25 way or the other who it was. 
Page 86 
1 Q. If the expenditures were being made on a 
2 case that were substantial, did you have to approve 
3 them or did you have a specific practice for them? 
4 A. The head of a practice group could basically 
5 approve them but Irene, our CFO, would generally run 
6 them by me before she actually cut the check. If] 
7 wasn't around she'd run it by Stu. 
8 Q. So as the equity partners you had the 
9 authority to make the determination what funds could 
1 0 and could not be expended? 
1 1 A. As the shareholders, as the two 50 percent 
12 shareholders, we controlled the finances. 
1 3 Q. And if Irene was coming to you to tell you 
14 what the funding was for, to get approval rather, 
1 5 would she tell you specifically what the funding was 
16 for or just tell you "we need $100,000"? 
17 A. No, if it was a substantial expense --
1 8 Q. Tell me what you deem as substantial. 
1 9 A. That would have been -- substantial to me 
20 would have been based upon how much money we had in 
21 our coffers at the time. So, if it was one of those 
22 periods of time where we had 20 or $30 million 
23 floating around the law firm, Irene probably would 
2 4 have just written a check without even letting me know 
25 we were writing it. If it was one of those times 
Page 87 
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where we owed 20, $30 million in Ponzi payments out 
and she needed to write a check for even $5,000, she 
probably would have checked with me on that. So 
substantial and whether or not she would have checked 
with me depended upon the circumstance at the time. 
Q. You stated earlier, and I think get 
this quote right, that 2009 was a dismal year; is that 
correct? 
A. For the legitimate law finn business, it was 
a dismal year. 
Q. So in the months immediately preceding the 
dissolution of RRA, July to October of 2009, what 
would you consider a substantial expense that had to 
be approved? 
A. It would vary literally from day-to-day. 
Q. Do you have any independent recollection of 
how you were doing in, say, July 2009? 
A. The legitimate business was always doing 
poorly in 2009, as far as I was concerned. 
Q. So would you have --
A. The Ponzi scheme had its moments of 
significant wealth and significant poverty, so it 
varied from time to time. It was a daily thing. 
Sometimes it was hourly. It just depended upon what 
was coming in and what needed to go out. 
Page 88 
Q. So would you have to utilize the 
illegitimate funds to fund the legitimate cases at 
times? 
A. Yes. 
Q. And that varied daily you said? 
A. Well, all the money was commingled together, 
so we used whatever funds were in there to fund both 
the legitimate and the illegitimate financial 
requirements of the firm, the Ponzi scheme and other 
legitimate and illegitimate things that were going on. 
Q. If an outside agency or investigator was 
being utilized for a case and they needed a signed 
retainer agreement with your firm, would you have to 
approve that? 
A. It would depend upon the significance of the 
expense. I didn't necessarily get involved in every 
retention of every expert in every case. 
Q. Okay. So it would depend on the cost or the 
nature of the case? 
A. Who the lawyer was, their level of 
expertise, all things of that nature. 
Q. If it was this gentleman who you have no 
recollection of meeting, Mr. Black, and the attorney 
was Mr. Edwards, was that something you needed to look 
over? 
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1 A. Did Wayne Black work for Ron Cacciatore? 
2 Q. Are you asking me --
3 A. I'm asking anyone in the room who wants to 
4 talk to me. 
5 Q. I love to talk to you, but I don't know the 
6 answer to that question. He might have. Brad might 
7 be able to tell you. 
8 MR. EDWARDS: No. 
9 THE WITNESS: When you said Wayne Black's 
10 name again and that I hired him to do something,] 
11 seem to think that he may have been associated in 
12 some way with Mr. Cacciatore, but I'm not sure one 
13 way or the other. I don't remember whether or not] 
14 met Mr. Black, it's possible I did, it's also 
15 possible I did not. And] don't have an independent 
16 recollection of retaining him to do anything or 
17 whether] was part and parcel of the decision if we 
18 did, in fact, retain him, whether] was part and 
19 parcel of the decision to retain him. 
