Barnhart & Shipley, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, FL 33409
mep@searcylaw.com
jsx@searcylaw.com
scarolatcam@searcylaw.com
Co-Counsel for Defendant/Counter-Plaintiff
J. [REDACTED] | Nichole J. Segal
Burlington & Rockenbach, P.A.
Courthouse Commons, Suite 350
444 West Railroad Avenue
West Palm Beach, FL 33401
njs@FLAppellateLaw.com
kbt@FLAppellateLaw.com
Co-Counsel for Defendant/Counter-Plaintiff
J. [REDACTED] | | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | |

J. [REDACTED]
Pottinger LLC
425 N. Andrews Avenue, Suite 2
Fort Lauderdale, FL 33301-3268
brad@epllc.com
staff.efile@pathtojustice.com
Co-Counsel for Defendant/Counter-Plaintiff
J. [REDACTED]

|

Marc S. Nurik
Law Offices of Marc S. Nurik
One E. Broward Boulevard, Suite 700
Ft. Lauderdale, FL 33301
marc@nuriklaw.com
Counsel for Defendant Scott Rothstein

| | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | |

Jack A. Goldberger
Atterbury, Goldberger & Weiss, P.A.
250 Australian Avenue S., Suite 1400
West Palm Beach, FL 33401
jgoldberger@agwpa.com
smahoney@agwpa.com
Co-Counsel for Plaintiff/Counter-Defendant
Jeffrey Epstein