20 BY MS. HADDAD: 
21 Q. Traveling out of state for depositions for 
22 the particular cases, did you have to approve that? 
23 A. It would depend upon who the lawyers were, 
29 tilt significance of the expense. It would have been 
25 case by case. l certainly would not have been 
Page 90 
1 approving or disapproving Mr. Nurik's travel, 
2 Mr. Rosenfeldt's travel, Mr. Boden's travel, 
3 Mr. Lippman's travel. That was their own thing. 
4 If a younger lawyer like a Shawn Birken came 
5 to-me and said he need to travel out of state for 
6 something, if it was just for a deposition, I wouldn't 
7 have gotten involved in that unless he was telling my 
8 CFO, Ms. Stay, that he wanted to fly first class and 
9 stay in the Ritz Carlton, then I would have gotten 
10 involved. But other than that, no. The firm was too 
11 big for me to vet involved on a daily basis with all 
12 that stuff. 
13 Q. If Brad had to go out of state to take a 
14 deposition, you wouldn't be the person to approve or 
15 disapprove that? 
16 A. Russ Adler would have handled that. And if 
17 there was an issue, Russ would have come to me. And 
18 don't know what the relationship was specifically 
19 between Brad and Russ, but its certainly possible 
20 that Brad just was going to go do what he needed to do 
21 to properly handle the case and I would have trusted 
22 him to do that. 
23 MS. HADDAD: Can we just take a second. We 
24 are going to take a minute, okay? 
25 THE WITNESS: Sure. 
Page 91 
1 [Short recess taken.] 
2 FURTHER DIRECT EXAMINATION 
BY MR. GOLDBERGER: 
Q. All right. Mr. Rothstein, Jack Goldberger, 
I'm going to ask you some questions now. You 
testified that you knew Jeffrey Epstein was a 
7 billionaire. You did testify to that today, correct? 
8 A. Yes. 
9 Q. Okay. Tell me how you knew that. How did 
10 you know that Mr. Epstein was a billionaire? 
11 A. Russ Adler told me. I looked him up on the 
12 internet. 
13 Q. What did you look on the internet about 
14 Mr. Epstein? 
15 A. I don't recall, but I remember looking up an 
16 seeing that he was very wealthy, that he was a 
17 billionaire. 
18 Q. Okay. So as far as learning that 
19 Mr. Epstein was a billionaire, you learned via two 
2 0 ways, one was from Russ Adler, correct? Is that 
21 correct? 
22 A. Yes, sir. 
2 3 Q. And the other was through looking up 
2 4 Mr. Epstein on the internet, correct? 
25 A. Yes. 
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Page 92 
Q. Okay. And you don't know what you reviewed 
on the internet in an effort to determine that 
Mr. Epstein was a billionaire; is that correct? 
A. I do not recall. 
Q. Do you know when you did that? 
A. I do not. 
Q. Was it prior to your needing to use the 
Epstein case to further your Ponzi scheme? 
A. Yes. 
Q. Okay. So prior to -- I think you indicated 
that you needed an influx of money at some point and 
that's when you decided to use the Epstein case in 
furtherance of the Ponzi scheme; is that correct? 
A. Yes. 
Q. So prior to that time though, prior to 
determining that you needed to use the Epstein case 
for the Ponzi scheme, you looked up Mr. Epstein and 
you spoke to Mr. Adler about his work; is that 
correct? 
A. Yes. 
Q. Why did you do that, Mr. Rothstein, if you 
weren't using the Epstein case at that point in your 
Ponzi scheme? 
A. Because it was a legitimate case in the 
legitimate portion of RRA that] had reason to believe 
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1 from speaking to Mr. Adler could bring in a 
2 significant amount of money to the firm. 