| | NOT A CERTIFIED COPY **APP.32** NOT A CERTIFIED COPY #### IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE No.502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, - vs - SCOTT ROTHSTEIN, individually, J. , individually, L.M., individually, and Defendants. G() . Repor Sandia Townsend, FPR No lic, State of Florida lm Beach Office Job #1358 #### VIDEOTAPED DEPOSITION QF'WEFFREY EPSTEIN. Wednesday, (Marc 17,) 2010, 10:17 a.r>lh 1;2/ p.m. ( SB \\ yan Boulevard Suite 400 Beach, Florida 33401 1 that question. 2 BY MR. SCAROLA: 3 Q. Have you ever acknowledged to — 4 A. Excuse me. 5 Q. — 6 A. Sir, may I suggest that if I say I refuse to 7 answer, that it means the Fifth, Sixth and 14th or would 8 you prefer that I recite it each time? 9 Q. I would prefer that you answer the questions, 10 that's my preference. But if you're going to assert a 11 privilege, I will assume that if you simply say that you 12 are refusing to answer, your refusal to answer will be 13 on the basis of various Constitutional privileges 14 against self-incrimination without the necessity of 15 specifying. 16 If your refusal to answer is on the basis of 17 any other privilege, it will be necessary for you to 18 identify that privilege. 19 A. Thank you. 20 MR. PIKE: And Pm going to instruct you, too, 21 when you do invoice, invoke the Fifth, Sixth and the 22 14th. 23 THE WITNESS: Yes. 24 BY MR. SCAROLA: 25 Q. Have you ever acknowledged in the presence of 1 invoke my Fifth, Sixth and 14th Amendment Right. 2 Q. Have you ever acknowledged in the presence of 3 Terri Becker, acoSorter present at a deposition 4 taken by Brad in a -- in a case in which the 5 individual identified by the initials L.M. was a 6 Plaintiff that you knew and/or liked — 7 MR PIKE: Form. 8 THE WITNESS: Again, — 9 BY MR. SCAROLA: 10 Q. - L.M.? 11 MR. PIKE: Same objection. 12 THE WITNESS: Again, I'm-going to have to 13 assert my Fifth, Sixth and 14Iltanendment Right. 14 BY MR. SCAROLA: 15 Q. Have you ever acknOftedged in the presence of 16 Steve Jaffe that you knew and?\* liked L.M.? 17 A. Again, Mr..Sdarola, though I'd like to answer 18 each and everyone of your questions today, I'm going to 19 have to, at the advice of Counsel, invoke my Fifth, 20 Sixth and 14th Amendment Right. 21. Q. Why ace you suing L.M.? 22 MR.R1RE: Form. 23 MR. SCAROLA: Let me state for the record that 24 it consider a form objection to be a proper 2 jection, unless you specify the defect in the 1 J. hat you knew the individual 2 identified by the initials L.M.? 3 A. Fm going to have to refuse to answer 4 question. 5silamycsever acknowledged in\* 6 1 that you knew L.1%,4.?/ 1 7 MR. PIKE: Again, for purposeigtherecord, 8 I'm instructing you to invoke the Fifth Sixth and 9 14th; rather than just simplist7t7\_ 10 THE WITNESS: Okay. 11 MR. PIKE: -- I refuse to answer. I want it 12 to be clear for the Court that you have invoked 13 your Fifth, Sixth and 14th. 14 THE WITNESS: Fine. 15 Then on advice of Counsel, Pm going to have 16 to invoke my Fifth, Sixth and 14th Amendment Right. 17 BY MR. SCAROLA: 18 Q. Have you ever acknowledged in Brad 19 presence that you liked the individual identified by the 20. initials L.M.? 21 A. Again, I'm going to have to invoke my Fifth, 22 Sixth and 14th Amendment Right, Mr. Scarola. 23 Q. Have you ever acknowledged in 24 presence that you liked L.M.? 25 A. Again, Mr. Scarola, I'm going to have to 17 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 form and provide me with an opportunity to correct the defect MR. PIKE: That's fine. I believe the rules provide otherwise. But, nonetheless, I stand on my objection to form. THE WITNESS: I'm sorry. You have to repeat the question. BY MR. SCAROLA: Q. Why are you suing EM.? MR. PIKE: Form. (THEVITNESS7L7M7isp.rt of a conspiriq, (TvitlfSEARIRTAITsieh7BnTidleTalwrds eatinr—\_,- (excuse me — creating fraudulent cases of a ( cuall)Thhargedratu in—Vvliialitl U.S.—Attomey, (hralready—ZhWd-thTfin7cof Rotltsicin—a firm of VeliiallEtiffd1WEdWingis a partner, was a partner, with creating fabncating malicious cases rof a sexual nature, includingcases with respect to me specifically, in order to fleece unsuspecting (inversirT.SoTitliFIcTridarati tifFnillionsofi (dollars. BY MR SCAROLA: Q. (Wha- Wrolnoyou coMendtMiTilaTed.iirtla (crispirWc57r'we. fraudularses?, A. (17,M.'FtFssinWy_bfor her'ire_t/v—. rr,IIIIIIIL 1 was dramatically -- sworn testimony to the FBI was\ 2 dramatically different after she came in contact with\ 3 Mr. [REDACTED] where her testimony then changed to\ 4 sort of a hostile and had claims of -- claims never [REDACTED]\ 5 before, never made to anyone before, and allegations\ 6 that I've read in her Complaint that that had been\ 7 dramatically different from the ones she had spoken to\ 8 the FBI about, sir. 9 Q. Is it your contention that L.M.'s statement to\ 10 the FBI was true? 11 MR. PIKE: Form. 12 THE WITNESS: Mr. Scarola, unfortunately,\ 13 today with respect to that question, I'm going to\ 14 have to assert my Fifth, Sixth and 14th Amendment\ 15 Right. Though I know -- I believe you know the\ 16 answer to that question, I can't answer the\ 17 question under advice of Counsel. And he's told me\ 18 if I chose to do so, I risk losing his\ 19 representation. 20 BY MR. SCAROLA: 21 Q. What is the basis of your belief that I know\ 22 the answer to the question? 23 MR. PIKE: Form. 24 THE WITNESS: You -- I believe you have seen\ 25 this, because you're supposed to be a decent 1 lawyer, you've read the testimony. I would guess\ 2 you've read the difference in her testimony to the\ 3 FBI versus her testimony after she's met your\ 4 client and his partners, who are currently in jail. 5 BY MR. SCAROLA: 6 Q. How does that respond to my question as to\ 7 whether you contend that her testimony to the FBI was\ 8 true or false? 9 MR. PIKE: Form. 10 THE WITNESS: I don't believe that was your\ 11 question. Will you repeat? 12 BY MR. SCAROLA: 13 Q. Okay. Well, let's -- let me rephrase the\ 14 question then. 15 Is it your contention that L.M.'s statement to\ 16 the FBI was true? 17 A. Sir, on advice of Counsel, at least today, I'm\ 18 going to have to assert my Fifth, Sixth and 14th\ 19 Amendment Right. 20 Q. Was L.M.'s statement to the FBI false in any\ 21 respect? 22 A. Sir, at least, again, today, on advice of\ 23 Counsel, I'm going to have to assert my Fifth, Sixth and\ 24 14th Amendment Right. 25 Q. Was L.M.'s subsequent testimony after, 1 according to you, she met Mr. [REDACTED] and changed her\ 2 testimony, true? 3 A. Did she change her testimony? Is that -- yes,\ 4 her testimony was changed. 5 Q. My question to you is: Was her testimony\ 6 which you contend was changed true testimony? 7 A. Your question is not a good question. Is it\ 8 her testimony before or after? 9 Q. Was the subsequent testimony given by L.M.\ 10 after she met Mr. [REDACTED] which you contend was\ 11 different from her testimony before the FBI, was the\ 12 subsequent testimony true or false? 13 MR. PIKE: Form. 14 THE WITNESS: Sir, I'm going, at least today,\ 15 I'm going to have to assert my Fifth, Sixth and\ 16 14th Amendment Right. 17 BY MR. SCAROLA: 18 Q. Did you ever engage in any sexual conduct with\ 19 L.M.? 20 A. I would like to answer that question, but -- 21 Q. You don't need to tell me what you'd like to\ 22 do, Mr. Ep [REDACTED] You just need to do it, please. 23 THE WITNESS: Please -- 24 MR. PIKE: Mr. Scarola, please let the witness\ 25 finish his response. 1 MR. SCAROLA: That's not a response to my\ 2 question. 3 MR. PIKE: In your mind it may not be a\ 4 response. In a Judge's mind, it may be. We may\ 5 have to certify it to the Court. If such a\ 6 procedure even exists, we can take it up with the\ 7 Court. But please let the witness finish his\ 8 response. 9 THE WITNESS: Again, please? 10 BY MR. SCAROLA: 11 Q. Did you engage -- ever engage in any sexual\ 12 conduct with L.M.? 13 A. I would like to answer that question; however,\ 14 today I'm going to have to assert my rights as provided\ 15 by the Fifth, Sixth and 14th Amendment to that question,\ 16 sir. 17 Q. Have you ever exchanged anything of value with\ 18 L.M.? 19 MR. PIKE: Form. 20 THE WITNESS: At least today, I'm going to\ 21 have to assert my Fifth, Sixth and 14th Amendment\ 22 Right, sir. 23 BY MR. SCAROLA: 24 Q. Did you ever direct anyone to deliver anything\ 25 of value to L.M.? 1 MR. PIKE: Form. 2 THE WITNESS: At least today, I'm going to 3 have to refuse to answer that question based on the 4 Fifth, Sixth and 14th Amendment. 5 BY MR. SCAROLA: 6 Q. Do you know 7 A. At least today, sir, l'm going to have to 8 refuse to testify about that question. Based on advice 9 of Counsel, I'm going to have to assert my Fifth, Sixth 10 and 14th Amendment Ri t. 11 Q. Did introduce you to L.M.? 12 A. Sir, respectfully, I'd lace to answer that 13 question today. As I said, I'd like to answer each and 14 every one of your questions. However, on advice of my 15 Counsel today, Pm going to have to assert my Fifth, 16 Sixth and 14th Amendment Right. 17 Q. Did L.M. suffer any damage as a consequence of 18 any interaction between you and L.M.? 19 MR. PIKE: Form. 20 THE WITNESS: Could you repeat the question, 21 please? 22 BY MR. SCAROLA: 23 Q. Did L.M. suffer any damage as a consequence of 24 any interaction between you and L.M.? 25 MR. PIKE: Form. 1 2 3 4 5 6 7 8 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 (Cvluch is outrageous. BY MR. SCAROLA: Q. How much have you settled claims for? MR. PIKE: I'm going to instruct you not to answer that question. MR. SCAROLA: And the basis of that instruction is? MR. PIKE: Confidential settlement agreements, to the extent that they exist. And the terms would be confidential. BY MR. SCAROLA: Q. Have you settled claims? A. Yes, I have. Q. What is the nature of claims you settled? MR. PIKE: I'm got instruct you not to answer that qu BY MR. SCAROLA: Q. How many claims have you settled? MR. PIKE: I'm going to instruct you not to answer that question as well. MR. SCAROLA: What is the basis for those unctions? MR. PIKE: Confidential, as well as there is a ictim's Right Statute that may — you may be ing into the identity of — 2 every one of your questions here today, I'd like to answer each and 1 THE WITNESS: 3 Mr. Scarola; however, on advice of Co 4 I'm going to have to assert my Fifth, Sixdread 5 14th Amendment Right. 6 BY MR. SCAROLA: 7 Q. (Your Complaint in this action allegesChat 8 (L.M. made claims for damages out of proportion they 9 (alleged damages. What does diet mean?) 10 A. It means what it says. 11 Q. I don't understand it. Explain it to me. 12 MR. PIKE: To the extent you can answer that 13 question without disclosing my conversations with 14 you or Mr. Clifton's conversations with you, as 15 wekes_rnyxvork product, you can answer the 16 questita. 17 (THE' WITNESS: I believe that as part of th7 18 (Tcheme to defraud investors in South Florida out oft 19 (millions of dollars, claims of outrageous sums of) 20 (money were made on behalf of alleged victims across) 21 (the board. And the only way — in fact, ScottO 22 (Rothstein sits in jail. And what I've read in the) 23 (paper, claims that I've settled cases 6) 24 (P00-million, which is totally not true 25 (She has made claims of serious sum of money) 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: I'm not tiptoeing anywhere. MR. PIKE: Let me finish my objection, Mr. Scarola. You may be tiptoeing into the identity of various alleged victims underneath the Victims Right Statute, as well as ongoing investigations or past investigations that have remained open with the State, as well as the Federal Government. So in that regard, we would have to put the State Attorney, as well as the Federal Government on notice that you were seeking to potentially back door certain identities at this deposition. BY MR. SCAROLA: Q. Other than having alleOysien different testimony before she met Mr. then given after she met Mr. M, did L.M. do anything else that forms the basis for your claim against her? MR. PIKE: Form. Asked and answered. THE WITNESS: rd like to answer that question, as well as every one of your questions with respect to L.M. here today; however, on advice of Counsel, at least today, Mr. Scarola, I'm going to have to assert my Sixth Amendment, Fifth Amendment and 14th Amendment Right. BY MR. SCAROLA: 1 Q. Did L.M. fail to do anything that she had an\ 2 obligation, duty or responsibility to do -- 3 MR. PIKE: Form. 4 BY MR. SCAROLA: 5 Q. -- that forms the basis for your claim against\ 6 her? 7 MR. PIKE: I apologize. Form. 8 THE WITNESS: Again? I'm sorry. Has she\ 9 failed to do? Can you repeat? 10 BY MR. SCAROLA: 11 Q. Yes, sir. Lawsuits are generally based, civil\ 12 lawsuits are generally based on a claim that someone has\ 13 done something that they shouldn't have done or failed\ 14 to do something that they should have done. 15 I asked you whether L.M. did anything that she\ 16 shouldn't have done and you asserted a Fifth Amendment\ 17 privilege in refusing to answer that question. 18 I'm now attempting to find out whether L.M.\ 19 failed to do something that she should have done that\ 20 forms the basis of your claims against her. 21 Did L.M. do anything that she should have done\ 22 that forms the basis of your claims against her? 23 MR. PIKE: Form. 24 THE WITNESS: On advice of Counsel, at least\ 25 today, Mr. Scarola, I'm going to have to refuse to 1 answer that question based on my Fifth Amendment,\ 2 Sixth Amendment and 14th Amendment Right. 3 BY MR. SCAROLA: 4 Q. (Did Brad Edwards do anything that he shouldn't\ 5 (have done that forms the basis of your lawsuit against\ 6 [REDACTED]?) 7 MR. PIKE: Form. 8 (THE WITNESS: Yes, many things.) 9 BY MR. SCAROLA: 10 Q. (List them for me, please.) 11 (A. He has -- he has gone to the media out of, I\ 12 (believe, in an attempt to gin up these allegations. He\ 13 (has contacted the media. He has used the media for his\ 14 (own purposes. He has brought discovery -- he has\ 15 (engaged in discovery proceedings that bear no\ 16 (relationship to any case filed against me by any of his\ 17 (clients.) 18 (His firm, which he's the partner of, has been\ 19 (accused of forging a Federal Judge's signature.) 20 Q. I want to know what Mr. [REDACTED] -- 21 MR. PIKE: One second. 22 THE WITNESS: Excuse me. I'm answering. 23 BY MR. SCAROLA: 24 Q. I want to know what Mr. [REDACTED] did. I'm not\ 25 asking you about allegations concerning his law firm. 1 MR. PIKE: Mr. Scarola, that's the second time\ 2 that I'm going to ask you not to interrupt the\ 3 witness when he's giving a response. He is giving\ 4 a response. When he finishes his response, you can\ 5 go on with your next question or you can -- you can\ 6 elicit any sort of information you intend to elicit\ 7 from the witness. 8 MR. SCAROLA: He's being unresponsive. 9 MR. PIKE: No, that's your contention. 10 MR. SCAROLA: No, that's a fact. 11 MR. PIKE: And you can take it up with a\ 12 Judge. And if we want to continue going back and\ 13 forth and bantering, not allowing the witness to\ 14 answer the question -- we're here for you today,\ 15 for you to ask the questions and for you to get\ 16 answers. But if you continue to banter with the\ 17 witness and interrupt the witness, I will adjourn\ 18 the deposition. This is not proper and we\ 19 certainly can take it up with the Judge. So that's\ 20 the second warning, Mr. Scarola. Please -- 21 MR. SCAROLA: How many do I get? 22 MR. PIKE: I'm not sure yet today. 23 MR. SCAROLA: Okay. 24 MR. PIKE: Okay? 25 MR. SCAROLA: Good. Then let's move on. 1 MR. PIKE: But I can tell you one thing: On a\ 2 professional nature, just because you are\ 3 interrupting the witness and bantering with me, I\ 4 will adjourn the deposition. 5 BY MR. SCAROLA: 6 (Q. Besides having gone to the media in an attempt\ 7 (to, quote, gin up, unquote, these allegations and\ 8 (engaged in what you contend to [REDACTED] vant discovery,\ 9 (proceedings, what else did Mr. [REDACTED] personally, do\ 10 (that forms the basis for this lawsuit?) 11 (A. Mr. [REDACTED] personally, engaged with his\ 12 (partners, Scott Rothstein, who sits in a Federal jail\ 13 (cell, potentially for the rest of his life, he shared\ 14 (information, what I've been told and -- excuse me --\ 15 (what I've read in the newspapers, 13 boxes of)\ 16 (information that had my name on it, with other attorneys\ 17 (at his firm.) 18 (He counseled his clients to maintain a\ 19 (position alleging multi-million dollar damages in order\ 20 (for them to scam local investors out of millions of\ 21 (dollars.) 22 (He and his -- many of his other partners)\ 23 (already under investigation by the FBI and the U.S.)\ 24 (Attorney have been accused by the U.S. Attorney of)\ 25 (running a criminal enterprise.) 1 Q. (Anything else?)\ 2 MR. PIKE: Form.\ 3 THE WITNESS: (Not I can think of at the\ 4 (moment)\ 5 BY MR. SCAROLA: 6 Q. (Okay. What media did Mr. Edwards go to?)\ 7 (A. I am aware of at least the Daily News in New\ 8 (York City) 9 (I have been told by other people that there\ 10 were other media, local media) 11 (I've been told that the -- his investigator\ 12 was sent to California to harass people representing\ 13 (his -- Brad Edwards' investigator -- representing\ 14 fictitiously, fraudulently that he was a FBI agent to\ 15 try to gather information for Mr. [REDACTED] claims) 16 Q. Does that have something to do with going to\ 17 the media? 18 MR. PIKE: Form.\ 19 THE WITNESS: I've answered your question.\ 20 BY MR. SCAROLA: 21 Q. Does the investigator going to California to\ 22 do something have something to do with the media? 23 A. I believe I've also told that you that he's\ 24 gone to the Daily News, sir; is that correct? 25 MR. PIKE: Form. Mischaracterizes the 1 witness' testimony as well.\ 2 BY MR. SCAROLA: 3 Q. Do you understand the question that you're\ 4 supposed to be answering? 5 MR. PIKE: Well, let's go ahead and repeat it. 6 MR. SCAROLA: No, let's get an -- let's get an\ 7 answer to that question. 8 BY MR. SCAROLA:\ 9 Q. Do you understand the question you're supposed\ 10 to be answering? 11 A. When --\ 12 MR. PIKE: I'm confused. Wait one second. 13 THE WITNESS: Sorry.\ 14 MR. PIKE: I'm confused as to what question is\ 15 on the table. 16 MR. SCAROLA: And when your deposition is\ 17 being taken, your confusion is relevant and\ 18 material. 19 MR. PIKE: Right. And it's --\ 20 MR. SCAROLA: When Mr. [REDACTED] -- excuse\ 21 me -- when Mr. Epstein's deposition is being taken, 22 I'm concerned with whether he understands the\ 23 question being asked. 24 MR. PIKE: Right. So...\ 25 BY MR. SCAROLA: 1 Q. Do you understand the question you're supposed\ 2 to be answering, Mr. Epstein? 3 MR. PIKE: And I'm going to instruct you not\ 4 to answer that question right now because as your\ 5 Counsel I cannot let you answer that question until\ 6 I understand what question is on the table. 7 There's been a lot of bantering back and\ 8 forth, so, Mr. Scarola, if you would respectfully\ 9 repeat the question and then you may be able to ask\ 10 him whether or not he understands the question.\ 11 But I cannot allow him to answer a question that I\ 12 don't understand is on the table. 13 BY MR. SCAROLA:\ 14 (Q. (What does an investigator going to California\ 15 have to do with Mr. [REDACTED] allegedly going to the media\ 16 (in an attempt to, quote, gin up, unquote, these\ 17 allegations?)\ 18 MR. PIKE: Please answer the question.)\ 19 (THE WITNESS: Good. It's part of Mr. Edwards'\ 20 scheme to involve people who have nothing to do\ 21 with any of his cases in order to, in fact, go back\ 22 to the media and gin up his stories and make false\ 23 allegations of people that have sexually charged\ 24 nature cases in order to attempt to fleece\ 25 investors, local investors out of millions of 1 (dollars)\ 2 (His firm has been accused by the U.S. Attorney\ 3 (of manipulating the media, by hiring investigators)\ 4 (by illegal wire taps, by illegal methods of\ 5 (eavesdropping in order to go to the media and\ 6 (generate cases))\ 7 (BY MR. SCAROLA:) 8 (Q. (When did Mr. [REDACTED] go to the Daily News?)\ 9 (A. I don't know))\ 10 (Q. (How did he go to the Daily News?)\ 11 (A. I don't know))\ 12 (Q. What did he say to the Daily News?)\ 13 (A. I believe Mr. Edwards knows that. I don't\ 14 (know exactly what he said))\ 15 (Q. What is the source of your information that he\ 16 went to the Daily News at all, ever?) 17 MR. PIKE: To the extent you can answer that\ 18 question without violating any attorney/client\ 19 privileges, you can answer the questions.\ 20 (THE WITNESS: It's attorney/client)\ 21 (BY MR. SCAROLA:) 22 (Q. You said you were told by other people that he\ 23 went to other media representatives?)\ 24 (A. Yes, sir)\ 25 (Q. Who are the other people that told you that?) 1 A. 'I don't recall at the moment.\ 2 Q. 'What did these other people who you don't\ 3 remember tell you Mr. [REDACTED] did with respect to other\ 4 media representatives besides the Daily News?\ 5 A. 'Again, the question again?\ 6 Q. 'What did these other people tell you\ 7 Mr. Edwards did with respect to going to other media?\ 8 MR. PIKE: Form.\ 9 THE WITNESS: 'Mr. Edwards went to the media to\ 10 gin up his cases in order that the Rothstein firm\ 11 could generate profits, falsely taking in\ 12 investors, creating false stories to the local\ 13 medias and making statements to local press\ 14 regarding false claims made by his clients in order\ 15 that Scott Rothstein, who currently sits in jail,\ 16 could defraud, along with his other partners of his\ 17 firm, local Florida investors, Mr. Scarola, out of\ 18 millions of dollars.\ 19 BY MR. SCAROLA:\ 20 Q. 'When did these other people whose identity you\ 21 can't remember tell you these things that Brad [REDACTED]\ 22 did?\ 23 A. 'Sometime in the past year.\ 24 Q. 'How many other people were there who told you\ 25 these things about Mr. Edwards? 1 themselves or were these anonymous callers?\ 2 MR. PIKE: Form.\ 3 THE WITNESS: Sitting here today, Mr. Scarola,\ 4 I don't recall with specificity.\ 5 BY MR. SCAROLA:\ 6 Q. 'What specifically did Mr. Edwards allegedly\ 7 communicate to the Daily News to, quote, gin up these\ 8 allegations, unquote?\ 9 A. 'The newspapers have quoted Mr. [REDACTED] -- not\ 10 quoted Mr. -- newspapers have made allegations referred\ 11 to as Mr. [REDACTED] statements.\ 12 MR. SCAROLA: Would you read the question\ 13 back, please, Sandy?\ 14 (Pending question was read.)\ 15 MR. PIKE: Did he answer your question?\ 16 MR. SCAROLA: No.\ 17 MR. PIKE: Are you asking him again?\ 18 THE WITNESS: So you're asking the question\ 19 again?\ 20 BY MR. SCAROLA:\ 21 Q. Yes.\ 22 THE WITNESS: Sorry. Could you repeat the\ 23 question again?\ 24 (Pending question was read.)\ 25 THE WITNESS: He alleged that third parties 1 A. 'I don't recall with specificity,\ 2 Q. 'Well, do you recall in any degree how many\ 3 there were?\ 4 A. 'I would say, probably five to ten.\ 5 Q. 'Where were you when these conversations took\ 6 place that you can't -- the identity of whose\ 7 participants you can't remember?\ 8 MR. PIKE: 'So we're clear, within the last\ 9 year, -- correct? -- timewise?\ 10 MR. SCAROLA: 'Well, that's what your client\ 11 said. 'I don't believe a word he says, but that's\ 12 what he said:\ 13 MR. PIKE: Form. Objection. Overbroad.\ 14 THE WITNESS: 'Again, sir?\ 15 BY MR. SCAROLA:\ 16 Q. 'Yes, sir. Where did these conversations with\ 17 these five to ten people take place whose identity you\ 18 can't remember?\ 19 MR. PIKE: Form.\ 20 THE WITNESS: (On the telephone)\ 21 BY MR. SCAROLA:\ 22 Q. 'Who initiated the phone calls?\ 23 A. 'Sir, these questions, I have no -- I don't\ 24 have any recollection.\ 25 Q. (Did the people who were on the phone identify) 1 (had already been involved in some allegations to do\ 2 with sexual misconduct)\ 3 BY MR. SCAROLA:\ 4 Q. Which third parties?\ 5 A. 'I don't recall sitting here today.\ 6 Q. (Involved how?\ 7 MR. PIKE: Form.\ 8 THE WITNESS: If I recall with specificity, if\ 9 I had the articles in front of me, I would be able\ 10 to recall. Maybe next time)\ 11 BY MR. SCAROLA:\ 12 Q. (What does "gin up these allegations" mean?\ 13 MR. PIKE: Form.\ 14 THE WITNESS: It means craft allegations of\ 15 multi-million dollar cases; in fact, alleging in\ 16 (L.M.'s case damages of \$50-million, settlements in\ 17 order for Scott Rothstein and the rest of)\ 18 (Mr. Edwards' partners to fleece unsuspecting\ 19 (investors out of millions and millions of dollars\ 20 (based on cases that didn't exist or alleged cases\ 21 (that I had settled)\ 22 Can I take a break?\ 23 VIDEOGRAPHER: Going off video record, 10:50.\ 24 (Brief recess.)\ 25 VIDEOGRAPHER: We're now on video record at 1 10:57 a.m.\ 2 BY MR. SCAROLA:\ 3 (Q. (Was your reference to, quote, gin up these\ 4 allegations, unquote, a reference to allegations made\ 5 against you?\ 6 MR. PIKE: Form. 7 (THE WITNESS: As part of the vast conspiracy\ 8 of the Rothstein firm and Mr. Edwards'\ 9 participation in it, it has been alleged that many\ 10 cases were fraudulently brought -- alleged that\ 11 (have been brought; ginned up, meaning, crafted;\ 12 multi-million dollar numbers put on cases in order\ 13 to fleece investors, where his partner, Scott\ 14 Rothstein, currently sits in jail for just those\ 15 purposes, Mr. Scarola. 16 BY MR. SCAROLA:\ 17 Q. (My question to you is: Did the reference to\ 18 quote, gin up these allegations refer to allegations\ 19 against you?\ 20 A. (Reported in the newspaper the answer is, yes.\ 21 (And others, but specifically me, yes, by the newspaper\ 22 reports) 23 Q. Specifically what are the allegations against\ 24 you which you contend Mr. [REDACTED] ginned up?\ 25 A. I would like to answer that question. A, many 1 Q. I want to know whether when you use the phrase\ 2 "gin up" and the word "crafted," which you have told us\ 3 is synonymous with gin up, -- 4 A. Yes. 5 Q. -- you mean fabricated? 6 A. I'm sorry. On advice of Counsel, sir, and\ 7 I've answered that question before, but if you didn't\ 8 hear me the first time, I must assert my Fifth, Sixth\ 9 and 14th Amendment Right. 