3 Q. At that time Mr. Adler was one of your 
4 co-conspirators in the Ponzi scheme; is that con-ect? 
5 A. By this time, yes, sir. 
6 Q. Okay. When did Mr. Adler become a 
7 co-conspirator in your Ponzi scheme? 
8 A. I don't recall the specific date. 
9 Q. Was it before or after Mr. Adler recommended 
1 0 that Brad Edwards be hired at your firm? 
1 1 A. Before. 
1 2 Q. So before Brad Edwards was hired at RRA, 
1 3 Russell Adler was a co-conspirator of yours in the 
1 4 illegal part of the RRA firm; is that correct? 
15 A. Yes. 
1 6 Q. Then after that time you hired --
1 7 Mr. Edwards was hired after Adler was your 
1 8 co-conspirator? You are laughing, you are smiling, 
1 9 why is that, sir? 
2 0 A. Because when you say "RRA" that way, the 
2 1 speaker sounds, it sounds like you are roaring. 
2 2 Q. Okay. I'll just say Rothstein, how about 
2 3 that? You know what I'm talking about if I just say 
24 Rtthstein. 
25 A. RBA is fine. 
Page 
• 1 Q. What did Adler tell you about the Epstein 
2 case that Edwards had at the time you were 
3 contemplating hiring him to become a member of the 
4 Rothstein firm? 
A. He told me that it was a huge case involving 
7 6 a billionaire pedophile and that it was a winner. 
i 7 Q. Did you, when you heard that, did you think 
8 that that was a case that could become part of your 
9 Ponzi scheme? 
P 10 
1 A. No, I actually thought of it as a way to 
11 earn legitimate money to help me out of the Ponzi 
12 scheme. 
1 3 Q. So at the time you hired Mr. Edwards and you 
1 4 were talking to Adler about Edwards, you were trying 
15 to get out from under the Ponzi scheme? 
1 6 A. In the bulk of 2009 I was praying for some 
17 sort of legitimate influx of money to get out of the 
1 8 Ponzi scheme. 
1 9 Q. Okay. So now Adler tells you about this 
20 Brad Edwards guy, did you know Brad Edwards before 
2 1 Adler talked to you about him? Had you run into him? 
B 22 A. I may have. I don't have a specific 
23 recollection one way or the other. 
2 4 Q. Okay. So now he-tells you that you should 
25 consider hiring Brad Edwards, this is your 
1 Q. Okay. So Adler is your co-conspirator in 
2 the Ponzi scheme at the time that Brad Edwards is 
3 hired, correct? 
4 A. Yes. 
5 - Q. Okay. Was it Adler who recommended to you 5 
6 that Brad Edwards be hired? 
A. Yes. He was one of the people. 
8 Q. Who else recommended that Edwards be hired? 
9 A. I don't have a specific recollection of who 
10 it was, but others did. 1C 
1 1 Q. All right. But you have a recollection of 1 1 
12 Adler being one of the people, so let's talk about 1 2 
13 that, all right? 13 
1 4 What did Adler tell you about Brad Edwards 1 4 
15 when you hired him? Did he tell you that he had these 15 
16 Epstein cases or an Epstein case in the fold? 1 6 
17 A. Among other things, yes. 17 
18 Q. What else did he tell you? 18 
19 A. Told me he was a great lawyer and a great 19 
20 guy. 20 
21 Q. Did he tell you what his history was, what 2 1 
22 Edwards' history was prior to coming to the Rothstein 22 
23 firm? 23 
24 A. I'm certain that I asked him, but I don't 24 
25 have a specific recollection of that conversation. 25 
Page 95 
4 
Page 96 
co-conspirator talking to you, right? Is that 
correct? 
A. Yes. 
Q. And he says, by the way, he's got this great 
Epstein case involving this billionaire, correct? 
A. Yes. 
Q. Presumably then-you had a meeting with Brad 
Edwards when you met him; is that correct? 