10 Q. (What specific discovery proceedings did\ 11 Mr. [REDACTED] engage in which you contend form the basis\ 12 for your lawsuit? 13 (A. The discovery proceedings of bringing my\ 14 attorneys to various people that had nothing to do with\ 15 any of his clients or these lawsuits) 16 Q. Which various people? Who?\ 17 MR. PIKE: Form. 18 (THE WITNESS: For example, he tried to depose\ 19 (Bill Clinton, strictly as a means of getting\ 20 (publicity so that he and his firm could\ 21 (fraudulently steal, craft money from unsuspecting\ 22 (investors in South Florida out of millions of\ 23 (dollars)\ 24 BY MR. SCAROLA:\ 25 Q. Who else besides Bill Clinton is included in 1 of the files and documents that we've requested from\ 2 Mr. [REDACTED] and the Rothstein firm are still\ 3 unavailable. 4 With respect to anything that I can point to\ 5 today, I'm, unfortunately, going to have to take the\ 6 Fifth Amendment on that, Sixth and 14th. 7 Q. You seemed to be defining ginned up as\ 8 crafted; is that correct? 9 A. That's correct. 10 Q. Does ginned up or crafted mean fabricated?\ 11 MR. PIKE: Form. 12 THE WITNESS: I'm sorry, Mr. Scarola. I\ 13 understand that you are trying to back door your\ 14 way into a waiver of my Fifth Amendment. But\ 15 respect to that question, I'm going to have assert\ 16 my Fifth Amendment, Sixth Amendment and 14th\ 17 Amendment Right. 18 BY MR. SCAROLA:\ 19 Q. So you are asserting your Fifth Amendment,\ 20 Sixth Amendment and 14th Amendment Right to remain\ 21 silent about what you mean when you use the words "gin\ 22 up" and "crafted;" is that correct?\ 23 A. I don't believe that was your question. 24 Q. Yes, sir, that's exactly my question.\ 25 A. Would you repeat the question for me? 1 your reference to various people?\ 2 A. There are people in California. There are\ 3 people in New York. 4 Q. Would you name them for us, please?\ 5 A. I'm sorry. Sitting here today, Mr. Scarola,\ 6 I'm going to have to assert my Fifth Amendment, Sixth\ 7 Amendment and 14th Amendment Right. 8 Q. Let's then talk about Bill Clinton, by whom I\ 9 assume you mean former President Clinton; is that\ 10 correct? 11 A. That's correct.\ 12 Q. All right. Do you know former President\ 13 Clinton personally? 14 A. I'm sorry. As I sit here today, though I'd\ 15 like to answer that question, on advice of my Counsel,\ 16 at least today, I'm going to have to take the Fifth,\ 17 Sixth and 14th Amendment. 18 (Q. You said something about Mr. Edwards sharing\ 19 (13 boxes of information with somebody --\ 20 (A. Yes.\ 21 (Q. -- as forming part of the basis for your\ 22 (lawsuit against Mr. [REDACTED] correct?)\ 23 (A. Correct.\ 24 (Q. All right. With whom did Mr. Edwards share\ 25 (these 13 boxes of information? 1 A. (It has been reported in the Scherer Complaint\ 2 that he shared those boxes with the partners of his firm\ 3 that was then formally accused by the U.S. Attorney,\ 4 sir, of being a criminal enterprise. 5 MR. PIKE: And just for purposes -- 6 BY MR. SCAROLA: 7 (Q. Do you remember my question? 8 (A. You asked me who he shared it with? 9 (Q. Yes. 10 (A. The partners of his firm, sir. 11 (Q. Okay. So part of the basis of your lawsuit is\ 12 that Mr. Edwards allowed members of his own law firm to\ 13 see 13 boxes of information; is that correct? 14 (A. No, that's not correct. My claim is that the\ 15 13 boxes of information that were shown to investors by\ 16 Mr. Edwards' partners, 13 boxes that we've been told by\ 17 the press contain multiple cases, fraudulently -- and if\ 18 you like the word -- fabricated in order to fleece\ 19 investors out of money. The 13 boxes were shared with\ 20 investors, Mr. Edwards, Mr. Edwards' partners and some\ 21 of those partners currently under inditement, the others\ 22 already sitting in jail. 23 Q. I had asked you earlier whether ginned up and\ 24 crafted meant fabricated and you asserted your Fifth\ 25 Amendment privilege. 1 Are you now telling us that there were claims\ 2 against you that were fabricated by Mr. [REDACTED]? 3 A. I'm going to again assert my Fifth, Sixth and\ 4 14th Amendment Right, sir. 5 I would respond that the newspapers are very\ 6 clear that the cases were fabricated. 7 Q. (Which newspaper said which case was\ 8 fabricated? 9 A. (Bob Norman's blog said most of the cases were\ 10 fabricated, to my best recollection. 11 (The Scherer Complaint alleged many fabricated\ 12 cases, sir.) 13 Q. Well, which of Mr. Edwards' cases do you\ 14 contend were fabricated? 15 A. Again, we've requested most of the --\ 16 information from the bankruptcy trustee. We've been\ 17 unable -- Mr. Edwards has not given us the total file,\ 18 but respect to any individual, I would have -- at the\ 19 moment I would have to assert my Fifth, Sixth and 14th\ 20 Amendment claim, sir. 21 Q. So you will not answer questions about whether\ 22 the claim on behalf of L.M. was fabricated; is that\ 23 correct? 24 A. I believe I've already answered that, but, if\ 25 again, I'll have to assert my Fifth, Sixth and 14th 1 Amendment Right, sir. 2 Q. Your Complaint also makes reference to a claim\ 3 on behalf of Jane Doe, referred to as Jane Doe versus\ 4 Epstein, case number 08-CIV-80893, a case pending in the\ 5 United States District Court for the Southern District\ 6 of Florida. 7 Is it your contention that the claim on behalf\ 8 of Jane Doe is a fabricated claim? 9 A. Sir, though I'd like to answer that question,\ 10 as well as every one of your other questions here today,\ 11 today I'm going to have to assert my rights as under the\ 12 Constitution of the Fifth, Sixth and 14th Amendment. 13 Q. Do you know the real name of the person\ 14 referred to as Jane Doe in that case? 15 A. I don't know which -- I'm sorry, sir. I do\ 16 not, sitting here today. 17 Q. Did you ever have personal contact with the\ 18 person referred to by the name Jane Doe in that lawsuit? 19 A. I'm sorry, sir. Sitting here today, I'm going\ 20 to have to assert my Fifth, Sixth and 14th Amendment\ 21 Right. 22 Q. When did you first meet the person referred to\ 23 as Jane Doe? 24 A. Sir, though I'd like to answer each and every\ 25 one of your questions here today, at least with respect 1 to that question, I'm going to have to assert my rights\ 2 under the Sixth Amendment, 14th Amendment and Fifth\ 3 Amendment. 4 Q. Where did you first meet the person referred\ 5 to as Jane Doe? 6 A. Sir, though I'd like to answer that question\ 7 here today, at least today on advice of Counsel, I'm\ 8 going to have to assert my Fifth Amendment, Sixth\ 9 Amendment and 14th Amendment Right. 10 Q. How many times have you been in the physical\ 11 presence of the person referred to as Jane Doe? 12 A. The person referred to as Jane Doe? 13 Q. Yeah. How many times have you been in her\ 14 physical presence? 15 MR. PIKE: Form. 16 THE WITNESS: At least -- at least sitting\ 17 here today, Mr. Scarola, I'm going to have to\ 18 assert my Fifth Amendment, Sixth Amendment and 14th\ 19 Amendment Right. 20 BY MR. SCAROLA: 21 Q. Did you ever have any physical contact with\ 22 Jane Doe? 23 MR. PIKE: Form. 24 THE WITNESS: Now, for this purposes, you're\ 25 assuming this Jane Doe is somebody I know? I don't 1 Q. Would your answer be the same with regard to 2 L.M. and to Jane Doe? 3 MR. PIKE: I'm going to instruct you if your 4 answer is the same, to invoke in hill. 5 THE WITNESS: With respect to, I believe, Jane 6 Doe — and who is the other person? I'm sorry. 7 BY MR. SCAROLA: 8 Q. L.M. 9 A. L.M. Though I'd like to answer claims 10 with respect to all three of Mr. clients, on 11 advice of Counsel, at least today, Fm going to have to 12 invoke my Fifth, Sixth and 14th Amendment Rights. 13 Though I'd prefer to answer the question, Fve been told 14 that if I choose to do so, I risk losing their 15 icpiwentation. 16 Q. Among those items listed by you as wrongdoing 17 on the part of Mr. forming the basis for this 18 lawsuit is that he, quote, counseled his clients to make 19 multi-million dollar claims against you; is that 20 correct? 21 MR. PIKE: Form. Document speaks for itself. 22 THE WITNESS: Document speaks for itself. 23 BY MR. SCAROLA: 24 Q. I'm not asking about a document. I'm asking 25 you about the list of wrongdoing that you gave us during 1 the course of this deposition, which you allege form t 2 basis for your claim against Mr. 3 Is contention that among those 4 Mr. did that form the basis for youj 5 to have counseled his clients to make m 6 dollar claims against you? 7 MR. PIKE: Form. 8 THE WITNESS: What the n have said is 9 that the claims purported to have been made by the 10 Rothstein firm and its partners;allege 11 multi-million dollar claims where no claims exist. 12 However, respect specifically to my claim 13 today, I'm going to have assert my Fifth, Sixth and 14 14th Amendment Right. 15 MR. PIKE: Aiso, the question mischaracterizes 16 the witness' testimony. 17 BY MR. SCAROLA: 18 Q. By whom was employed when he 19 initiated litigation against you? 20 A. I would like to know the answer to that 21 question. 22 Q. So the answer to that question is, I don't 23 know? 24 A. I would like -- 25 Q. Correct? A. No. I answered that question, which is, I'd like to know. Q. Yes. But that isn't an answer to m iti.usfion. My question is: By whom was Mr. employed at the time that he initiated litigation against you? Do you know the answer to that question? A. Pd have no way of knowing the answer to that question, sir. C wliieh you contendion'rithibrsiraf this . Among the allegations of wrongdoing against laysuif irnelliinht7/ingtrdoWithending (investigator to California: (Wouldu yo retell please, more specifically (what it is thaCM%Eilwarcls d1 withnThrardrisendirTa (Friuwestigator to California which you contend araifieTzTleralllainWafilifWEdivardii MR. PIKE: Form. And also mischaracterizes the witness' testimony. WITNESS-Reported widelyin the (newspapers is the use of illegal activities, wire taps and methods by the Rotluiein firm while NinITtclinrstiPti=irT/ITFisten, whO's mentiagd the Complaint, represented himself as 'S - Page 49 agent, falsely represented himself as an FBI (BY.MR7SCAROIN: 3\[Q. Do you have any personal knowledge of anythiiii 4 adtitili"."FiiiErdiarvIiiielli."Fistrvasin California?, 5 MR. PIKE: To the extent that you can answer 6 that question without disclosing my conversation or 7 my firm's conversation or any of your attorneys' conversations with you, you can answer the 9 question. 10 (TREWITNESS7FriWBased7ciii 11 rnatto ey/client privilege, I can't —ansrei) 12 BY MR. SCAROLA: 13 Q. (Lilt your contention that Mr 4Edwirdsras 14 (in—Crolild.in—ri nilleTaltvire—tapy — j 15 A. It was widely reported in the newspape 16 (9., I'm not asking it was reported? 17 (S Excuse 18 G.). — in the newspapir. 19 (A. Excus ne. 20 (071 . want to know whether your contention is that 21 (MrEilv7gdras iirrols7rfirrariillerml7virrap.,, 22 MR. PIKE: Try once spin to answer that 23 question. 24 (THEVITNESSF-Ifiberwiaelyreporteciirta 25 newspaper that his firm and his partners were. 1 (involved in illegal wire taps, eavesdropping, hired\ 2 (former FBI and law enforcement officials in order\ 3 (to fabricate cases of a sexually charged nature\ 4 (against me and others)\ 5 (BY MR. SCAROLA:\ 6 (Q. (Do you have any personal knowledge of\ 7 (Mr. Edwards ever having engaged in any illegal wire tap?\ 8 (A. I have no personal knowledge; however, what I\ 9 (read in the newspapers and is widely reported is that\ 10 (his firm, and I believe Mr. Sakowitz went to the FBI\ 11 (after he was told that the firm was engaged in illegal\ 12 (wire taps and his partners were engaged in illegal wire\ 13 (taps)\ 14 (The FBI, the U.S. Attorney has accused his\ 15 (firm of RICO, being the largest criminal fraud\ 16 (enterprise in South Florida's history and engaged in\ 17 (illegal wire taps. But the answer specifically to your\ 18 (question about personal knowledge, sir, no)\ 19 (Q. Do you have any personal knowledge of\ 20 (Mr. [REDACTED] ever having been involved in any illegal or\ 21 (improper eavesdropping?)\ 22 (A. (It's been widely reported in the newspapers in\ 23 (South Florida that Mr. Edwards' firm, his partners were\ 24 (involved in illegal wire taps, illegal fact gathering)\ 25 (using what the newspapers quoted as sophisticated) 1 (methods. Mr. Sakowitz, who was approached as an\ 2 (investor, and Mr. Scherer, who's filed a Complaint)\ 3 (alleges similar activities. But personal knowledge\ 4 (myself, sir, no)\ 5 (Q. Do you have any personal knowledge that\ 6 ([REDACTED] was ever involved in obstructions of\ 7 (justice?)\ 8 (MR. PIKE: To the extent that you can answer\ 9 (that question without disclosing any\ 10 (attorney/client communications with any of your\ 11 (attorneys, you can answer that question.)\ 12 (THE WITNESS: It's attorney/client privilege)\ 13 (I'm afraid)\ 14 (BY MR. SCAROLA:\ 15 (Q. Do you have any personal knowledge that\ 16 (Bradley Edwards was ever involved in any actionable\ 17 (frauds?)\ 18 (MR. PIKE: Same -- same instruction, with any\ 19 (of your lawyers.)\ 20 (THE WITNESS: Yes. (Outside of the newspapers,\ 21 (which have accused his firm of a monstrous fraud)\ 22 (purported to be the largest fraud in South\ 23 (Florida's history, accused by the U.S. Attorney)\ 24 (where his partner sits in jail -- excuse me --)\ 25 (reported in the newspapers of boxes of material on) 1 (Jeffrey Epstein, separate and apart from the\ 2 (allegations of fraud by his partners, I cannot\ 3 (answer that question because of attorney/client\ 4 (privilege)\ 5 (BY MR. SCAROLA:\ 6 (Q. Do you have any personal knowledge that\ 7 ([REDACTED] was involved in any egregious civil\ 8 (litigation abuses?)\ 9 (MR. PIKE: Form. Confusing.)\ 10 (THE WITNESS: It's widely reported in the\ 11 (newspaper that Mr. [REDACTED] firm engaged in\ 12 (discovery processes, illegal activities, illegal\ 13 (eavesdropping in order to fleece unsuspecting\ 14 (investors in South Florida out of millions in\ 15 (dollars by crafting, fabricating malicious cases of\ 16 (a sexually charged nature in order to perpetrate a\ 17 (fraud.)\ 18 (BY MR. SCAROLA:\ 19 (Q. (Do you have any personal knowledge that\ 20 ([REDACTED] ever forged Federal Court Orders and/or\ 21 (Opinions?)\ 22 (A. It's attorney/client privilege.)\ 23 (Q. Do you have any personal knowledge that\ 24 ([REDACTED] was ever involved in the marketing of\ 25 (non-existing Epstein settlements?) 1 (MR. PIKE: Same instruction.)\ 2 (THE WITNESS: I'm sorry) (I would like to\ 3 (answer that question, but on attorney/client\ 4 (privilege I cannot today)\ 5 (BY MR. SCAROLA:\ 6 (Q. (It is alleged in your Complaint that you were\ 7 (subject to, quote, abusive investigatory tactics)\ 8 (Other than those matters previously referred\ 9 (to in earlier questions, is it your contention that\ 10 (Bradley Edwards had any personal involvement in any\ 11 (other, quote, abusive investigatory tactics?)\ 12 (MR. PIKE: Form.)\ 13 (THE WITNESS: It's been widely reported in the\ 14 (newspapers that Mr. Edwards' firm was engaged in\ 15 (widely -- wildly abusive practices throughout the\ 16 (State of Florida in order to fleece unsuspecting\ 17 (investors out of millions of dollars)\ 18 (The U.S. Attorney's Complaint alleges his firm\ 19 (engaged in a corrupt criminal enterprise)\ 20 (Mr. Scherer's Complaint alleges monstrous\ 21 (amounts of fraud and discovery abuse)\ 22 (I have no personal knowledge, separate from\ 23 (the attorney/client privileged information,\ 24 (regarding Mr. Edwards)\ 25 (BY MR. SCAROLA: 1 (Q. \[Do you have any personal knowledge that\ 2 Bradley [REDACTED] ever filed legal papers that were\ 3 unsupportable? 4 MR. PIKE: I'm going to object to form.\ 5 And to the extent you can answer that question\ 6 without disclosing any attorney/client\ 7 communications with any of your attorneys, I'm\ 8 going to allow you to answer that question. 9 THE WITNESS: I'm afraid it's attorney/client\ 10 privilege. 11 BY MR. SCAROLA: 12 Q. Do you have any personal knowledge that\ 13 Mr. [REDACTED] was ever involved in any conduct that,\ 14 quote, compromised the core values of both State and\ 15 Federal justice systems in South Florida? 16 MR. PIKE: Form. 17 (THE WITNESS: Can you just ask -- can you\ 18 define for me what you mean by "personal\ 19 knowledge," sir? 20 (BY MR. SCAROLA: 21 (Q. (Yes. Did you ever see, hear, smell, taste, or\ 22 touch anything that communicated to you directly and not\ 23 through the report of some third person or newspaper\ 24 that Bradley [REDACTED] was personally involved in\ 25 compromising the core values of both State and Federal 1 (justice systems in South Florida? 2 (MR. PIKE: Form) 3 (Same instruction with regard to\ 4 attorney/client) 5 (THE WITNESS: Yes. Are you suggesting that\ 6 anyone who told me specifically or things that I\ 7 might have read that specifically relate to him, is\ 8 not what you've been asking me for? 9 (BY MR. SCAROLA: 10 (Q. (Yes, sir, that's exactly right) 11 (A. You told me if I hear something, that's not\ 12 personal knowledge) 13 (Q. (Not if you hear it from somebody else) 14 (A. (Who else would I hear it from, besides\ 15 somebody else, sir?) 16 (Q. (Well, if you heard it directly yourself) 17 (A. From who?) 18 (Q. (Maybe Mr. Edwards) 19 (A. Uh-huh. Is that the only person, sir?) 20 (Q. (That's the only person, that's correct) 21 (A. Well, if it's the only person, separate from\ 22 attorney/client privilege, I cannot answer that) 23 Q. Your Complaint makes reference to a purpose in\ 24 filing this lawsuit to, quote, "vindicate the\ 25 hardworking and honest lawyers and their clients who 1 were adversely affected by the misconduct that is the\ 2 subject of this Complaint," unquote. 3 Who are those hardworking and honest lawyers\ 4 that you are seeking to vindicate? 5 MR. PIKE: Form. 6 Give me a minute. What page of the Complaint\ 7 are you referring to? 8 MR. SCAROLA: Page 2. 9 MR. PIKE: Give me one second. 10 THE WITNESS: Can we go off the record just\ 11 for a second? 12 MR. PIKE: If it's okay with Mr. -- 13 THE WITNESS: It's a bathroom break. 14 MR. PIKE: There's a question pending and\ 15 usually -- 16 THE WITNESS: Sorry. 17 MR. PIKE: Just give me a second.\ 18 Okay. 19 THE WITNESS: Where is it? 20 MR. PIKE: It's page 2 of the Complaint, which\ 21 has my notes on it down here, the last sentence. 22 And to the extent that you have knowledge and\ 23 can answer that question, you can do so. 24 THE WITNESS: Could you repeat the question\ 25 for me, sir? 1 BY MR. SCAROLA: 2 Q. Yes, sir. (Your Complaint makes reference to a\ 3 purpose in filing this lawsuit -- 4 (A. Yes) 5 (Q. -- to vindicate the hardworking and honest\ 6 lawyers and their clients who were adversely affected by\ 7 the misconduct that is the subject of this Complaint) 8 (A. Yes, sir) 9 (Q. (Who are those hardworking and honest lawyers\ 10 on whose behalf you are bringing this Complaint?) 11 MR. PIKE: Okay. Form. Mischaracterizes the\ 12 Complaint itself. 13 To the extent you understand that question,\ 14 you can attempt to answer, if you recall. 15 (THE WITNESS: Yes) 16 (The U.S. Attorney, sir, has accused the\ 17 Rothstein firm of misusing the entire legal system,\ 18 a level of abuse never seen before in the United\ 19 States history, of forging documents, an affront to\ 20 any decent lawyer, signing Judge's Orders, sending\ 21 false statements to other lawyers. The people who\ 22 have been -- excuse me -- the Complaint by the U.S.\ 23 (Attorney, in fact, describes the behavior of the\ 24 law firm, as well as Mr. -- my Complaint says)\ 25 (Mr. [REDACTED] being a part of that) 1 BY MR. SCAROLA:\ 2 Q. Now, before you answered that question, you\ 3 reviewed a document, right? 4 A. The Complaint, sir.\ 5 Q. I'd like to see it, please. 6 MR. PIKE: Definitely not, Mr. Scarola.\ 7 My notes are on that and that's\ 8 attorney/client. I allowed the witness to take a\ 9 look at the document and he did not write anything\ 10 on the document. He looked at the document.\ 11 That's my client. And you will certainly not be\ 12 looking at my notes, which are all over this\ 13 document. 14 MR. SCAROLA: He didn't look at everything.\ 15 He looked at one page. I would like that one page,\ 16 please. 17 MR. PIKE: Absolutely not, Mr. Scarola.\ 18 MR. SCAROLA: I would like that page marked as\ 19 an Exhibit to this deposition. 20 MR. PIKE: Absolutely not, Mr. Scarola. 21 MR. SCAROLA: I would state for the record\ 22 that it is my intention, since that page with\ 23 handwritten notations on it was reviewed by the\ 24 witness during the course of this deposition while\ 25 a question was pending, I want that page preserved 1 so that the Court can make a determination as to\ 2 whether I am entitled to see it. 3 MR. PIKE: I would object based upon\ 4 attorney/client and work product in that regard. 5 THE WITNESS: Now can we take a bathroom\ 6 break? 7 MR. SCAROLA: No, sir, because you still\ 8 haven't answered my question. 9 THE WITNESS: Okay.\ 10 BY MR. SCAROLA: 11 (Q. 'I want to know who the quote, "hardworking\ 12 and honest lawyers" are that are referred to in that\ 13 section of your Complaint: 14 (A: My attorneys, at least, are honest: 15 (Q. Which ones? 16 (A: All of them: 17 (Q. And you say that you want to vindicate the\ 18 hardworking and honest lawyers and their clients? 19 (A: That's correct: 20 (Q. Which clients? 21 (A: Me, some of the other clients; in fact, abused\ 22 by the Rothstein firm. I don't know the full extent;\ 23 Hopefully when we get to trial, we're going to find out\ 24 the extent of the people, the lawyers, the clients that\ 25 were abused by Mr. Edwards and the Rothstein firm: 1 We have asked for Scott Rothstein's\ 2 deposition. We hopefully will get it. Maybe he will\ 3 give us some insight on how other lawyers have, in fact,\ 4 been handled and the abuses they've undergone, including\ 5 forging a Federal Judge's signature, sir. 6 Q. Now, was it your intention in this sentence to\ 7 say that you were trying to vindicate the hardworking\ 8 and honest lawyers and their clients? 9 A. It's attorney/client. I'm sorry. 10 Q. Your intention is attorney/client privileged? 11 MR. PIKE: Form. I'm not quite -- 12 BY MR. SCAROLA: 13 Q. Is that what you're telling us? 14 MR. PIKE: Wait a second. I'm not quite sure\ 15 I understand the question. 16 THE WITNESS: What's the question? 17 BY MR. SCAROLA: 18 Q. Were you attempting to communicate in this\ 19 Complaint a desire on your part to vindicate hardworking\ 20 and honest lawyers and their clients? 21 MR. PIKE: Form. 22 THE WITNESS: In this Complaint, I intend to\ 23 get to the truth of Mr. [REDACTED] behavior and the\ 24 Rothstein firm, sir. 25 BY MR. SCAROLA: 1 Q. Well, what this sentence says is, quote, -- 2 A. Yes. 3 Q. -- "the Rothstein racketeering enterprise\ 4 endeavored to compromise the core values of both State\ 5 and Federal systems in South Florida and to vindicate\ 6 the hardworking and honest lawyers and their clients who\ 7 were adversely affected by the misconduct that is the\ 8 subject of this Complaint." 9 Is that what you meant to communicate? 10 A. It says what it says, sir. 11 Q. Well, I know it says what it says. I'm trying\ 12 to find out if that's what you meant to say; that is,\ 13 that the Rothstein racketeering enterprise endeavored to\ 14 vindicate the hardworking and honest lawyers and their\ 15 clients who were adversely affected by the misconduct\ 16 that is the subject of this Complaint. 17 MR. PIKE: Form. Mischaracterizes the\ 18 language of the document. 19 THE WITNESS: Yeah, I think you've misread\ 20 that again. You want to -- I certainly didn't ask\ 21 for the Rothstein firm to vindicate the lawyers, is\ 22 what you've just -- 23 BY MR. SCAROLA: 24 Q. Well, that's what I'm trying to find out,\ 25 whether you meant to say what you said in this 1 Complaint. 2 Did you read the Complaint before it was\ 3 filed? 4 MR. PIKE: Form. Move to strike. 5 THE WITNESS: Thank you, sir. 6 BY MR. SCAROLA: 7 Q. Did you read the Complaint before it was\ 8 filed? 9 A. It was a while ago, yes, sir. 10 Q. And did you approve the Complaint prior to its\ 11 filing? 12 A. Yes, sir. 13 Q. (And did you mean to say what this sentence\ 14 says, "the Rothstein racketeering enterprise endeavored\ 15 to vindicate the hardworking and honest lawyers and\ 16 their clients, who were adversely affected by the\ 17 misconduct that is the subject of this Complaint?") 18 (MR. PIKE: (Okay. I'm going to move to strike.\ 19 Mischaracterizes the language of the document. 20 (The document reads as follows, for purposes of\ 21 the record: "The Rothstein racketeering enterprise\ 22 endeavored to compromise the core values of both\ 23 (State and Federal justice systems in South Florida\ 24 and to vindicate the hardworking and honest lawyers\ 25 and their clients who were adversely affected by 1 (the misconduct that is the subject of this\ 2 (Complaint.) 3 BY MR. SCAROLA: 4 Q. (Is that what you meant to say? 5 (A. What I meant to say, it is -- seems to me\ 6 somewhat unclear -- is that the Rothstein firm, along\ 7 with Mr. Edwards, is part of a criminal enterprise, the\ 8 largest -- excuse me -- the largest criminal enterprise\ 9 in South Florida's history, forging Judges' signatures,\ 10 engaging in illegal wire taps, illegal behaviors. And\ 11 part of this lawsuit should vindicate, which means, I\ 12 believe should set right. 13 (And if it's not clear, the Rothstein firm\ 14 compromised the core values of our legal justice system.\ 15 It abused every -- many of the precepts, the most basic\ 16 values of the American justice system. 17 (And, in fact, I believe this lawsuit, part of\ 18 the reason for filing this lawsuit, it will disclose the\ 19 various techniques of attorney/client privilege, abuse\ 20 of technique, abuse of discovery, illegal wire taps,\ 21 forging signatures engaged in by both Mr. [REDACTED] and\ 22 his firm. 23 Q. (So it is your contention that Mr. [REDACTED] was\ 24 part of a criminal enterprise?) 25 A. (Yes, it is) 1 Q. (Knowingly part of a criminal enterprise? 2 MR. PIKE: Form. 3 (THE WITNESS: Attorney/client privilege. 4 MR. SCAROLA: You wanted to take a break and\ 5 before I move on to another subject, we'll do that.\ 6 But I want -- I want to observe for the record that\ 7 the last break was less than an hour ago. While I\ 8 want to try to make reasonable accommodations to\ 9 witnesses so as not to impose unnecessarily upon\ 10 their physical comfort, I will object to breaks\ 11 occurring at less than one-hour intervals during\ 12 the course of this deposition. 13 VIDEOGRAPHER: We're now off video record. It\ 14 is 11:34 a.m. 15 (Brief recess.) 16 VIDEOGRAPHER: We are now back on video\ 17 record. It is 11:45 a.m. and we are on media\ 18 number two. 19 BY MR. SCAROLA: 20 (Q. What knowledge do you have of Bradley [REDACTED]\ 21 ever having personally engaged in mail fraud?) 22 (A. It's been widely reported in the press --) 23 (Q. (I'm going to withdraw my question.) 24 (What personal knowledge do you have of Bradley\ 25 Edwards ever having been engaged in any mail fraud?) 1 A. (Will you describe what you mean by "personal\ 2 knowledge," sir?) 3 (Q. (I mean direct observation through your senses\ 4 on your part.) 5 (A. So are you asking me whether or not I've\ 6 witnessed him sending something directly, putting\ 7 physically in the mail, sir?) 8 (Q. (I'm asking whether you have ever personally\ 9 witnessed [REDACTED] ever having engaged in mail\ 10 fraud.) 11 (A. I'm not sure how that's possible for anybody\ 12 to witness a mail fraud, so would you inform me how it's\ 13 done?) 14 (Q. (So the answer to my question is, you don't\ 15 know; is that correct?) 16 (A. My answer to your question is --) 17 (MR. PIKE: Form. Mischaracterizes the\ 18 witness' testimony.) 19 (THE WITNESS: I've asked for a clarification.) 20 (BY MR. SCAROLA:) 21 (Q. Have you ever personally witnessed Bradley\ 22 Edwards engaging in mail fraud?) 23 MR. PIKE: Form. 24 (THE WITNESS: No, sir.) 25 BY MR. SCAROLA: 1 Q. (Have you ever personally witnessed [REDACTED]\ 2 \[Edward - [REDACTED] engaged in wire fraud?\ 3 (A. How would one -- I'm not sure how anyone would\ 4 personal -- have personal knowledge, witness someone\ 5 engaging in wire fraud, unless they were simply sitting\ 6 over their computer looking at their bank accounts. So,\ 7 unfortunately, I would have to say, no, sir.\ 8 (Q. (Have you ever personally witnessed Bradley\ 9 [REDACTED] engaged in money laundering?\ 10 MR. PIKE: Form.\ 11 (THE WITNESS: Again, sir, the U.S. Attorney's\ 12 (Complaint of the Rothstein firm alleges money\ 13 (laundering, wire fraud, mail fraud, RICO claims of\ 14 (Mr. Edwards' partners and his firm, calling the\ 15 (firm the largest criminal enterprise in South\ 16 (Florida's history, accused of fabricating malicious\ 17 cases, sir, of a sexually charged nature in order\ 18 to fleece unsuspecting South Floridians out of\ 19 (millions of dollars.\ 20 (BY MR. SCAROLA:\ 21 (Q. And I'm trying to find out, Mr. Epstein;\ 22 (whether you have any evidence whatsoever that\ 23 (Mr. [REDACTED] ever personally participated in any of that\ 24 (wrongdoing?\ 25 MR. PIKE: To that question, to the extent you 1 (payout settlement?\ 2 MR. PIKE: Form.\ 3 (THE WITNESS: I'd like to answer that question\ 4 (by saying that the newspapers have reported that\ 5 (his firm was engaged in fraudulent structured\ 6 (settlements in order to fleece unsuspecting Florida\ 7 (investors.\ 8 (With respect to my personal knowledge, I'm\ 9 (unfortunately going to, today, but I look forward\ 10 to at some point being able to disclose it, today\ 11 (I'm going to have to assert the attorney/client\ 12 (privilege.\ 13 (BY MR. SCAROLA:\ 14 (Q. Your Complaint alleges that Rothstein and\ 15 (others in RRA were using RRA to market investments.\ 16 (Who are the others referred to in the\ 17 (Complaint?\ 18 (A) (From my understanding of the U.S. Attorney's\ 19 (Complaint, from Mr. Scherer's Complaint, it is the\ 20 (partners and people who held themselves out to be\ 21 (partners of the Roth -- Scott Rothstein, including\ 22 (Mr. Berger, Mr. Adler, Mr. Edwards and other people\ 23 (associated with the firm like Mr. Fisten, Diane\ 24 [REDACTED] if that's how you pronounce her name,\ 25 (Adler, and many of the other partners of his firm 1 can answer it without violating attorney/client and\ 2 work product, you can answer the question.\ 3 (THE WITNESS: I'm afraid it will be\ 4 (attorney/client privilege, sir.\ 5 (BY MR. SCAROLA:\ 6 (Q. Do you have any evidence -- knowledge of any\ 7 (evidence whatsoever that Mr. Edwards ever participated\ 8 (in any effort to market any kind of investment in\ 9 (anything?\ 10 (A. I would have to claim attorney/client\ 11 (privilege on that, sir.\ 12 MR. PIKE: Form.\ 13 BY MR. SCAROLA:\ 14 (Q. (Do you have knowledge of any evidence\ 15 (whatsoever that Mr. [REDACTED] was ever a participant in\ 16 (devising a plan through which were sold purported\ 17 (confidential assignments of a structured payout\ 18 (settlement?\ 19 A. (The newspapers and blogs have widely reported\ 20 (that Mr. Edwards' firm crafted -- would you repeat the\ 21 (question for me, again, sir? I'm sorry.\ 22 Q. (Yes, sir. I want to know whether you have any\ 23 (knowledge of evidence that Bradley Edwards personally\ 24 (ever participated in devising a plan through which were\ 25 (sold purported confidential assignments of a structured 1 (currently under investigation by either the Florida Bar\ 2 (or the U.S. Attorney or FBI or all of the above, sir.\ 3 (Q. (Which -- which source of information\ 4 (referenced in that answer specifically made reference to\ 5 (Mr. Edwards?\ 6 (A) (I don't recall, sir.\ 7 Q. But you do have a recollection that one or\ 8 more of them did; is that correct?\ 9 A. I don't recall, sir.\ 10 Q. So you want to withdraw the earlier response\ 11 that you made and your real answer is, I don't know; is\ 12 that correct?\ 13 MR. PIKE: Mischaracterizes the witness'\ 14 testimony. Move to strike.\ 15 BY MR. SCAROLA:\ 16 Q. Your response, sir?\ 17 A. My answer stays the same, sir.\ 18 Q. Is it your contention that one or more\ 19 lawsuits was fabricated against you?\ 20 A. It's been widely reported in the newspapers --\ 21 Q. That's not my question.\ 22 A. Excuse me. I was answering.\ 23 MR. PIKE: Please let the witness answer the\ 24 question, Mr. Scarola.\ 25 BY MR. SCAROLA: 1 Q. No, you're not answering my question. 2 MR. PIKE: He's only said three words, so you 3 don't know whether he's answering your question or 4 not. 5 MR. SCAROLA: I didn't ask him anything about 6 newspapers. I asked him about his contention. I 7 don't know he's not answering my question. 8 BY MR. SCAROLA: 9 Q. But you can go ahead, Mr. Epstein, and you can 10 make your silly speech one more time. 11 MR. PIKE: Fm going to move to strike. 12 THE WITNESS: You want to repeat the question? 13 BY MR. SCAROLA: 14 Q. Yes, sir. I would like to know whether it is 15 your contention that one or more lawsuits have been 16 fabricated against you. 17 A. My contention, sir, is that the firm of 18 partners, Scott Rothstein, fabricated many 19 cases, reported by the press and the U.S. Attorney, 20 amongst people like me and others of a sexually charged 21 nature in order to fleece investors of South Florida out 22 of millions of dollars. 23 Do I have a with respect to my individual 24 cases that Mr. has filed in these three cases, 25 I'm unfortunately today, and only today at least, on 1 advice of Counsel I'm going to have to assert my Fifth, 2 Sixth and 14th Amendment, sir. 3 Q. Okay. Well, I'm not limiting my quesd 4 the three cases referenced in your Complaint/I yin 5 know whether you contend that any claim against you has 6 been fabricated? 7 MR. PIKE: Form. Overbroad and confusing and 8 it's compound. 9 THE WITNESS: The question makes no sense to 10 me. Pm sure you could do better. 11 BY MR.. SCAROLA:, 12 Q. Is there anyPending claim against you which 13 you contend is flibricated? 14 A. At least teday, sir, I'm going to have to 15 respondlyaantintiny Fifth, Sixth and 14th Amendment 16 Right. --- 17 MR. PIKE: Form, also. 18 BY MR. SCAROLA: 19 Q. Is it your contention that was 20 ever personally involved in manufacturing false and/or 21 fraudulent Court Opinions or Orders? 22 A. Attorney/client privilege. 23 Q. Your Complaint makes reference to someone 24 sifting through a potential defendants garbage looking 25 for damaging evidence to use with investors to show how 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 2,,S\\niu 24 potential defendants could be, in essence, blackmailed. MR. PIKE: Would you identify for me, Mr. Scarola, what page? MR. SCAROLA: Page 8, paragraph 19. BY MR. SCAROLA: Q. Did anyone ever sift through your garbage looking for damaging evidence? MR. PIKE: One second. In light of clarity, Mr. Scarola, would you please read the entire paragraph so Mr. Epstein understands the tenor of the paragraph? MR. SCAROLA: No. I want to know whether anyone ever sifted through It garbage through Mr. Epstein's garner. Mtn the pending question. MR. PIKE: Tcrifantelit you understand the question, you can answeti l THE WITNESS: I think the question is poorly phrased. Did anyone ever sift through my garbage? Whatdnes that mean? BY Mt SC OLA: n't know what sifting through garbage Does that mean the garbage man? Does that the garbage man? I'm sure he sifted through my 17 garbage. Q. Which garbage man sifted through your garbage? 3 A. I'm sure people who go through garbage sift 4 through the garbage. I have no idea. 5 Q. Did anyone ever sift through your gerbils 6 (IcTollin-Ifirdar--firginj-Fiilei li? 7 (A. it's been widely reported in the newspapm 8 (iiiTitill that- eng,ageliiiiiftin—g-thrrx(gh 9 many people's garbage in order— in an attempt to 10 blackriailihn. 11 Q. Yes. But I didn't ask you what some newspaper 12 is alleged to have reported. 13 What I did ask you is whether anyone ever 14 sifted through your garbage looking for damaging 15 evidence. 16 And the answer to that question, I think, can 17 be either yes, no, or I don't know. 18 NM. PIKE: Move to strike. 19 BY MR. SCAROLA: 20 Q. • Or you could refuse to answer it on the 21 grounds that it may tend to incriminate you. 22 A. I think you might — 23 MR PUCE: Move to strike. 24 THE WITNESS: I would like to answer my own 25 questions. If you'd like to answer all my 1 questions, Mr. Scarola, I'm more than happy to sit 2 here and answer them. Would you like to continue? 3 BY MR. SCAROLA: 4 Q. (Yerrc likitElarvwhWthe answer trIthit 5 (question is. Did anyone ever sift through your garb:trio 6 (I cTol)rig-for damagingevidence? 7 MR. PIKE: Form. 8 (THE WITNESS71115iff WER. 9 BY MR. SCAROLA: 10 Q. Did you ever have damaging evidence in your 11 garbage? 12 A. What's damaging evidence, sir? 13 Q. Evidence tending to implicate you in criminal 14 conduct. 15 MR PIKE: Form. 16 THE WITNESS: At least today, Mr. Scarola, 17 with these — with your questions and your claims 18 and your defense of Mr. and his firm, the 19 Rothstein firm, while his partner sits in jail, 20 today I'm going to have to assert my Fifth, Sixth 21 and 14th Amendment Right, sir. 22 BY MR. SCAROLA: 23 Q. Did you ever have any evidence in your garbage 24 that would subject you to blaclanail? 25 MR. PIKE: Form. Same — same objection. 1 You've been interchanging knowledge with personal 2 knowledge. And many of the objections to which I 3 am asserting an attorney/client and work product privilege arc based upon your malphrased question 5 and use of personal knowledge and knowledge 6 interchangeably with those questions. 7 So if you want to rephrase your question to 8 attempt to elicit a response let me finish — 9 then I have no objection to that. However, I'm not 10 going to sit hero and allow my client to waive 11 attorney/client and work product. 12 Now, to the extent you're saying Pm coaching 13 the witness, I object to that because I am 14 certainly not. The witness bi here to answer your 15 questions and I believe has been answering your 16 questions today tothe best of his ability. 17 MR. SCAR ; I arp saying you're coaching the 18 witness. 19 BY MR. SC LA:" 20 Q. Could you answer the question? 21 MR. PIKE: Same objection. 22 THE WITNESS: You'll have to repeat it. 23 SCAROLA: 24 (ps7rou have information mclicaturithrit 2 ey Edwards ever had any knowledge of anyone 2 the question by asserting my Fifth, Sixth and 14 THE WITNESS: Again, I'll respectfully answer 1 3 Amendment Right. ir2 4 BY MR. SCAROLA: 5 Q. Your Complaint in paragraph 21,0ge 6 that: "Upon information and belief R tein, D d 7 Boden, Debbie= Andrew Barnett, Michael Fisten 8 and Kenneth Jenne, all employees of RRA, through brokers 9 or middle men would stage regular meetings during which 10 false statements were made about the number of 11 cases/clients that existed or RRA had against Epstein 12 and the value thereof? 13 Do you have any knowledge that Mr. 14 ever knew aboutsuch meetings being conducted? 15 MR. PIKE: Form. 16 To the atent you understand the question and 17 it will not violate any attorney/client or work 18 product privilege information, you can answer that 19 question. 20 MR. SCAROLA: Mr. Pike, it has become evident 21 that that speaking instruction to your witness is 22 an instruction for him to assert an attorney/client 23 privilege, regardless of whether it is or is not 24 valid and I object to it. 25 MR. PIKE: Let me make the record clear. 44\\ 1 1 (associated with the Rothstein firm holding meetinTs (dirring which, quote, "false statements were made about 3 (the number of cases/clients that existed or RRA hid 4 Grainst Epstein and the value thereof," unquote? 5 MR. PIKE: Form. Same objection. 6 (THE WITNESS: My best recollection is the UTS) 7 (Attorney has accused the Rothstein firmeifjtIsi 8 (those types of meetings where the partners got 9 together, schemed to defraud local investors of) 10 (millions of dollars by fabricating cases of3 11 sexuallycharged nature. And whether Mr. Edward 12 personally rticipaUadTrn itt lerT'sf 13 at tay, sir, have to assert the attorneyklieit 14 (Ir(Cfilege, but look forward to one day disclor4 15 (111. 16 MR. SCAROLA: Move to strike all unresponsive 17 portions of the answer. 18 BY MR. SCAROLA: 19 © (Paragraph 23 f our Complaint says tht? 20 (1KRA, Rothstein and cliirTling the needla 21 anonymity with regard to existing abricated clients, 22 (i y were able to effectively use initials." 23 (to you have any knowledge that 24 (fabricated a client toa claim against you?( 25 MR. PIKE: Form. 1 THE WITNESS: I believe Mr. Scherer's\ 2 Complaint\ 3 BY MR. SCAROLA:\ 4 Q. I'm not asking about Mr. Scherer's Complaint.\ 5 I'm asking about any evidence that you have.\ 6 MR. PIKE: The witness is basically been five\ 7 words into his sentence and you're not allowing him\ 8 to finish, once again.\ 9 So if you recall the question, then please\ 10 respond.\ 11 THE WITNESS: Please repeat it back, please?\ 12 MR. PIKE: Madame Court Reporter, if you\ 13 would.\ 14 (Pending question was read.)\ 15 MR. PIKE: Form.\ 16 THE WITNESS: The pleadings of Mr. Scherer and\ 17 (his claim against the Rothstein firm for a massive\ 18 (fraud, as well as Mr. Sakowitz's claims to -- at\ 19 (least in the -- described in the public press,\ 20 (because he went to the FBI, for fabricating cases\ 21 (that included initials.\ 22 (With respect to anything specific with\ 23 (Mr. Edwards, I'm going to have to claim the\ 24 (attorney/client privilege today, sir.\ 25 BY MR. SCAROLA: 1 MR. PIKE: -- then, please, --\ 2 THE WITNESS: Yes.\ 3 MR. PIKE: -- answer Mr. Scarola's question.\ 4 THE WITNESS: Separate from --\ 5 MR. SCAROLA: Objection. Coaching the\ 6 witness.\ 7 THE WITNESS: Separate from the communication\ 8 I've had with my attorneys, I can't answer that\ 9 question.\ 10 MR. PIKE: Mr. Scarola, I'm confused. I\ 11 started objecting to form in the beginning of this\ 12 deposition. You then instructed me, which is\ 13 against the rules, Mr. Pike, I don't know what's\ 14 wrong with the form. I object to you objecting to\ 15 form.\ 16 Then I assert the attorney/client, work\ 17 product, and now you're telling me I'm coaching the\ 18 witness.\ 19 So tell me, Mr. Scarola, what is the -- what\ 20 is the way that you would like me to object in this\ 21 deposition, and maybe I can conform that way for\ 22 you, which may or may not be consistent with the\ 23 Florida Rules of Civil Procedure.\ 24 MR. SCAROLA: Mr. Pike, --\ 25 MR. PIKE: Yes, sir. 1 Q. (Do you have any -- do you have knowledge of\ 2 (the existence of any evidence that Bradley Edwards knew\ 3 (that Rothstein was utilizing RRA as a front for a Ponzi\ 4 (scheme?)\ 5 MR. PIKE: Form.\ 6 (THE WITNESS: That's attorney/client\ 7 (privilege)\ 8 BY MR. SCAROLA:\ 9 (Q. Do you have knowledge of any evidence that\ 10 (would indicate [REDACTED] Ed [REDACTED] should have known that\ 11 (Rothstein was utilizing RRA as a front for a Ponzi\ 12 (scheme?)\ 13 MR. PIKE: Form.\ 14 THE WITNESS: At least today --\ 15 MR. PIKE: Wait.\ 16 THE WITNESS: Sorry.\ 17 MR. PIKE: Form. Same objections. Same\ 18 attorney/client, work product as to the last\ 19 question. Same objections here, attorney/client\ 20 work product.\ 21 THE WITNESS: And today I'm going to have to\ 22 (assert the attorney/client privilege.\ 23 MR. PIKE: To the extent you can answer that\ 24 question --\ 25 THE WITNESS: I understand. 1 MR. SCAROLA: -- if you don't know the\ 2 difference between a form objection and a privilege\ 3 objection --\ 4 MR. PIKE: Right.\ 5 MR. SCAROLA: -- then this deposition is not\ 6 the proper context in which for you to learn the\ 7 difference between a form objection and a privilege\ 8 action.\ 9 MR. PIKE: I'm pretty clear on what a form\ 10 objection is and what a privilege objection is and\ 11 I'm pretty knowledgeable on that. The problem --\ 12 MR. SCAROLA: Then we don't need to engage in\ 13 any further discussion.\ 14 MR. PIKE: -- I want to try to make the record\ 15 clear, because initially you didn't want me to\ 16 object to form. You wanted me to speak. So I'm\ 17 thinking you're conceding to that point.\ 18 What my question is, is: What's wrong with my\ 19 objecting to attorney/client, work product? So I\ 20 guess I'm asking you what you were asking me\ 21 earlier on. What's wrong with the form?\ 22 We can just move forward.\ 23 BY MR. SCAROLA:\ 24 Q. In your Complaint you identify the RRA law\ 25 firm, Rothstein and [REDACTED] as the, quote, "litigation 1 team," unquote. 2 You then go on to say in paragraph 31 of your 3 Complaint at page 12 that: "Rothstein and the 4 litigation team" — 5 MR. PIKE: Wait a minute. Put that down for a 6 second. Hold on. 7 THE WITNESS: You can read it. 8 BY MR. SCAROLA: 9 Q. 'Individually and in a concerted effort may 10 have unethically and illegally engaged in certain 11 specified conduct" 12 May we correctly conclude from that statement 13 that you don't have any knowledge as to whether the, 14 quote, litigation team," including Mr. S engaged 15 in any unethical and illegal conduct? 16 MR. PIKE: For now, while Pm reviewing the 17 document itself, I'm just going to just tell you to 18 hold off — 19 THE WITNESS: Sure. 20 MR. PIKE: -- on answering that question. 21 You may want to go otTthe record, so we don't 22 have a lag in — 23 MR. SCAROLA: No, I'd like it on the record. 24 Thank you. 25 MR. PIKE: Mr. Scarola, did you bring an extra 1 copy of the Complaint that you're questioning 2 Mr. Epstein on for Mr. Epstein to look at? 3 MR. SCAROLA: No. 4 MR- PIKE: Okay. I'm going to ha 5 him a copy so he can — the paragrapheof 6 Complaint are very long and the CoMplaint itlElf is 7 in excess of — it was approximatelyttpages, 8 9 MR. SCAROLA: I'll withdowalte question. 10 BY MR. SCAROLA: - 11 Q. (Do you haveanyovidence thatErad Edward!, 12 cold;allowed to be soldigil/or assisted7iththe sit 13 (of an interest in-non-settled personal Injury lawsuits? 14 MR7PIKJ3: Form. 15 TIM WITNESS:(Thenewspapers have widely, 16 (reported that the Rothstein-firm engaged in illegal 17 (structured -sVtlementSofcaseeof exual as naturei 18encludingspecifically-me:-We have subpoenaed the 19 i(c cumentafrom•Mr1M7dhis finnand we have 20 er 2t. been able to get them as of ye/3 21 l —arrronlident that once we do be able 22 (to-answer your questions with-more-specificity; 23 BY MR. SCAROLA: 24 Q. (As you sit here today; do you have any/ 25 (evidence whatsoever to support an-assertion that 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24s, 2 (SiEdiiiicliTallyand personallrroldrallm—Cedlo nib-Fold ITid/ol'a--ssiStEdi-vith-th-o-fall-fif b-iiiiiterislin (non-settled personal tgryry lawsuits? MR. PIKE: Before you answer that question, Madame Court Reporter, will you please read that question back to me? (Pending question was read.) MR. PIKE: To the extent you can answer that question without divulging attorney/client or work product information, you may answer that question. MR. SCAROLA: Objection. Coaching. THE WITNESS:-risaiiiTalicrudib-bWald. going to assert attomey/ai wile-li -fo (the answer, I'm afraid, but NI like to answer that question. BY MR. SCAROLA: Q. lio you have howled e of any evideTe (hTdicTatin--g-thilBrildley ever reached agreements 0-5-share attomey's fees with—ifori-lau—yrrs? MR. PIKE: I'm sorry. Mr. Scarola, can you tell me what page of the Complaint you're referring to, if you are? " \\ preMR. SCAROLA: I'm not referring to any page of Complaint, although I will tell you that that cise allegation is made in the Complaint. 1 Page 85 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 WITNESS:(rfa,"Mi:Scrrola,--w—ehWe abpoenaed-Mr:Edwards documents and-documents (from hits firm tliaf 1 Rlie7ilITiTftglivme ( more specificity with answers ffthat question. (1YrilakinTforvrardlcittinTthr-thit 01x-TcifireVideWerWith - respect to what we (currently know, sitting hertodayr, pinfoltdicatelfgoihitolfaVito-blaim my cattorney/elientiTriCiilers. (23y MR7SCARDLTA: (9) (Do you toda have an evidence to support an assertioTitha ever usedinvestor money (to payL.M.7E.W., and/or Jane Da-IV-front money, such (tfialthey would-lifus—itErgettlrob-ril-attioiTs? MR. PIKE: Same instruction. THE WITNESS: You'll have to get I need to hear the first part of the question. Do I have any evidence? Do I have knowledge of evidence? I'm sorry. What was the — BY MR. SCAROLA: Q. Do you have knowledge of any evidence to support that assertion? MR. PIKE: To the extent you can answer that question without violating attorney/client, work product, please do so. 1 MR. SCAROLA: Objection. Coaching.\ 2 THE WITNESS: "I'm going to have to assert the\ 3 \[attorney/client privilege, I'm afraid, though I'd\ 4 (like to answer that question as well, sir.\ 5 BY MR. SCAROLA:\ 6 Q. (Do you have any evidence to support the\ 7 [redacted] conducted searches, wire\ 8 (taps or intercepted conversations in violation of State\ 9 or Federal laws and Bar rules?\ 10 A. (Your question, once again, asked did Mr. -\ 11 was Mr. Edwards personally involved in the\ 12 eavesdropping? Did he walk to someone's house and sort\ 13 of put a bug in their house? Did he, personally, stand\ 14 outside?\ 15 (The question is, did Mr. Edwards' firm engage\ 16 in this behavior in an attempt to defraud local\ 17 investors out of millions of dollars? The U.S. attorney\ 18 has filed a Complaint saying that they did. The\ 19 Complaints filed by Scherer saying that his firm did.\ 20 (The Scherer Complaint says my name and the\ 21 boxes of files that we've subpoenaed used my name, sir.\ 22 (We have requested information, but up until\ 23 today have not received any.\ 24 (To give you a more specific answer, I'm afraid\ 25 I cannot. 1 To the extent you can answer the question\ 2 without disclosing attorney/client or work product\ 3 information, do so.\ 4 (THE WITNESS: The pleadings of Mr. Scherer\ 5 with respect to the largest Ponzi scheme in South\ 6 Florida's history engaged in by Mr. Edwards' firm\ 7 and Scott Rothstein, who currently sits in jail,\ 8 probably for the rest of his life for engaging in,\ 9 not only illegal wire taps and eavesdropping, but\ 10 an abuse of the entire legal system, I believe\ 11 speaks for itself.\ 12 (Unfortunately, with respect to Mr. Edwards\ 13 today, I'm going to have to assert the\ 14 attorney/client, work privilege, sir.\ 15 BY MR. SCAROLA:\ 16 Q. (Is it your contention that Mr. Scherer's\ 17 Complaint even contains the name [redacted]?\ 18 (A) (I don't recall, sir.\ 19 Q. Did sexual assaults ever take place on a\ 20 private airplane on which you were a passenger?\ 21 MR. PIKE: Form. Relevance.\ 22 THE WITNESS: At least -- I would like to\ 23 answer each and every one of your questions here\ 24 today, Mr. Scarola. But at least today, I'm going\ 25 do have to assert my Fifth, Sixth and 14th 1 Q. (Do you have knowledge of any evidence that\ 2 [redacted] ever conducted searches, wire taps or\ 3 (intercepted conversations in violation of State or\ 4 (Federal laws and Bar rules?\ 5 MR. PIKE: Same instruction.\ 6 THE WITNESS: (The newspapers and the U.S.\ 7 (Attorney's Complaint widely reported that\ 8 (Mr. [redacted] firm and people hired by his firm,\ 9 (investigators hired by his firm fraudulently\ 10 (representing themselves as FBI agents engaged in\ 11 (just those activities, sir.\ 12 BY MR. SCAROLA:\ 13 Q. (Do you have any knowledge of any evidence that\ 14 (Bradley Edwards was ever aware of any such activities?\ 15 A. (I'm going to have to --\ 16 MR. PIKE: Same objection.\ 17 THE WITNESS: -- assert the attorney/client,\ 18 (privilege to that, sir.\ 19 BY MR. SCAROLA:\ 20 Q. (Do you have any knowledge that [redacted]\ 21 (ever participated in or was aware of actions that\ 22 (utilized the judicial process, including, but not\ 23 (limited to, unreasonable and unnecessary discovery for,\ 24 (the sole purpose of furthering a Ponzi scheme?\ 25 MR. PIKE: Same objection. 1 Amendment Rights as provided by the U.S.\ 2 Constitution.\ 3 BY MR. SCAROLA:\ 4 Q. Does a flight log kept for a private jet used\ 5 by you contain the names of celebrities, dignitaries or\ 6 International figures?\ 7 A. At least today, sir, I'm going to have to\ 8 respectfully decline to answer based on my Fifth, Sixth\ 9 and 14th Amendment Right, though I'd like to answer that\ 10 question.\ 11 Q. Have you ever had a personal relationship with\ 12 Donald Trump?\ 13 A. What do you mean by "personal relationship,"\ 14 sir?\ 15 Q. Have you socialized with him?\ 16 A. Yes, sir.\ 17 Q. Yes?\ 18 A. Yes, sir.\ 19 Q. Have you ever socialized with Donald Trump in\ 20 the presence of females under the age of 18?\ 21 A. Though I'd like to answer that question, at\ 22 least today I'm going to have to assert my Fifth, Sixth\ 23 and 14th Amendment Right, sir.\ 24 Q. Have you socialized with Alan Dershowitz?\ 25 A. Yes, sir. He's my attorney, as well as a 1 friend.\ 2 Q. (Have you ever socialized with Alan Dershowitz\ 3 in the presence of females under the age of 18? 4 (MR. PIKE: Form.\ 5 (THE WITNESS: Sir, at least here today, I'm\ 6 going to have to assert my Fifth Amendment, Sixth\ 7 Amendment and 14th Amendment Rights. 8 BY MR. SCAROLA:\ 9 Q. Have you ever socialized with Tommy Mottola?\ 10 A. This is the type of questions where people who\ 11 have nothing to do with this case whatsoever have been\ 12 brought into the case by Mr. [REDACTED] in an attempt to\ 13 simply imperil my relationships with social friends and\ 14 serves as an example of why this case has been brought\ 15 against Mr. [REDACTED] and his firm, sir.\ 16 MR. PIKE: Form as well.\ 17 BY MR. SCAROLA: 18 Q. Well, do you know who brought those persons'\ 19 names into this lawsuit?\ 20 (MR. PIKE: Form.\ 21 (And just to be clear, what Mr. Scarola, I\ 22 believe, talking about this lawsuit, Epstein versus\ 23 (RRA?\ 24 (BY MR. SCAROLA:\ 25 (Q. Yes, sir, that's the lawsuit I'm talking 1 about. The one in which your deposition is being taken\ 2 today.\ 3 Do you know who brought those persons' names\ 4 into this lawsuit? 5 A. As a reaction, and only as a reaction to total\ 6 misbehavior on Mr. [REDACTED] part, and the Complaint was\ 7 obviously written by my attorneys, sir. 8 Q. So you know that those names are in your\ 9 Complaint, right? 10 A. Yes, sir.\ 11 Q. Okay. So because those names are in your\ 12 Complaint, I'm asking you about the people you named. 13 Have you had a social relationship with Tommy\ 14 Mottola? 15 A. The names in my Complaint are strictly as a\ 16 reaction to the abusive discovery process by\ 17 Mr. [REDACTED] his partners, Scott Rothstein, who sits in\ 18 jail, in an attempt to imperil my friendships. 19 But, yes, I have socialized with Mr. Mottola.\ 20 Q. Have you ever socialized with Mr. Mottola in\ 21 the presence of females under the age of 18? 22 MR. PIKE: Form.\ 23 THE WITNESS: At least today, the typical to\ 24 the [REDACTED] contention of bringing cases of a\ 25 malicious nature where his partner sits in jail for 1 (this -- just this type of behavior, the answer is,\ 2 today, at least, I must assert my Fifth, Sixth and\ 3 14th Amendment Right, though I'd like to answer\ 4 each and every one of your questions, Mr. Scarola. 5 BY MR. SCAROLA:\ 6 Q. Have you had a social relationship with David\ 7 Copperfield?\ 8 A. As a reaction to, once again, the abusive\ 9 discovery process of bringing in names of people that\ 10 have absolutely nothing to do with any of Mr. [REDACTED],\ 11 Mr. Rothstein's or their clients' claims, by bringing in\ 12 the names of friends of mine strictly in an attempt to\ 13 stress my relationships, imperil my business\ 14 relationships, I'm going to say, yes, I do know\ 15 Mr. Copperfield. 16 Q. (Have you ever socialized with David\ 17 (Copperfield?\ 18 (A. Again, as --\ 19 (MR. PIKE: Form.\ 20 (THE WITNESS: Sorry,\ 21 (It's a typical Edwards/Rothstein strategy of\ 22 trying to involve well-known people in maliciously\ 23 fabricated cases in order to fleece investors out\ 24 of millions of dollars. They brought up names in\ 25 attempts at abuse of discovery process to try and 1 (take discovery of people who have nothing to do\ 2 with this case.\ 3 (Did I socialize with David Copperfield? The\ 4 answer is, yes. 5 (BY MR. SCAROLA:\ 6 Q. Did you ever socialize with David Copperfield\ 7 in the presence of females under the age of 18?\ 8 (A. I'm sure, again, this question is a typical\ 9 question of Mr. Edwards/Rothstein scheme to defraud\ 10 investors, asking questions knowing it serves no purpose\ 11 or relationship relevance to their case whatsoever.\ 12 (At least today, though I'd like to answer that\ 13 question, on advice of my Counsel, and only on advice of\ 14 my Counsel, I'm going to have to assert my Fifth, Sixth\ 15 and 14th Amendment Right.\ 16 (MR. PIKE: Form as well.\ 17 BY MR. SCAROLA: 18 Q. (Have you ever had a social relationship with\ 19 Bill Richardson, Governor of New Mexico and formerly\ 20 (U.S. Representative and Ambassador to the United\ 21 Nations?\ 22 (MR. PIKE: Form.\ 23 (THE WITNESS: As is typical of the Edwards\ 24 scheme, along with his partner, Scott Rothstein,\ 25 who sits in jail, what they attempted to do was 1 (bring in any celebrity I might have known,\ 2 well-known people, in an attempt to strictly\ 3 imperil my relationships with these people where\ 4 these people have no bearing whatsoever on any of\ 5 their claims or cases. 6 (Yes, I do have a social relationship. 7 (BY MR. SCAROLA: 8 (Q. (Have you ever socialized with Mr.\ 9 (in the presence of females under the age of 18? 10 (MR. PIKE: Form. 11 (THE WITNESS: Again, typical of the\ 12 (Edwards/Rothstein scheme of bringing in well-known 13 (people, asking them ridiculous questions)\ 14 (ridiculous questions in an attempt strictly to\ 15 (imperil my relationships with these people where\ 16 (they have absolutely nothing to do with anything to\ 17 (do with Edwards, Rothstein or any of their alleged\ 18 (victims, the answer to your question is, yes, I\ 19 (have socialized. 20 (BY MR. SCAROLA: 21 (Q. (Yes, but that wasn't my question)\ 22 (My question was: Have you ever socialized\ 23 (with Mr. Richards in the presence of females under the\ 24 (age of 18? 25 (MR. PIKE: Form. 1 THE WITNESS: In response to your question,\ 2 again, my full answer was, typical of the\ 3 (Rothstein scheme to ask questions of a\ 4 sexual charged nature, crafted cases, the U.S.\ 5 Attorney has called his firm the largest fraud in\ 6 U.S. history, fleecing investors out of millions of\ 7 dollars by engaging in just these types of\ 8 questions. Though I would like to answer each and\ 9 every question about every one of these people, on\ 10 advice of my Counsel today, I must take -- assert\ 11 my Fifth Amendment, Sixth Amendment and 14th\ 12 Amendment Right. Though I'd prefer to answer the\ 13 question, I was told that if I choose to do so, I\ 14 risk losing their representation, sir. 15 (BY MR. SCAROLA: 16 (Q. Have you ever sexually abused children? 17 (MR. PIKE: Form. 18 THE WITNESS: On advice of Counsel, and only\ 19 upon advice of Counsel, though I'd like to answer\ 20 that question, as well as every other one of your\ 21 claims brought by Mr. ( and his partner, who\ 22 currently sits in jail, sir, I would like to answer\ 23 those questions. But today at least, I have to\ 24 assert my Sixth Amendment, 14th Amendment and Fifth\ 25 Amendment Right. Though I'd prefer to answer the 1 (question, I'm told by my Counsel that if I choose\ 2 to do so, which is my preference, I risk losing\ 3 their representation. 4 (BY MR. SCAROLA: 5 (Q. (How many children have you sexually abused? 6 (MR. PIKE: Form. 7 (And I just want to be clear on the record. 8 (These types of questions are argumentative and\ 9 (harassing. And, moreover, it's my contention that\ 10 these types of questions are not related to this\ 11 (lawsuit by any stretch of the imagination. In this\ 12 (deposition, while I've been liberal in allowing\ 13 these questions, are being utilized in an attempt\ 14 to provoke a waiver of the Fifth Amendment Right. 15 There has been an Order entered by, I believe,\ 16 Judge Hafele regarding these types of questions. 17 So with that caution, Mr. Scarola, I would ask\ 18 you that you refrain from asking abusive and\ 19 harassing questions that are not relevant to this\ 20 case. 21 MR. SCAROLA: Well, it's very interesting that\ 22 you claim they're not relevant when they are\ 23 directly taken from the allegations in your\ 24 Complaint. 25 And I agree with you that they are not 1 relevant because there is no basis whatsoever for\ 2 this claim against Mr. ( But since you've\ 3 made these baseless allegations, I am obliged to\ 4 pursue the allegations by asking these questions. 5 So we'll move on from there. And whenever you\ 6 think it's appropriate to terminate this deposition\ 7 because you believe that I've acted\ 8 inappropriately, be my guest. 9 MR. PIKE: I appreciate your invitation,\ 10 Mr. Scarola. 11 I'm going to move to strike. 12 The fact is, Mr. Scarola, is that, these types\ 13 of questions have already been ruled upon as being\ 14 argumentative and harassing. 15 If you want to direct some questions relevant\ 16 to your lawsuit, I invite you to do so. But\ 17 attempting to use this deposition process as a\ 18 mechanism to provoke a waiver of the Fifth\ 19 Amendment and to obtain information that is more or\ 20 potentially more relevant to Mr. ( cases in\ 21 which he is lead Counsel on, I think is improper. 22 BY MR. SCAROLA: 23 Q. Did you have staff members that assisted you\ 24 in scheduling appointments with underage females; that\ 25 is, females under the age of 18? 1 Q. What day are you prepared to answer all these 2 questions? 3 MR. PIKE: Form. Attorney/client and work 4 product. 5 THE WITNESS: That's attorney — I wish I 6 could answer that question as well, but it's 7 attorney/client privilege, sir. 8 BY MR. SCAROLA: 9 Q. Your Complaint says that: "Rather than 10 evaluating and resolving the cases based on the merits," 11 open patens, "i.e., facts," close parens, "which 12 included knowledgeable, voluntary and consensual actions 13 by each of the claimants," et cetera. 14 Who are the claimants that are referenced 15 there? 16 A. It's — I'm sorry. You have to repeat the 17 question. 18 Q. Yes, sir. Your Complaint says,: — 19 MR. PIKE: Page? 20 Q. "rather than evaluating" — 21 MR. PIKE: Can you give me a page, sir? 22 MR. SCAROLA: Page 27, paragraph 49, second 23 sentence. 24 BY MR. SCAROLA: 25 Q. Quote, "rather than evaluating and resolving 1 the cases based on the merits, that is, facts which 2 included knowledgeable, voluntary and conse 3 by each of the claimants." 4 A. Yes. 5 Q. Who are the claimants that you're 6 there? 7 A. Theyre the prostitutes you refers to jh the 8 past, sir. 9 Q. What are their names? 10 A. I think the prostitutes' nitrites were — the 11 prostitute that you deseitibed before was L.M. 12 With respect to the others, I'm ping to have 13 to claim the Fifth, Sixth and 14th Amendment, sir. 14 Q. So one of the individuals that you're 15 refereneingliale is L.M.; is that correct? 16 A. It's-- fife Individual I've referenced is a 17 person who flied a claim against me. 18 Q. Is it L.M.? 19 A. It is L.M., as far as I Imow from the claim, 20 sir. 21 Q. Okay. So one of the people that you're 22 referring to is L.M., who you've identified as L.M.; is 23 that correct? 24 A. With respect to that question, sir, on advice 25 of Counsel, I'm going to have to assert my Fifth, Sixth 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 and 14th Amendment. Q. What are the voluntary and consensual actions by L.M. that you are referencing there? A. Sir, though I'd like to answer each one of your questions here today, fm going to have to respectfully decline based on advice of my Counsel, and have to assert my Fifth, Sixth and 14th Amendment Right. Q. (What are the damages that you claim to have suffered as a consequence of any wrongdoing on theThiart MR. PIKE: Form. (THE—WITNESS:7Th° cost ofildiculous litigation, of having my attorneys prepare responses to wildly irrelevant discovery in various (kration ninimum, sli) BY MR. SCAROLA: Q. Which lawyer! A. (Burman ritton,leek Goldberger, and a bunch arthe others, sir Q. (Whichonest(Name them for me, please) A. Spec' cally — have so man lawyers de ding me here against Mr. I con'ail (here — at the moment I can't recall it with\` ci) 'tep. (You don't remember any of your lawyers' names? 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25. A. Lth71-clin Q. (BesidesMr. -- besides the Burman Critton an irr.:Goldberger?/ ATAre you askingme for the firm, sir, or are Foraskini_na games?, --747(1 want as much information as you can give me! (bout this element of damage which you claim;aa l:,—ih—at 61, the cost of legal services that you claim to be (damages in this—ZO. A. (sica.7 MR. PIKE: Form. And move to stripe. (THE WITNESS; ah . Roy Black BY MR. SCAROLA: Q. (Okay. Who else? A. (Mi. Marty Weinbei av .Alan Dershcoviik' al rliTiLl-fkowitz. The finn of Burman Crittortier. (That's it for the rnnu nent. Q. (How much have you paid the law firm of Burman (Critton and Luttier which you claim is damage! A. (Hundreds of thousands of dollars, sir) Q7Hovrnuch? A. (I don't have that figure offhand) Q. (Can you give us any better figure than hundreds of thousands of dollars?) E) (No, not sittinghere today:, 1 Q. (Are you paying them on an hourly basis?\ 2 (A. Yes, sir.\ 3 Q. What is the hourly rate at which you are\ 4 (compensating members of the law firm?\ 5 (A. They're ordinary rates.\ 6 Q. (What are they?\ 7 (A. I don't know.\ 8 Q. How much have you paid Mr. Goldberger?\ 9 (A. I'm not aware total amount, sir.\ 10 Q. (What is the hourly rate at which you're paying\ 11 (Mr. Goldberger?\ 12 (A. His normal hourly rate.\ 13 Q. How much is that?\ 14 (A. I don't know.\ 15 Q. How much have you paid Mr. Black which you\ 16 (claim as damages in this case?\ 17 (A. Hundreds of thousands of dollars.\ 18 Q. Are you paying him on an hourly basis?\ 19 (A. I believe so.\ 20 Q. (What is the hourly rate?\ 21 (A. I'm not -- I do not know, sir.\ 22 Q. How much have you paid Marty Weinberger?\ 23 (A. (I don't know the exact amount, sir.\ 24 Q. What's your best estimate?\ 25 (A. More than a hundred thousand dollars. 1 (A. (I don't know.\ 2 Q. Does someone do that on your behalf?\ 3 (A. (I would guess so.\ 4 Q. Who?\ 5 (A. I don't know.\ 6 MR. PIKE: Form.\ 7 BY MR. SCAROLA:\ 8 Q. Who are the people who are authorized to make\ 9 payment on your behalf?\ 10 A. With respect to that question, I'm going to\ 11 have to assert the Fifth, Sixth and 14th Amendment, sir.\ 12 Q. (Are there any other elements of damage, apart\ 13 (from the money paid to lawyers?\ 14 (A. Yes, sir.\ 15 Q. (What?\ 16 (A. The stress and emotional damage of imperiling\ 17 (my friendships and business relationships with no\ 18 (relevance whatsoever to these cases, brought by a firm\ 19 (that whose partner sits in a Federal prison, who engaged\ 20 (in discovery to harass my friends and social contacts\ 21 (with no consideration or relevance to this case\ 22 (whatsoever, in an attempt to simply fleece -- partly\ 23 (fleece investors in South Florida out of millions of\ 24 (dollars, sir.\ 25 (Q. (What is the value of those losses? 1 Q. (Are you paying him on an hourly basis?\ 2 (A. I believe so.\ 3 Q. What's the hourly rate?\ 4 (A. I don't know, sir.\ 5 Q. How much have you paid Alan Dershowitz?\ 6 (A. Hundreds of thousands of dollars.\ 7 Q. (Are you paying him on an hourly basis?\ 8 (A. I believe so.\ 9 Q. At what hourly rate?\ 10 (A. I don't know, sir.\ 11 Q. How much are you paying Jay -- how much have\ 12 (you paid Jay Lefkowitz?\ 13 (A. I'm not sure, sir.\ 14 Q. (Do you have any idea at all?\ 15 (A. More than a hundred thousand dollars.\ 16 Q. Are you paying him on an hourly basis?\ 17 (A. Yes, sir.\ 18 Q. What's the hourly rate?\ 19 (A. I don't know.\ 20 Q. (What is the form of payment to your lawyers?\ 21 (How do you transfer money to them?\ 22 (A. I don't know, sir.\ 23 MR. PIKE: Form.\ 24 BY MR. SCAROLA:\ 25 Q. (Pardon me? 1 (A. MR. PIKE: Form.\ 2 THE WITNESS: (I'm not sure yet, sir.\ 3 BY MR. SCAROLA:\ 4 (Q. (Do you have any idea at all?\ 5 (A. Not sitting here today.\ 6 (Q. (More or less than \$10?\ 7 MR. PIKE: Form.\ 8 (THE WITNESS: I would guess it's more than\ 9 (\$10, sir.\ 10 (BY MR. SCAROLA:\ 11 Q. More or less than a hundred?\ 12 A. (I would guess it's quite an amount of money.\ 13 (Q. (Is it more or less than a hundred?\ 14 (A. Yes, sir.\ 15 Q. More or less than a thousand?\ 16 (A. I would say it's more than 150,000.\ 17 Q. More or less than a million?\ 18 (A. I don't know, sir.\ 19 Q. (So somewhere between 150,000 and a million?\ 20 (A. No, sir. It's not --\ 21 MR. PIKE: Form. Mischaracterizes the\ 22 witness' testimony.\ 23 (THE WITNESS: No, sir. That's not what I\ 24 (said, I said, I did not know.\ 25 BY MR. SCAROLA: 1 Q. Maybe more than a million?\ 2 (A. Yee)\ 3 (Q. More or less than a billion?\ 4 MR. PIKE: Form.\ 5 (THE WITNESS: I don't know)\ 6 BY MR. SCAROLA:\ 7 Q. Maybe more than a billion?\ 8 (A. Maybe more)\ 9 Q. How are you going to go about finding out what\ 10 (the value of that loss is?)\ 11 MR. PIKE: Attorney/client, work product.\ 12 To the extent you can answer without\ 13 disclosing our conversations or the conversations\ 14 with your other attorneys that you've delineated,\ 15 you can do so.\ 16 BY MR. SCAROLA:\ 17 Q. Or you can just take the signal and say, I\ 18 refuse to answer because it's attorney/client privilege.\ 19 A. I resent that.\ 20 MR. PIKE: Move to strike.\ 21 THE WITNESS: But it's okay. You can continue\ 22 to try to harass me, sir. It doesn't work. The\ 23 ladies and gentlemen of the jury, hopefully when\ 24 they see the deposition will recognize and see\ 25 these pile of tricks. The answer -- 1 (1) BY MR. SCAROLA:\ 2 (2) Q. Do you attribute all of the damages that you\ 3 have described to Mr. [REDACTED] conduct?\ 4 MR. PIKE: Form.\ 5 THE WITNESS: As a participant -- I don't know\ 6 how to proportion the conduct as opposed to\ 7 Mr. [REDACTED] and his partner who sits in jail. I\ 8 guess the U.S. Attorney will also make a decision\ 9 to how much the conduct and proportion is relevant\ 10 to both damages and anything else he's done in this\ 11 case, sir.\ 12 BY MR. SCAROLA:\ 13 Q. But I'm not asking you about what the U.S.\ 14 Attorney's opinion is.\ 15 I want to know whether you hold Mr. [REDACTED]\ 16 responsible for all of those elements of damage that you\ 17 have described to us.\ 18 A. It's a difficult question to answer,\ 19 Mr. Scarola.\ 20 Q. No, it's easy. Yes, no, or I don't know.\ 21 MR. PIKE: Mr. Scarola, you know as well as I\ 22 do, the witness is attempting to answer your\ 23 question.\ 24 MR. SCAROLA: I don't think so. I think he's\ 25 attempting to evade all of my questions. 1 MR. SCAROLA: Hopefully they will.\ 2 THE WITNESS: Yes.\ 3 MR. PIKE: Move to strike.\ 4 (THE WITNESS: I will respectfully decline to\ 5 answer that)\ 6 (BY MR. SCAROLA:)\ 7 (Q) (On what basis?)\ 8 (A. Attorney/client privilege)\ 9 (MR. PIKE: And work product)\ 10 (BY MR. SCAROLA:)\ 11 (Q. Any other elements of damage?)\ 12 (A. Not -- there might be, but sitting here today,)\ 13 (I can't think of them.)\ 14 (Q) (Do you have written contracts with any of your)\ 15 (lawyers?)\ 16 (A. I don't know.)\ 17 (Q) (Who does?)\ 18 (A. I don't know.)\ 19 MR. SCAROLA: Let's take a short break. We\ 20 may be finished.\ 21 VIDEOGRAPHER: We are now off the record at\ 22 1:12 p.m.\ 23 (Brief recess.)\ 24 VIDEOGRAPHER: We are back on video record at\ 25 1:18 p.m. 1 MR. PIKE: And I understand your contention.\ 2 However, if you would, allow Mr. Epstein to finish\ 3 his response.\ 4 (4) THE WITNESS: Could you repeat your question?\ 5 (5) BY MR. SCAROLA:\ 6 (6) Q. Do you hold Mr. [REDACTED] responsible for all of\ 7 the damages that you have described?\ 8 (8) MR. PIKE: Form.\ 9 (9) THE WITNESS: It's difficult for me to\ 10 proportion the damages that I have described\ 11 between Mr. [REDACTED] his partner, who is currently\ 12 in jail, his -- the other people named in the\ 13 Complaint. Hopefully a jury will do that.\ 14 (14) BY MR. SCAROLA:\ 15 (15) Q. Do you hold L.M. responsible for all of the\ 16 damages you have described?\ 17 MR. PIKE: Form.\ 18 THE WITNESS: Again, these questions, these\ 19 ambiguous questions, as opposed to who\ 20 participated, I would let Mr. [REDACTED] and his\ 21 clients and his partners decide whose proportionate\ 22 responsibility it is, sir.\ 23 BY MR. SCAROLA:\ 24 Q. So you defer to them?\ 25 MR. PIKE: Form. **APP. 33** NOT A CERTIFIED COPY #### IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN individually. J individually, and L.M., individually, < 94S) Defendants, COMES NOW the Counter-Amended Exhibit List as follows: RADLEY J. M=. and hereby files his - O. No objection - 1. All objections - 2. All object' a e t authenticity - 3. IrreleGiDtt aterial - 4. Probatlye value substantially outweighed by danger of unfair prejudice, confusion of issues, misleading the jury, or needless presentation of cumulative evidence - 5. Privileged - 6. Opinion - 7. Hearsay - 8. Authenticity lacking - 9. Other (please identify basis of objection) O SA ## T LIST #### OBJECTIONS Jeffrey Epstein vs. Scott Rothstein, J. and L.M. Case No. 502009CA040800XXXXMBAG Counter-Plaintiff's, J. Amended Exhibit List | | Counter-Plaintiff | | --- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------ | | | Marked Marked for Description of Exhibit | | | Objection in Evidence Identification | | 1. | All applicable criminal statutes. | | 2. | All applicable Florida Statutes. | | 3. | Photos and information of Jeffrey Epstein's homes, airplanes and automobiles. Tools" and "Training Miss Abernathy: A Workbook for Erotic Slaves and Their Owners". | | 5. | Non-Prosecution Agreement. | | 6. | Jane Doe 102 Complaint. | | 7. | Messages taken from messagepads found at Epstein's home. | | 8 | Documents related to Jeffrey Epstein produced by | | | Alfredo Rodriguez. ,- | | 9. | Jeffrey Epstein's flight log,t. | | 10. | Jeffrey Epstein'S phone records. | | 11. | Sarah Kelten's phone records. | | 12. | JailliVisftati ion Logs. | | 13. | -"I‘effrny Epstein's probation file. | | 14. | All probable cause affidavits related to criminal investigation of Jeffrey Epstein. | | 15. | Victims' statements to the FBI related to criminal investigation of Jeffrey Epstein. | | 16 | Video of Search Warrant of Jeffrey Epstein's home being executed. | | 17. | Application for Search Warrant of Jeffrey Epstein's home. | Jeffrey Epstein vs. Scott Rothstein, and L.M.. Case No.: 502009C M0 IXI RCXMBAG Counter-Plaintiff's, .1 Amended Exhibit List | | vs. Scott Rothstein, J. and L.M. | | --- | ---------------------------------------------------------- | | | Marked Marked for | | | Objection ' Evidence Identification | | | J. Amended Exhibit List | | 18 | Complaint Jane Doe v. Epstein and all subsequent | | 19. | All records of homes, properties, bank accounts and | | | any/ all records related to Jeffrey Epstein's assets. O S' | | 20. | Jeffrey Epstein's passport (or copy). | | 21. | Jeffrey Epstein's driver's license (or copy). | | 22. | List of corporations owned by Jeffrey E | | 23. | Yearbooks of Jane Doe. | | 24. | 2002 Palm Beach High I Book. | | 25. | 2001 Palm Beach Year Book. | | 26. | 2003 Palm Beach G ens School Year Book. | | 27. | Affidavit and lication for Search Warrant on | | | Notepa s nd in Jeffrey Epstein's home and/or | | | d ' g h lls outside of his home during criminal | | | i tiga' on. | | 29. | e alm Beach State Attomey's Criminal file against | | | J rey Epstein. | | 30 | All documents related to Jeffrey Epstein's 6/30/08 | | 31. | Jeffrey Epstein's criminal plea colloquy. | Jeffrey Epstein vs. Scott Rothstein, J. and L.M.. Case No.: 502009.10t0CMBAG Counter-Plaintiff's, Amended Exhibit List | Jeffrey Epstein vs. Scott Rothstein, [REDACTED] J. [REDACTED] and L.M.
Case No. 502009CA040800XXXXMBAG
Counter-Plaintiff's, [REDACTED] J. [REDACTED], Amended Exhibit List | | | | | | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------ | ------------------ | --------------------- | | Counter-Plaintiff | | Marked Marked for | | | | No. | Description of Exhibit | Objection | in Evidence | Identification | | 32. | List of properties and vehicles in Larry Visoski's name. | | | | | 33. | All of Jeffrey Epstein's Responses to Requests for Production, Requests for Admission, Answers to Interrogatories in this matter, and cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092. | | | | | 34. | All discovery related responses of Jeffrey Epstein in this matter and cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092. | | | | | 35. | Jeffrey Epstein's Answers and Affirmative Defenses in all civil cases against him. | | | | | 36. | All Complaints in which Jeffrey Epstein is/was a defendant. | | | | | 37. | Jeffrey Epstein's Deposition testimony and discovery responses in this case and cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092. | | | | | 38. | Jeffrey Epstein's Deposition testimony and discovery responses in State Court cases LM v. Jeffrey Epstein, Case No. 502008CA028051XXXXIMB AB and E.W. v. Jeffrey Epstein, Case No. 502008CP003626XXXXMB. | | | | | 39. | Jeffrey Epstein Deposition Testimony and discovery responses in State Court case Jeffrey Epstein v. Scott Rothstein, et al. Case No 502009CA040800XXXXMBAG. | | | | Jeffrey Epstein vs. Scott Rothstein, J. and I....M.. Case No.: 50200911.O.00XXXXMBAG Counter-Plaintiff's, JEER Amended Exhibit List | | vs. Scott Rothstein, J. and L.M. | | --- | ----------------------------------------------------------- | | | Marked Marked for | | | Objection le Evidence Identification | | | J. Amended Exhibit List | | 40 | Any and all newspaper articles, online articles or | | 41. | Report and Analysis of Jeffrey Epstein's assets. | | 42 | Video footage (DVD) of walk through site inspection of | | 43. | Photos of all of Jeffrey Epstein's properties, cars, toNand | | | planes. :0 | | 44. | Probable Cause Affidavits prepared agc ffri | | 46. | Victim Notification Letter fromIUS Attorney's | | 47. | Expert Dr. L. Dennison Report of Victim. | | 48 | Palm Beach Police Department Incident Report dated | | 50. | >114/ Witness Statements generated by Palm Beach | | 51. | Passenger Manifests of Jeffrey Epstein's aircraft and | | 52. | Passenger lists for flights taken by Jeffrey Epstein. | Jeffrey Epstein vs. Scott Rothstein, J. and L.M.. Case No.: 502009 ray tX CMBAG Counter-Plaintiff's, Amended Exhibit List | | vs. Scott Rothstein, J. and L.M. | | --- | -------------------------------------------------------- | | | Marked Marked for | | | Objection Evidence Identification | | 53. | Letter from Jeffrey Epstein to Alberto Pinto | | | regarding house island project. e ic | | 54. | Jeffrey Epstein's bank statements. | | 55. | Jeffrey Epstein's tax returns. | | 57. | DVD of plea and colloquy taken on 6-3 | | 58. | Transcript of plea and colloquy ta n -08. | | 59. | Massage Table. | | 60. | No Contact Orders entered against Jeffrey Epstein. | | 61. | Criminal Score Sheet regarding Jeffrey Epstein. | | 62 | Documents evidencing Jeffrey Epstein's | | 63. | JeffregtpstNt's Sex Offender Registrations (from various | | 64. | 71,efffey Epstein's Booking photograph. | | 66. | List of Jeffrey Epstein's House contacts. | | 67. | Documents related to Jeffrey Epstein's investments. | Jeffrey Epstein vs. Scott Rothstein, J. and L.M.. Case No.: 5020091.0/.1MBAG Counter-Plaintiff's, .1 Amended Exhibit List | Jeffrey Epstein vs. Scott Rothstein, [REDACTED] J. [REDACTED] and L.M.
Case No. 502009CA040800XXXXMBAG
Counter-Plaintiff's, [REDACTED] J. [REDACTED], Amended Exhibit List | | | | | | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ----------------------------------------------------------------------- | --------- | ------------------ | ------------------------- | | Counter-Plaintiff | | Objection | Marked in Evidence | Marked for Identification | | No. | Description of Exhibit | | | | | 68. | Letter from Chief Michael Reiter to Barry Krischler. | | | | | 69. | List of planes owned by Jeffrey Epstein. | | | | | 70. | Letter from Guy Fronstin to Assistant State Attorney dated 1-11-06. | | | | | 71. | Letter from Guy Fronstin to Assistant State Attorney dated 1-13-06. | | | | | 72. | Letter from Guy Fronstin to Assistant State Attorney dated 2-17-06. | | | | | 73. | Letter from Guy Fronstin to Assistant State Attorney dated 4-6-06. | | | | | 74. | Letter from Guy Fronstin to Assistant State Attorney dated 4-10-06. | | | | | 75. | Letter from Goldberger dated 6-22-06. | | | | | 76. | All subpoenas issued to State Grand Jury. | | | | | 77. | Documents related to the rental of a vehicle for [REDACTED] | | | | | 78. | Ted's Sheds Documents. | | | | | 79. | Documents related to property searches of Jeffrey Epstein's properties. | | | | | 80. | Arrest Warrant of [REDACTED] | | | | | 81. | Police report regarding [REDACTED] picking up money dated 11-28-04. | | | | Jeffrey Epstein vs. Scott Rothstein, J. and L.M.. Case No.: 502009a91O0.1111MBAG Counter-Plaintiff's, Amended Exhibit List | .Jeffrey Epstein Case No. No. 82. 83. 84. 85. 86. 87. 88. 89. | vs. Scott Rothstein, J. and L.M. 502009CA040800XXX X MBAG Counter-Plaintiff's, J. Amended Exhibit List Counter-Plaintiff Marked Marked for Description of Exhibit Objection in Evidence Identification List of Trilateral Commission Members of 2003. Aii Guy Fronstin letter dated 4-17-06. Jeffrey Epstein Account Information. Jeffrey Epstein Criminal Closeout Sheet. JEGE, Inc. Passenger Manifest. Hyperion Air Passenger Manifest. C c\\ Flight information for | | ------------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | | 90. | Passenger List Palm Beac 005. | | 91. | Jeffrey Epstein notep d not 'a. | | 92. | Pleadings of J oe 1 and 2 v. US case. | | 93. | Jeffrey E in 5 endment Speech. | | 94. | Rei er Krisher dated 5-1-06. | | 95. | Police Report dated 11-28-04. | | 96. | tim's school records and transcripts. | | 97. | Victim Notification letter dated 7-9-08. | | 98. | Police report of Juan Alessi theft at Jeffrey Epstein's home. | | 99. | Victim's Medical Records from Dr. Randee Speciale. | Jeffrey Epstein vs. Scott Rothstein, J. Case No.: 502009CA040g0 MBAG Counter-Plaintiff's, J Amended Exhibit List and L.M.. | Jeffrey Epstein vs. Scott Rothstein, [REDACTED] J. [REDACTED] and L.M.
Case No. 502009CA040800XXXXMBAG
Counter-Plaintiff's, [REDACTED] J. [REDACTED], Amended Exhibit List | | | | | | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | -------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------ | ----------- | -------------- | | Counter-Plaintiff | | Marked Marked for | | | | No. | Description of Exhibit | Objection | in Evidence | Identification | | 100. | All surveillance conducted by law enforcement on Jeffrey Epstein's home. | | | | | 101. | Emails received from Palm Beach Records related to Jeffrey Epstein. | | | | | 102. | All items listed on the Palm Beach Police Property Report Lists. | | | | | 103. | All copies of convictions related to Jeffrey Epstein. | | | | | 104. | Jeffrey Epstein criminal records. | | | | | 105. | All documents produced by Palm Beach Police Department prior to the deposition of Detective Recarey. | | | | | 106. | Statements, deposition transcripts, videotaped depositions and transcripts taken in connection with this and all related cases and exhibits thereto. | | | | | 107. | Any and all expert witness reports and/or records generated in preparation for this litigation by any party to this cause. | | | | | 108. | Demonstrative aids and exhibits including, but not limited to, charts, diagrams and models, surveys, photographs and similar material including blow-ups of the listed items/exhibits. | | | | | 109. | [REDACTED] reserves all objections to Epstein's Exhibits. | | | | | 110. | [REDACTED] reserves the right to supplement and/or amend his Exhibit List. | | | | Jeffrey Epstein vs. Scott Rothstein, J. and L.M.. Case No.: 5020091110 rBAG Counter-Plaintiff's, J Amended Exhibit List | Jeffrey Epstein vs. Scott Rothstein, [REDACTED] J. [REDACTED] and L.M.
Case No. 502009CA040800XXXXMBAG
Counter-Plaintiff's, [REDACTED] J. [REDACTED], Amended Exhibit List | | | | | | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------ | ------------------ | --------------------- | | Counter-Plaintiff | | Marked Marked for | | | | No. | Description of Exhibit | Objection | in Evidence | Identification | | 111. | By listing an Exhibit, [REDACTED] is not waiving his right to object to same at trial and does not waive their right to amend same. | | | | | 112. | All exhibits listed by Epstein subject to [REDACTED] objections. | | | | | 113. | All pleadings and attachments in the action under the Crime Victims Rights Act prosecuted by [REDACTED] on behalf of victims of Epstein's criminal molestations. | | | | | 114. | [REDACTED] Motions for Summary Judgment, all attachments thereto and all Undisputed Facts. | | | | | 115. | All time records and hourly billing documentation produced in discovery. | | | | | 116. | All deposition testimony and discovery responses by Epstein submitted in this action. | | | | | 117. | All pleadings filed by Epstein in the Rothstein bankruptcy proceeding. | | | | | 118. | All submissions by Epstein in connection with the Rothstein deposition. | | | | | 119. | All Settlement Agreements between Epstein and victims of his sexual molestations. | | | | | 120. | Phone Journal taken from Epstein's home and produced to the FBI by Alfredo Rodriguez. | | | | | 121. | Photo depicting [REDACTED], Ghislaine Maxwell and Prince Andrew. | | | | Jeffrey Epstein vs. Scott Rothstein, J. and L.M.. Case No.: 502009Q1120=414. MBAG Counter-Plaintiff's, J Amended Exhibit List | Jeffrey Epstein vs. Scott Rothstein, [REDACTED] J. [REDACTED] and L.M.
Case No. 502009CA040800XXXXXMBAG
Counter-Plaintiff's, [REDACTED] J. [REDACTED], Amended Exhibit List | | | | | | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ------------------------ | ----------- | -------------- | | Counter-Plaintiff | | Marked Marked for | | | | No. | Description of Exhibit | Objection | In Evidence | Identification | | 122. | All flight logs for any Epstein owned or controlled aircraft | | | | | 123. | All emails produced by Defendant and/or all emails produced by Plaintiff in this case. | | | | | 124. | Evidence of contributions to the Palm Beach Police Dept. | | | | | 125. | Dr. Bernard J. Jansen Expert Report, Attachments and Back-up Documents, October 20, 2017. | | | | | 126. | Jeffrey Epstein vs. Scott Rothstein, Bradley J. Edwards and L.M., Complaint, December 7, 2009. | | | | | 127. | Jeffrey Epstein vs. Scott Rothstein, [REDACTED] J. [REDACTED] and L.M, Fourth Amended Counterclaim, January 9, 2013. | | | | | 128. | Jeffrey Epstein vs. Scott Rothstein, [REDACTED] J. [REDACTED] and L.M, Plaintiff/Counter-Defendant Jeffrey Epstein's Answer and Affirmative Defenses to Defendant/Counter-Plaintiff [REDACTED] [REDACTED] Fourth Amended Counterclaim, February 21, 2013. | | | | | 129. | Jeffrey Epstein vs. Scott Rothstein, [REDACTED] J. [REDACTED] and L.M, Notice of Voluntary Dismissal, August 16, 2012. | | | | | 130. | Brad Edward's Times Records and Billing Records related to this matter. | | | | | 131. | Jeffrey Epstein's NY State Online Sex Offender Registry Profile. | | | | | 132. | New York Post article: Billionaire Jeffrey Epstein: I'm a sex offender, not a predator, February 25, 2011 | | | | Jeffrey Epstein vs. Scott Rothstein, J. and L.M.. Case No.: 50200911.0.011111MBAG Counter-Plaintiff's, Amended Exhibit List | | vs. Scott Rothstein, I and L.M. | | ---- | ------------------------------------------------------------ | | | Marked Marked for | | | Objection If Evidence Identification | | | J. Amended Exhibit List | | 133. | Any and all responses to Subpoenas Duces Tecum with or | | 135. | Any and all documents produced in this action. | | 136. | Any and all depositions taken in this action. | | 137. | Any documents or other exhibit attach during | | 138. | Any and all exhibits, documen t . rred to in any | | 139. | Any and all documents and exhibits designated by all parties | | 140. | Any and all exhibits needed for impeachment or rebuttal. | | 141. | Any and all pleadings filed in this action. | | 142. | Any and all records produced or that will be produced by all | Jeffrey Epstein vs. Scott Rothstein, [REDACTED] J. [REDACTED] and L.M..\ Case No.: 502009CA040800XXXXXMBAG\ Counter-Plaintiff's, [REDACTED] J. [REDACTED], Amended Exhibit List I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve\ to all Counsel on the attached list, this 9th day of November, 2017. ![](<>)Jack Scarola\ Florida Bar No.: 169440\ Attorney E-Mail(s): jsx@searcylaw.com and\ mep@searcylaw.com\ Primary E-Mail: scarolateam@searcylaw.com\ Searcy Denney Scarola Barnhart & Shipley, P.A.\ 2139 Palm Beach Lakes Boulevard\ West Palm Beach, Florida 33409\ Phone: (561) 686-6300\ Fax: (561) 383-9451\ Attorneys for [REDACTED] J. [REDACTED] NOTA CERTIFY Jeffrey Epstein vs. Scott Rothstein, J. and L.M.. Case No.: 502009Calif0g2MOMBAG Counter-Plaintiff's, J Amended Exhibit List #### COUNSEL LIST Jack Semis, Esquire \_scarolateam@searcylaw.com; Seamy Denney Scarola Barnhart & Shipley PA 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorneys for J. Scott J. Link, Esq. Link & Rockenbach, P.A. ScottalinIcrocklaw.com Rara l inkrocklaw.com 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, FL 33401 Phone: 561-727-3600 Fax: 561-727-3601 Attorneys for Jeffrey Epstein William Chester = Esq wcblaw@aol.com; wcblawass 250 S Australian Avenu uite 1400 West Palm Beach, FL 33 Phone: (561)-65:601c m Fax: (561)-835- Attorneys fo Go Jack A er, Esquire jgoldbe gwpa.com; smahoney@agwpa.com Atterbury oldberger & Weiss, P.A. 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Jeffrey Epstein vs. Scott Rothstein, [REDACTED] J. [REDACTED] and L.M..\ Case No.: 502009CA040800XXXXMBAG\ Counter-Plaintiffs, [REDACTED] J [REDACTED], Amended Exhibit List [REDACTED] J. [REDACTED], Esquire\ staff.efile@pathtojustice.com\ Farmer Jaffe Weissing [REDACTED] Fistos & Lehrman, P.L.\ 425 N Andrews Avenue, Suite 2\ Fort Lauderdale, FL 33301\ Phone: (954)-524-2820\ Fax: (954)-524-2822 Tonja Haddad Coleman, Esquire\ tonja@tonjahaddad.com; efiling@tonjahaddad.com\ Tonja Haddad, P.A.\ 315 SE 7th Street, Suite 301\ Fort Lauderdale, FL 33301\ Phone: (954)-467-1223\ Fax: (954)-337-3716\ Attorneys for Jeffrey Epstein Marc S. Nurik, Esquire\ marc@nuriklaw.com\ One E Broward Blvd., Suite 700\ Fort Lauderdale, FL 33301\ Phone: (954)-745-5849\ Fax: (954)-745-3556\ Attorneys for Scott Rothstein NOT A CERTIFIED COPY **APP. 34** NOT A CERTIFIED COPY #### IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN individually, and J. individually, Defendants/Counter-Plaintiff. #### PLAINTIFF/COUNTER-DEFENDANT'S 0 TO DEFENDANT/ COUNTER-PLAINTIFF'S AMEND EXHIBIT LIST PlaintifVCounter-Defendant, Jeffrey Defendant/Counter-Plaintiff, J. Ed the following Objections to nded Exhibit List dated November 9, 2017: #### LEGEND FOR OBJECTIONS: I — All Objections 2 — All Objections except Auth tici 3 - Relevance 4 — Probative value subs misleading the jury, r n 5 — Privileged k 6 - Opinion 7 — Hearsa 8 — Authe 9 — O e identify basis of objection) 10 — Com teness 11 — Overbroad 12 — Not provided to Counsel for Epstein Prior to Filing Pretrial Stipulation 13 — Not a proper exhibit 14 — Trade secrets/Confidential outweighed by danger of unfair prejudice, confusion of issues, presentation of cumulative evidence | No. 1. 2. 3. 4. 5. 6. 7. | All applicable criminal statutes All applicable Florida Statutes Photos and information of Jeffrey Epstein's homes, airplanes and automobiles Order confirmation from Amazon.com for purchase of books "SM 101: A realistic Introduction," "Slave Craft: Roadmap for Erotic Servitude-Principles, Skills and Tools" and "Training Miss Abernathy: A Workbook for Erotic Slaves and Their Owners" Non-Prosecution Agreement Jane Doe 102 Complaint Messages taken from message pads found at Epstein's | Exhibit Description Epstein's Objections 3,4, 7, 11, 12 3,4, 7, 11, 12 3, 4, 7, 8, 10, 12 3, 4, 7, 8 '0 3 3, ,7, 8, 11,14 | | ------------------------ | ----------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | --------------------------------------------------------------------------------------------------------------------------- | | 8. | Documents related to Jeffrey Epstein produced b home Rodriguez | 14 3, 4, 7, 8, 11, 14 | | 9. | Jeffrey Epstein flight logs | 3, 4, 7, 8, 10, 11 \\ | | 10. | Jeffrey Epstein phone records | 3, 4, 10, 11, 14 | | 11. | phone records | 3, 4, 8, 10, 11 14 | | 12. | Jail Visitation Logs | 3, 4, 7, 8, 11 | | 13. | Jeffrey Epstcin's probati le | 3, 4, 7, 8, 11 | | 14. | All probable cause a avi investigation ofJeffrexptein | ated to criminal 3, 4, 7, 8, 10 | | 15. | Victims' state i ents to t e FBI related to criminal | 3, 4, 7, 8 | | | investigation o lif y Epstein | | | 16. | Video of Search executed . | arrant of Jeffrey Epstein's home being 3, 4, 8 | | 17. | Ap 'on 1rN C:5 t Jane Doe v. Epstein and all subsequent ded Complaints | Search Warrant of Jeffrey Epstein's home 3, 4, 7, 8, Cannot be read 3, 4, 7, 13, 12 (as to "subsequent Amended Complaints") | | 19. | II records of homes, properties, bank accounts and any/ all records related to Jeffrey Epstein's assets | | | 20. | Jeffrey Epstein's passport (or copy) | 12 | | 21. | Jeffrey Epstein's driver's license (or copy) | Cannot be read, 3, 14 | | 22. | List of corporations owned by Jeffrey Epstein | 3, 4, 7, 8, 12 | | 23. | Yearbooks of Jane Doe | 3, 4, 7, 8, 12 | | No. | [REDACTED] Exhibit Description | Epstein's Objections | | --- | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------ | -------------------------------------------------------------------------------------------------------------- | | 24. | 2002 [REDACTED] Palm Beach High School Year Book | 3, 4, 7, 8, 12 | | 25. | 2001 [REDACTED] Palm Beach High School Year Book | 3, 4, 7, 8, 12 | | 26. | 2003 Palm Beach Gardens High School Year Book | 3, 4, 7, 8, 12 | | 27. | Affidavit and Application for Search Warrant on Jeffrey Epstein's home | 3, 4, 7, 8, 10, | | 28. | Notepads found in Jeffrey Epstein's home and/or during trash pulls outside of his home during criminal investigation | 3, 4, 7, 8, 10, 11, 14 | | 29. | The Palm Beach State Attorney's Criminal file against Jeffrey Epstein | 3, 4, 6, 7, 8, 10, 11, 13 | | 30. | All documents related to Jeffrey Epstein's 6/30/08 conviction | 3, 4, 7, 8, 12 | | 31. | Jeffrey Epstein's criminal plea colloquy | 3, 4, 7, 8, 12 | | 32. | List of properties and vehicles in Larry Visoski's name | 3, 4, 7, 8, 11, 13, The exhibit provided was an entire Motion (which was denied) not just the identified item. | | 33. | All of Jeffrey Epstein's Responses to Requests for Production, Requests for Admission, Answers to Interrogatories in this matter, and cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 | 3, 4, 11, 12, 13 | | 34. | All discovery related responses of Jeffrey Epstein in this matter and cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 | 3, 4, 11, 12, 13 | | 35. | Jeffrey Epstein's Answers and Affirmative Defenses in all civil cases against him | 3, 4, 11, 12, 13 | | 36. | All Complaints in which Jeffrey Epstein is/was a plaintiff or defendant | 3, 4, 11, 12, 13. This also includes a motion which is not part of the stated exhibit. | | 37. | Jeffrey Epstein's Deposition testimony and discovery responses in this case and cases 08-80119, 08-80232, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 | 3, 4, 11, 12, 13 | | 38. | Jeffrey Epstein's Deposition testimony and discovery responses in State Court cases LM v. Jeffrey Epstein, Case No. 502008CA028051XXXXIMB AB and E.W. v. Jeffrey Epstein, Case No. 502008CP003626XXXXMB | 3, 4, 11, 12, 13 | | No. | Exhibit Description | Epstein's Objections | | --- | -------------------------------------------------------------- | ---------------------- | | 39. | Jeffrey Epstein Deposition Testimony and discovery | | | 40. | Any and all newspaper articles, online articles or | | | 41. | Report and Analysis of Jeffrey Epstein's assets | 3, 4, 7, 8, 14 | | 42. | Video footage (DVD) of walk through site inspection of | | | 43. | Photos of all of Jeffrey Epstein's properties, cars, boats and | | | | | cars boats) | | 44. | Probable Cause Affidavits prepared against Jeffrey Epstein | | | 45. | Documents related to or evidencing Jeffrey Epstein's | | | | | 3, , 8, 10 | | 46. | Victim Notification Letter from US Attorney's Off | | | 47. | Expert Dr. L. Dennison Report of Vic ' | 3, 4, 6, 7, 8, 14 | | 48. | Palm Beach Police Department Incident | | | 49. | All reports and documentation gen ffiti aim Beach | | | | Police Department related to Je sto n | | | | All Witness Statements gene b m Beach Police | | | | Department relating to Je y | | | 51. | Passenger Manifests of stein's aircraft and | | | 52. | Passenger lists for fl is ken by Jeffrey Epstein | 3, 4, 7, 8, 10, II, 12 | | 53. | Letter from Je to Alberto Pinto regarding | | | | house isla d .r. : t | | | 54. | Jeffrey : 41 I .ank statements | 3, 4, 7, 8, 12, 14 | | 55. | Jere' s 's tax returns | 3, 4, 7, 8, 12, 14 | | 56. | ails involving communications of Jeffrey Epstein, | | | 57. | DVD of plea and colloquy taken on 6-30-08 | 3, 4, 8, 12, 13 | | 58. | Transcript of plea and colloquy taken on 6-30-08 | 3, 4, 13 | | 59. | Massage Table | 3, 4, 12 (document | | 60. | No Contact Orders entered against Jeffrey Epstein | 3, 4, 13 | | No. | Exhibit Description | Epstein's Objections | | --- | ---------------------------------------------------------- | --------------------------- | | 61. | Criminal Score Sheet regarding Jeffrey Epstein | 3, 4, 7, 8, 12 | | 62. | Documents evidencing Jeffrey Epstein's Community | | | 63. | Jeffrey Epstein's Sex Offender Registrations (from various | | | 64. | Jeffrey Epstein's Booking photograph | 3, 4, 7, 8, Document says | | 65. | CAD calls to 358 EL BRILLO WAY, PALM BEACH FL | | | 66. | List of Jeffrey Epstein's House contacts | 3 , 2 (document | | | | of cription) | | 67. | Documents related to Jeffrey Epstein's investments | , 7, 8, 12, 14 | | 68. | Letter from Chief Michael Reiter to Barry Krischl | 3, 4, 7, 8 | | 69. | List of planes owned by Jeffrey Epstein | 3, 4, 7, 8, 12 (document | | 70. | Letter from Guy Fronstin to Assista | omey dated | | 71. | Letter from Guy Fronstin to | ' to Attorney dated | | 72. | Letter from Guy Fronsti o | nt State Attorney dated | | 73. | Letter from Guy Fro tint | istant State Attorney dated | | 74. | Letter from G nstin to Assistant State Attorney dated | | | 75. | Letter Gol erger dated 6-22-06 | 3, 4, 7, 8 | | 76. | AI | | | | e issued to State Grand Jury | 3, 4, 7, 8, 13 | | 77. | b i 111 | | | | is related to the rental of a vehicle for | 3, 4, 7, 8, document | | 78. | Ted's Sheds Documents | 3, 4, 7, 8, document | | 79. | Documents related to property searches of Jeffrey | | | 80. | Arrest Warrant of | 3, 4, 7, 8 | | No. | Exhibit Description | Epstein's Objections | | --------------------------------------------------------- | ---------------------------------------------------------- | ------------------------------- | | 81. | Police report regarding | picking up money 3, 4, 7, 8, 10 | | 82. | List of Trilateral Commission Members of 2003 | 3, 4, 7, 8, 10 | | 83. | Alan Dershowitz Letter dated 4-19-06 and Statute 90.410 | 3, 4, 7, 8, 12 | | 84. | Guy Fronstin letter dated 4-17-06 | 3, 4, 7, 8 | | 85. | Jeffrey Epstein Account Information | 3, 4, 7, 8, 12 14 | | 86. | Jeffrey Epstein Criminal Closeout Sheet | 3, 4, 7, 8 | | 87. | JEGE, Inc. Passenger Manifest | 3, 4 0, 11 | | 88. | Hyperion Air Passenger Manifest | i 3 , 7, 10, I1 | | 89. | Flight information for | 3, 7, 8, 10, 11 | | 90. | Passenger List Palm Beach flights 2005 | 3, 4, 7, 8, 10, I 1 | | 91. | Jeffrey Epstein notepad notes.maria | 3, 4, 7, 8, 10, 12 | | 92. | Pleadings of Jane Doe 1 and 2 v. US cases \\ , | 3, 4, 12 (document | | 93. | Jeffrey Epstein 51h Amendment S | 'l\\ 3, 4, 12 | | 94. | Reiter letter to Krisher dated | 3, 4, 7, 8, 12 | | 95. | Police | 11-28-04 3, 4, 7, 8, 10 | | 96. | Victim's school rec ds an | nscripts 3, 4, 7, 8 | | 97. | Victim Notification le dated 7-9-08 | 3, 4, 7, 8 | | 98. | Police report of ar Alessi theft at Jeffrey Epstein's home | 3, 4, 7, 8, 12 | | 99. | Victi s edica Records from Dr. Randee Speciale | 3, 4, 6, 7, 8 | | 100. Al su | conducted by law enforcement on Jeffrey | | | | ' ' home | | | 1 | 'Is received from Palm Beach Records related to | | | 103. All copies of convictions related to Jeffrey Epstein | | 3, 4, 7, 8, 12 | | 104. Jeffrey Epstein criminal records | | 3, 4, 7, 8, 12 | | No. | Exhibit Description Epstein's Objections | | ----------------------------------------------------------------- | ---------------------------------------- | | 109. reserves all objections to Epstein's Exhibits | Not ibit | | 110. reserves the right to supplement and/or amend his | N 'bit | | 111. By listing an Exhibit, | is not waiving his right to No exhibit | | 112. All exhibits listed by Epstein subject to | Not an exhibit | | 113. All pleadings and attachments in the actio | a | | Crime Victims Rights Act prosecuted b | I wards | | on behalf of victims of Epstein's crim | lestations. | | 114. Motions for Summary J | I attachments 3, 4, 7, 8, 12, 13 | | 115. All time records and hourly | ' d mentation | | 116. All deposition testimo | overy responses by | | Epstein submitted in | is a t n. | | 117. All pleadings filed b | in in the Rothstein bankruptcy | | 118. All submissio | in connection with the | | Rothste' cposi ' n. | | | hi I molestations. | | | 120. rnal taken from Epstein's home and produced to | | | 121 oto depicting | Ghislaine Maxwell and 3, 4, 7, 8 | | 122. All flight logs for any Epstein owned or controlled aircraft | 3, 4, 7, 8, 10, 11, 12 | | 124. Evidence of contributions to the Palm Beach Police Dept. | 3, 4, 7, 8, 10 duplicative | | No. | Exhibit Description Epstein's Objections | | ------------------------------------------------------------- | ---------------------------------------------------- | | 126. Jeffrey Epstein vs. Scott Rothstein, | J. and | | 127. Jeffrey Epstein vs. Scott Rothstein, | J. and 3, 4, 7, 13 | | L.M., Fourth Amended Counterclaim Jan | 9 2013 | | 128. Jeffrey Epstein vs. Scott Rothstein, | J. and 3, 4, 7, 13 | | Answer an Affirmative | to Defendant/Counter | | Plaintiff | Fourth Amended | | 129. Jeffrey Epstein vs. Scott Rothstein, | J. and O 14C ' ' | | | 3, 7, 8, 10, 12 | | 131. Jeffrey Epstein's NY State Online Sex Offender | 's | | 132. New York Post article: Billionaire Jeffrey E | a | | 133. Any and all responses to Subpoenas | with or | | 134. All Interrogatories and | to, Requests to | | Produce and Responses | or Admissions and | | 135. Any and all docume | pro ced in this action. 12 | | 136. Any and all de | tions taken in this action. 12 (document provided is | | 137. Any d 4" nts or other exhibit attached to or used during | | | an d • iti n in this action | | | 1 314 and all exhibits, documents, etc. referred to in any | | | 140. Any and all exhibits needed for impeachment or rebuttal | 12 (document provided is | | No. | [REDACTED] Exhibit Description | Epstein's Objections | | ---- | ------------------------------------------------------------------------------------------------------- | ----------------------------------------------------------- | | 141. | Any and all pleadings filed in this action | 12 (document provided is not reflective of description), 13 | | 142. | Any and all records produced or that will be produced by all records custodians relative to this action | 12 (document provided is not reflective of description), 13 | #### CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the atto Service List below on November 15, 2017, through the Court's e-filing Rule of Judicial Administration 2.516(bX1). ed on the t to Florida > LINK & ROCKEN 1555 Palm Beac West Palm B (561) 727- C Boulevard, Suite 301 da 33401 727-3601 [fax] By./ Link (FBN 602991) erard Rockenbach (FBN 44903) gela M. Many (FBN 26680) rimary: Scott@linIcrocIdaw.com Primary: Kara(41inkrocklaw.com Primary: Angelaelinkrocklaw.com Secondary: Tinaelinkrocklaw.com Secondary: Troy@linkrocklaw.com Secondary: TanyaQiinIcrocklaw.com Secondary: EserviceOlinIcrocklaw.com Trial Counsel for PlaintiffiCounter-Defendant Jeffrey Epstein #### SERVICE LIST |

Jack Scarola
Searcy, Denny, Scarola, Barnhart & Shipley, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, FL 33409
mep@searcylaw.com
jsx@searcylaw.com
scarolateam@searcylaw.com
Co-Counsel for Defendant/Counter-Plaintiff

|

Nichole J. Segal
Burlington & Rockenbach, P.A.
Courthouse Commons, Suite 350
444 West Railroad Avenue
West Palm Beach, FL 33401
njs@FLAppellateLaw.com
kbt@FLAppellateLaw.com
Co-Counsel for Defendant/Counter-Plaintiff

| | ------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | ---------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------------- | |

J. [REDACTED]
Pottinger LLC
425 N. Andrews Avenue, Suite 2
Fort Lauderdale, FL 33301-3268
brad@epllc.com
staff.efile@pathtojustice.com
Co-Counsel for Defendant/Counter-Plaintiff

|

Marc S. Nurik
Law Offices of Marc S. Nurik
One E. Broward Boulevard, Suite 700
Ft. Lauderdale, FL 33301
marc@nuriklaw.com
Counsel for Defendant Scott Rothstein

| |

Tonja Haddad Coleman
315 S.E. Seventh Street, Suite 301
Ft. Lauderdale, FL 33301
tonja@tonjahaddad.com
efiling@tonjahaddad.com
Co-Counsel for Plaintiff/Counter-Defendant
Jeffrey Epstein

|

Fred Haddad
Haddad & Navarro, PLLC
1 Financial Plaza, Suite 2612
Fort Lauderdale, FL 33394
dee@haddadandnavarrolaw.com
Co-Counsel for Plaintiff/Counter-Defendant
Jeffrey Epstein

| |

Jack A. Goldberger
Atterbury, Goldberger & Weiss, P.A.
250 Australian Avenue S., Suite 1400
West Palm Beach, FL 33401
jgoldberger@agwpa.com
smahoney@agwpa.com
Co-Counsel for Plaintiff/Counter-Defendant
Jeffrey Epstein

| | **APP.35** NOT A CERTIFIED COPY #### IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800MaMBAG JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN individually, J. individually, and L.M., individually, Defendant, Cos #### SEVENTH AMENDED AND SUPPL WITNESS LIST OF COUNTER-PLAINTIFF J. Counter-Plaintiff, J. ED 1l5, and through his undersigned attorneys, hereby supplements his list of witnesses trial follows: ## WITNESS ED TO BE PRESENTED - 1. Bradley J. Ed 2.. Jeffrey E - 3. o tephenson - W. Peachtree Street ta, Georgia 30339 - 4. do Erica Dubno 767 Third Avenue, Suite 3600 New York, New York 10017 - 5. Guiffre do Stan Pottinger 49 Twin Lakes Road, Suite 100 South Salem NY 10590 Case No.: 502009CA040800000CMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff J. Page 2 of 22 - 6. - 7. - 8. - 9. IIIMguis, Esq. Mintz & Gold LLP 600 Third Avenue, 25'h Floor, New York 10016 do Peter Guirguis, Esq. Mintz & Gold LLP 600 Third Avenue, 25'h Floor, New York, 10016 13701 Riverside Drive, Suite 800 Sherman Oaks, CA 91423-2449 do Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd Avenue, S 700 Miami, FL 33131 - 10. Robert C. Jose Podhurst Orsec One S.E. rd Aven Suite 2700 Miami, FL - 11. +12. Chief Michael Reiter Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 Dikieti Joseph Recarey ch Police Department uth County Road Beach, FL 33480 - 13. Johncmolly do = & Schuster 1230 6th Avenue New York, New York 10020 ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff J. Page 3 of 22 - 14. Charles Lichtman, Esquire Berger Singerman 300 East Las Olas Boulevard, Suite 1000 Fort Lauderdale, FL 33301 - 15. do Adam Horowitz. Horowitz Law 425 North Andrews Avenue, Suite 2 Fort Lauderdale FL 33301 - 16. Antonio Figueroa (Tony) Palm Coast, Florida - 17. Records Custodian of Palm Beach Police DepartMent 345 South County Road Palm Beach, FL 33480 - 18. Records Custodian of United States Attorney's Office for the Southern District of Florida - 19. Records Custodian of the Federal Bureau of Investigations - 20. Spencer Kuvin, Esquire 1800 S. Australian Avenue, #400 West Palm Beach, Florida 33409 - 21. Theodore Leopold, Esquire Milstein 1 2925 PGA Boulevard, Suite 200 'Palm Beach Gardens, Florida 33410 22."r Rinaldo Rizzo do Robert 228 East 45th Street 117th Floor New York, NY 10017 - 23. Adam Horowitz, Esquire 425 N. Andrews Ave., Suite 2 Ft. Lauderdale, FL 33301 [REDACTED] ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Page 4 of 22 24. Isidro M. [REDACTED], Esquire\ [REDACTED] Law Firm, P.A.\ 224 Datura Street, Suite 900\ West Palm Beach, FL, 33401 01. Earleen Cote, Esquire\ Kubicki Draper\ One East Broward Boulevard, Suite 1600\ Fort Lauderdale, FL 33301 01. Bernard J. Jansen, Ph.D.\ c/o Jack Scarola\ Searcy Denney Scarola Barnhart & Shipley\ 2139 Palm Beach Lakes Blvd.\ West Palm Beach, FL 33409 01. William Berger, Esquire\ Weiss, Handler, Cornwell, P.A.\ 2255 Glades Road, Suite 218A\ Boca Raton, FL 33431 **WITNESSES WHICH MAY BE CALLED IF THE NEED ARISES** 28. [REDACTED] 29. Landon Thomas\ c/o New York Times\ 620 Eighth Avenue\ New York, NY 10018 01. Oren Kramer\ c/o Boston Provident, L.P.\ 717 5th Avenue #12A\ New York, NY 10022 01. Lawrence LaVecchio\ United States Attorney's Office, Southern District of Florida\ Broward Financial Center\ Fort Lauderdale, Florida [REDACTED] ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Page 5 of 22 32. [REDACTED] c/o Adam Horowitz. Horowitz Law 425 North Andrews Avenue, Suite 2 Fort Lauderdale FL 33301 33. Evgenia Ignatieva 1650 Broadway, #910 New York, NY 10019 34. [REDACTED] 35. [REDACTED] c/o Adam Horowitz. Horowitz Law 425 North Andrews Avenue, Suite 2 Fort Lauderdale FL 33301 36. [REDACTED] c/o Jack Scarola Searcy Denney Scarola Barnhart & Shipley 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 37. [REDACTED] c/o Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd Avenue, Suite 2700 Miami, FL 33131 38. Brandy Brenson c/o Spencer Kuvin 1800 South Australian Ave #400 West Palm Beach, Florida, 33409 39. [REDACTED] c/o Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd Avenue, Suite 2700 Miami, FL 33131 Case No.: 502009CAG40800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff J. Page 6 of 22 40. do Spencer Kuvin 1800 South Australian Ave #400 West Palm Beach, Florida, 33409 01. William Scherer, Esquire 633 S Federal Hwy #800 Fort Lauderdale, FL 33301 CO 42. Paul Cassell, Esq. 383 S. University Street Salt Lake City Utah, UT 84112 43. c/o Adam Horowitz. Horowitz Law 425 North Andrews Avenue, Suit\\ Fort Lauderdale FL 33301 S\\4 ' ):49 44. 01. do Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd Avenue, Suite 2700 Miami, FL 33131 01. co oert . Josefsberg, Esq. 7 " -Podhurst Orseck, PA One S.E. 3rd Avenue, Suite 2700 Miami, FL 33131 01. do Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd Avenue, Suite 2700 Miami, FL 33131 Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff J. Page 7 of 22 - 48. Prince Andrew Albert Christian Edwards Duke of York, Buckingham Palace Road London SW1A 1 AA - 49. Frederic Fekkai Address Currently Unknown - 50. do Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd Avenue, Suite 2700 Miami, FL 33131 - 51. Lesley Groff do Mike 1114 Avenue of the Americas New York, NY 10036 - 52. Dave Rogers do Bruce Reinhart 505 S. Flagler Drive, West Palm Beach, F 934gt a mir St - 53. - 54. do Adam Horo Horowitz 425 North Fort --uderilale FL 33301 Avenue, Suite 2 o rt Josefsberg, Esq. A711\\ urst Orseck, PA e S.E. rAvenue, Suite 2700 Miami, FL 33131 - 55. Meagan Dorshel do Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd Avenue, Suite 2700 Miami, FL 33131 Case No.: 502009CA040800,OOOCMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff J. Page 8 of 22 - 56. do Adam Horowitz. Horowitz Law 425 North Andrews Avenue, Suite 2 Fort Lauderdale FL 33301 - 57. do Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd Avenue, Suite 2700 Miami, FL 33131 - 58. Tod Meister 101 Seminole Avenue Palm Beach, FL 38480 - 59. - 60. c/o Robert C. Josefsberg, Esq. Podhurst Orseck, PA One S.E. 3rd Avenue, Suite 2 Miami, FL 33131 do Robert C. Jopt6fsbeti Esq. Podhurst Orsec One S.E. akdsirnu e, Suite 2700 Miami, FL 131 - 61. do Spencer Kuvin 1800 South Australian Ave 4400 est Palm Beach, Florida, 33409 - 62. do Marshall Dore Louis 40 NW third Street, Suite 200 Miami, FL 33128 - 63. Jason Richards Federal Bureau of Investigation 16320 NW 2s AVE., Miami, FL 33169 Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Page 9 of 22 - 64. - 65. - 66. - 67. - 68. Esq. Po Pottinger LLC 425 North Andrews Avenue, Suite 2 Fort Lauderdale FL 33301 = Esq. Pottinger LLC 425 North Andrews Avenue, Suite 2 Fort Lauderdale FL 33301 do Adam Horowitz. Horowitz Law 425 North Andrews Avenue, Suite 2 Fort Lauderdale FL 33301 do Adam Horowitz. Horowitz Law ?s, 425 North Andrews \*fte 2 Fort Lauderdale do Adam Horowitz 425 North Andrews Avenue, Suite 2 F uderdale FL 33301 69., Kurkendall eral Bureau of Investigation 6320 NW rd Ave. Miami, FL 33169 - 70. do Isidro M. Law Firm, P.A. 224 Datura Street, Suite 900 West Palm Beach, FL, 33401 J. COSA Case No.: S02009CA040800)OOOCMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Page 10 of 22 71. Igor Zinoview Address Currently Unknown 01. Address Currently Unknown 01. 9 East 71 Street New York, NY 10021 OS A 74. Seth Lehrman 425 North Andrews Ave., Suite 2 C.) Fort Lauderdale, FL 33301 may ) 425 North Andrews Ave., Suite 2 75. Matt Weissing Fort Lauderdale, FL 33301 76. Maria Villafana 500 S. Australian Avenue, # West Palm Beach, FL 3 01. Any additional ind Office and who supplied as it rel entified as victims by the United States Attorney's were conveyed to Jeffrey Epstein as part of a list the NPA. irni Parkway 78. Leslie We us, Ohio 43206 A...\\ 79. 2 ent Donald J. Trump •Alan Garten, Esq. 5 Fifth Avenue New York, NY 10022 80. Larry Visoski 1131 Pine Point Road Riviera Beach, FL 33401 01. Maritza Vasquez 1293 SW 21' Terrace Miami, FL 33145 [REDACTED] ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Page 11 of 22 82. Maximilia [REDACTED]\ c/o William Unroch, Esquire\ 140 West End, Apt. 30-BW\ New York, NY 10023 01. [REDACTED]\ c/o Spencer Kuvin\ 1800 S. Australian Avenue, #400\ West Palm Beach, Florida 33409 01. [REDACTED]\ 2915 Share Rd. 111\ Tallahassee, FL 31312 01. [REDACTED]\ c/o Robert C. Josefsberg, Esq.\ Podhurst Orseck, PA\ One S.E. 3rd Avenue, Suite 2700\ Miami, FL 33131 01. David Copperfield (David Seth Kokin)\ 11675 Glowing Sunset Lane\ Las Vegas, NV 89135 01. [REDACTED] 01. Michael Fisten\ Weston, FL 01. [REDACTED] Adler\ Delray Beach, FL 01. [REDACTED] Alessi\ 6791 Fairway Lakes Dr.\ Boynton Beach, FL 33472 01. Janusz Banasiak\ 358 El Brillo Way\ Palm Beach, FL, 33480 - 96. Rosalie 53320 Avenida Madero La Quinta, CA 92253 - 97. Valdson Cotrin Address Currently - 98. - 99. V 1.11.1 nknown, South Africa - 100. Dubin 040 5th Ave. Unit 15A New York, NY 10028-0137 - 101. Abigail Wexner Three Limited Parkway Columbus, Ohio 43206 - 102. Officer Munyan Palm Beach Police Department 345 South County Road - 92. Beata Banasiak 358 El Brillo Way Palm Beach, FL, 33480 - 93. Juan Alessi 6791 Fairway Lakes Dr. Boynton Beach, FL 33472 - 94. Michael 53320 Avenida Madero La Quinta, CA 92253 - 95. Jerry Goldsmith 13285 Silver Fox Lane S) West Palm Beach, FL 33418-7942 ,' Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Page I2 of 22 Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff J. Page I.3 of 22 Palm Beach, FL 33480 - 103. Officer Minot Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 - 104. Sgt. Sorge Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 - 105. Address Currently Unknown - 106. Joseph Pagnano iS 4/) 9 1217 S Flagler Drive, Suite 301 West Palm Beach, FL 33401 - 107. Stephan Kosslyn 28 Garfield Street Cambridge, MA 0213 - 108. Cecile Dejongh ( A" 23 8 Estate Mafolieoy St. Thomas VI 008 - 109. Tommy Mottola 302 Caribbean Road Clint Beach, FL 33480-3012 - il - 110. ike Sanka 49 S Beverly Drive, Suite 101 Beverly Hills, CA 90212 - 112. William "Bill" 5645 Coral Ridge Drive II 391 Coral Springs, FL 33076 A44. CO Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff J. Page 14 of 22 - 113. Howard Rubenstein 1345 Avenue of the Americas New York, NY 10105 - 114. Robert Meister 101 Seminole Ave. Palm Beach, FL 33480 - 115. Todd Meister 101 Seminole Ave Palm Beach, FL 33480 - 116. President William J. Clinton - 117. William Hammond 2965 Fontana Place Palm Beach, FL - 118. Robert Roxburgh 5600 North Flagler Dr, #250 West Palm Beach, Flori - 119. Michele Pagan Palm Beach Pol. 345 South Count Road Palm Bea ent - 120. Michele Da son Palm Beach Police Department 45 South County Road a Beach, FL 33480 my Fortimer 12309 North Old Country Road Wellington, FL 33414 122. [REDACTED] ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Page 15 of 22 123. [REDACTED] 124. [REDACTED] 125. [REDACTED] 126. Latasha Lowe\ c/o Adam Horowitz.\ Horowitz Law\ 425 North Andrews Avenue, Suite 2\ Fort Lauderdale FL 33301 001. [REDACTED] 128. Zack Bryan\ 1150 Larch Way\ Wellington, Florida 001. [REDACTED] 130. Larry Morrison\ 11148 Cobblefield Dr..\ Wellington, FL 33449 001. Story Cowles\ 801 S Olive Ave., Unit 201S\ West Palm Beach, FL 33401 001. Michael Dawson\ Palm Beach Police Department\ 345 South County Road\ Palm Beach, FL 33480 ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 16 of 22 - 133. Salaam Kahlid Monroe 119 Menores Ave., Apt. 3 Coral Gables, FL 33134 - 134. Jelitza Negrette 503 Chandlers Warf Portland, ME 04101 - 135. Sergia Cordero 825 Brickell Bay Drive, #1141 Miami, FL 33131 - 136. Cassandra Rivera 5011 El Clam Circle West Palm Beach, FL 33415 - 137. Randee Speciale Palm Beach Victim Services 205 North Dixie Highway, # West Palm Beach, FL 3 - 138. - 139. Steven H. enberg Address C q, Unknown - 140. Mi6110eI Stroll urrently Unknown - 141. glas Shoettle 43 Riverside, Dr. New York, NY 10025 - 142. Ghislaine Maxwell Address Currently Unknown - 143. Amazon Records Custodian - 144. Yellow Cab Records Custodian ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Bradley J. Edwards Page 17 of 22 - 145. Citrix Systems, Inc. Records Custodian - 146. Federal Bureau of Investigation Records Custodian - 147. Milton Girls Juvenile Facility Records Custodian 5770 East Milton Road Milton, FL - 148. School District of Palm Beach County Records Custodian 3344 Forest Hill Blvd., Suite C-124 West Palm Beach, FL 33406 C.) - 149. St. Mary's Medical Center Records Custodian 901 45th Street West Palm Beach, FL 33401 - 150. Wellington Reginal Hospital Reco 10104 Forrest Wellington, FL 33414 6 s1" Hill Blvd. - 151. All witnesses that Defe n4cpasehaNisted on their Witness List not objected to by Plaintiff. - 152. All rebuttal wi - 153. All People on Jeffrey Epstein's Inmate Visitor Log while he was in jail. #### C\\ WITNESS TESTIMONY EXPECTED TO BE PRESENTED BY MEANS OF DEPOSITION - 15 Epstein Vandam Street ew York, NY 10013 - 155. - 156. do Alan S. Ross, Esq. - 157. Alfredo Rodriguez ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-PlaiMiffM1 Page I8 of 22 > do Federal Public Defender or Bureau of Prisons 11349 SW 86TH Lane Miami, FL - 158. Scott Rothstein c/o Mark Nurik One East Broward Boulevard, Suite 700 Fort Lauderdale, Florida 33301 - 159. Jeffrey Epstein - 160. do Adam Horowitz. Horowitz Law 425 North Andrews Avenue, Suite 2 Fort Lauderdale FL 33301 #### EXPER - 161. Bernard J. Jansen, Ph.D do Jack Scarola Searcy Denney amhart & Shipley 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Cos The followin witn are attorneys that are not retained or specially employed to provide expert to ny, b t may provide opinions relating to the propriety of Brad Edward's conduct of di y athe prosecution of the Epstein claims. - 16 ert C. Josefsberg, Esquire odhurst Orsecic, PA One S.E. 31.° Avenue, Suite 2700 Miami, FL 33131 - 163. Charles Lichtman, Esquire Berger Singerman 300 East Las Olas Boulevard, Suite 1000 Ft. Lauderdale, FL 33301 Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff J. Page 19 of 22 - 164. Spencer Kuvin, Esquire 1800 S. Australian Avenue, #400 West Palm Beach, Florida 33409 - 165. Theodore Leopold, Esquire Cohen Milstein 2925 PGA Boulevard, Suite 200 Palm Beach Gardens, Florida 33410 - 166. Adam Horowitz, Esquire 425 N. Andrews Ave., Suite 2 Ft. Lauderdale, FL 33301 - 167. I idro M. Garcia, Esquire Law Firm, P.A. 224 Datum Street, Suite 900 West Palm Beach, FL, 33401 Kubicki Draper - 168. Earleen Cote, Esquire \\ One East Broward Bouleva, S Sui 1600 Fort Lauderdale, FL 33301 - 169. William Berger, Esquire Weiss, Handler, Comwell, P.A. 2255 Glades Road, Suite 218A Boca Raton. 33431 Plaintiff reserves \*ght to amend this list. [REDACTED] ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counter-Plaintiff Page 20 of 22 [REDACTED] J. [REDACTED] I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list, this GPR day of November, 2017. ![](<>)JACK SCAROLA Florida Bar No.: 169440 Attorney E-Mail(s): jsx@searcylaw.com and mep@searcylaw.com Primary E-Mail: scarolateam@searcylaw.com Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorneys for [REDACTED] J. [REDACTED] [REDACTED] ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counterplaintiff Page 21 of 22 ### COUNSEL LIST Jack Scarola, Esquire\ scarolateam@searcylaw.com;\ Searcy Denney Scarola Barnhart & Shipley PA\ 2139 Palm Beach Lakes Boulevard\ West Palm Beach, FL 33409\ Phone: (561) 686-6300\ Fax: (561) 383-9451\ Attorneys for [REDACTED] J. [REDACTED] Scott J. Link, Esq.\ Link & Rockenbach, P.A.\ Scott@linkrocklaw.com\ Kara@linkrocklaw.com\ 1555 Palm Beach Lakes Boulevard, Suite 301\ West Palm Beach, FL 33401\ Phone: 561-727-3600\ Fax: 561-727-3601\ Attorneys for Jeffrey Epstein William Chester [REDACTED], Esquire\ wcblaw@aol.com; wcblawasst@gmail.com\ 250 S Australian Avenue, Suite 1400\ West Palm Beach, FL 33401\ Phone: (561)-655-4777\ Fax: (561)-835-8691\ Attorneys for Jeffrey Epstein Jack A. Goldberger, Esquire\ jgoldberger@agwpa.com; smahoney@agwpa.com\ Atterbury Goldberger & Weiss, P.A.\ 250 Australian Avenue S, Suite 1400\ West Palm Beach, FL 33401\ Phone: (561)-659-8300\ Fax: (561)-835-8691\ Attorneys for Jeffrey Epstein Case No.: 502009CA040800XXXXMBAG Seventh Amended and Supplemental Witness List of Counterplaintiff J. Page 22 of 22 J. M, Esquire staff efile@pathtojusticomn Jaffe Weissing Fistos & Lehrman, P.L. 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fax: (954)-524-2822 A"' CO 'S Attorneys for Jeffrey Epstein I.S 5) ? ' Fort Lauderdale, FL 33301 S Attorneys for Scott Rothstein C Tonja Haddad Coleman, Esquire tonja@tonjahaddad.com; efiling@tonjahaddad.com Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fax: (954)-337-3716 Fort Lauderdale, FL 33301 Phone: (954)467-1223 Marc S. Nurik, Esquire marc@nuriklaw.com One E Broward Blvd., Suite 700 Phone: (954)-745-5849 Fax: (954)-745-3556 **APP.36** NOT A CERTIFIED COPY IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT\ IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually,\ [REDACTED] J. [REDACTED], individually,\ and L.M., individually, Defendant(s). ______________________________________________________________________ VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN January 25, 2012 9:34 a.m. - 10:03 a.m. SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, PA\ 2139 Palm Beach Lakes Boulevard\ West Palm Beach Florida 33409 Stenographically Reported By:\ Tammy Nestor, RPR 1 MR. KNIGHT: Okay. 2 MR. SCAROLA: -- that's intended to coach 3 the witness, Mr. Knight. 4 MR. KNIGHT: I'm going to object. 5 6 7 8 9 MR. SCAROLA: So if you say you are -I, objecting on the basis that it calls ' a legal conclusion, that's fine. Anew AtIC4i would like the witness's answer unl i::...) are instructing him not to answe 10 11 to answer. MR. KNIGHT: I'm tructing him not 12 BY MR. SCAROLA: 13 Q Okay. j'Aliva ld you please answer the 14 question? 15 A ICIvsorry Would you repeat it? 16 17 Bradley 18 court action on behalf of LM? Q Yes, sir. Is it your contention that abusively prosecuted the federal 0 20 (How?, (Yes sir ; A 19 21 A a 234-count federal 22 (complaint in conjunction with his partner Scott) 23 (Rothstein to enable his partners at RRA to defraud) 24 (south Florida investors of millions of dollars) 25 (His partner Scott Rothstein and his partner) 1 2 3 4 5 6 7 8 (Mr. Adler have -- excuse me,) Mr. (Rothstein has now in) (deposition admitted that they needed to file a complaint) to.- (show investors that there was real action,)(E) (Rothstein's words)(going on in federal court) Eigt (investors had not been able to find (filed complaint and) (had complained to Mr)(Rothstein that there was filed) (complaints two days,)(excµse me,) (the federal complaint for 234) (before Mr. filed 9 Q (Were you ever served with_ttleibmpligAtO 10 (ID (Not to the best of my ecollection) 11 Cti) (so one contention Mr 12 13 (abusively prosecuted (behalf of LW with whith were never served,) 14 correct? 15 16 09 (in fact was notified that the case was,) 17 t you were never served with the case,) 18 19 QD (I was notified that the case was filed) 20 RD (But you were never served with the case,) 21 correct? 22 g (Not to the best of my recollection) 23 24 25 en Okay., (What damage did you incur as 40 (consequence of the filing of a complaint with which) (you were never served?) 1 A \[I(incurred many legal -- much legal fees\\ 2 (rar y legal fees)(in fact)(to try to figure out 3 (all/ -- what was going on and,(in fact,(gettind 4 (prepared to defend the case though I(had not yeti 5 (been served. 9 O (I don't recall) 10 Q Did you, in fact, engage in any sexual 11 conduct with LM? 9 Y 12 A I'm sorry S m sure -- the jury is 13 going to recogni th is simply meant to harass 14 me, and I'll j e t take the Fifth Amendment since 15 your clie, is trying to overturn my 16 prosecu on agreement. 6 (Q (Were the allegations in the federal 7 (complaint on behalf of LM any different than the 8 (allegations in the state court case on behalf of LW?, '74Noi 17 How many times did you engage in sexual 18 onduct with LM? O 19 A I'm going to have to invoke my Fifth 20.& 1 Amendment right again, sir. 21 Q Do you know who LM is? 22 A Again I'm going to assert my right. 23 MR. KNIGHT: We are going to go off the 24 record and take another break. 25 THE VIDEOGRAPHER: The time is 9:58. We