MR. SCAROLA: Presumably he had a meeting 
when he met him? 
MR. GOLDBERGER: I'm sorry, Mr. Scarola was 
cutting you off when you answered, so go ahead, answer 
again. 
MR. SCAROLA: I didn't understand the 
question. 
BY MR. GOLDBERGER: 
Q. Do you understand the question, 
Mr. Rothstein? 
A. I'm not sure I do because you asked me if] 
had a meeting when I met him and] think that meeting 
him is a meeting. 
Q. Well, there was a meeting, correct? 
A. I most likely met him before I hired him. I 
most likely talked to him before I hired him because 
that was my general way of doing business. It's all 
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1 together possible that I gave Russ the okay to hire 
2 him before, I just don't have a specific recollection 
3 one way or the other. 
4 Q. At some point,Itake it, you learned, 
5 whether you sat in on a meeting when Mr. Edwards was 
6 hired or whether your co-conspirator hired him, at 
7 some point you learned that Mr. Edwards, in fact, had 
8 been hired by the firm; is that correct? 
9 A. I'm certain that I gave the final okay to 
10 hire him. 
11 Q. Okay. When you were giving the final okay 
12 to hire him, I assume there had to be discussion of 
13 the money that he was going to be paid, correct? 
14 A. With somebody, yes. 
15 Q. Certainly with Mr. Edwards, right? I assume 
16 he wanted to know how much he was getting paid. 
A. Yes, but don't have a specific 
18 recollection of whether l discussed that with him or 
19 whetherl authorized Adler or maybe even Rosenfeldt to 
20 discuss it with him. 1 don't recall. 
21 Q. Do you have the slightest idea how much 
22 money Mr. Edwards was paid when he first joined the 
23 firm, what his salary was? 
24 A. 1 don't have an independent recollection. 
25 -- Q. Generally someone like Mr. Edwards at his 
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level of accomplishment and his age, you know what the 
general salary would have been at your firm? 
A. It didn't work that way. 
Q. I see. Tell me how it worked. 
A. It's a case-by-case basis. 
Q. Tell me how it worked. 
A. Case-by-case basis. 
Q. And how did you make that determination on a 
case-by-case basis? 
A. Actual book of business, potential book of 
business, potentiality for growth, character, what he 
brought to the table, and obviously a function of how 
much money we had available at the time. 
Q. Okay. And you don't have any recollection 
of the machinations that occurred in determining what 
Mr. Edwards salary would be, correct? 
A. I do not. 
Q. But certainly one of the things you would 
consider would be the book of business, i.e. the 
Epstein case, right? 
A. I'm certain thatl did consider the Epstein 
case. 
Q. Do you know whether he brought any other 
book of business --
A. But I'm also certain it wasn't the only 
Page 99 
1 factorl considered. 
Q. All right. Do you know whether he brought, 
in his book of business, do you know whether be 
brought any other cases to the firm other than the 
Epstein case? 
A. 1 don't recall one way or the other. 
Q. Okay. Do you know whether your -- well, bad 
question, I won't ask that. 
Now, you've talked a lot about Ken Jenne 
110 here this morning. Was Ken Jenne part of your Ponzi 
11 scheme? 
12 A. No. sir. 
13 Q. Had nothing to do with it, right? 
14 A. That's correct. 
15 Q. Other than his having -- working for you as 
16 an investigator, he was not one of your 
17 co-conspirators, right? 
18 A. He didn't work for me as an investigator, he 
19 worked for me heading up our investigative division, 
20 heading up our internal security, heading up my 
21 personal security, and acting as a political advisor 
22 tome. 
23 Q. Okay. Did he serve any kind of 
24 investigative function at all, after all, he was a law 
25 enforcement officer at one point in his career? 
Page 100 
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A. I note that he assisted the other people at 
the firm that were doing the investigative work. 1 
don't know if he personally did investigative work. 
He may have. 
Q. Do you know whether Mr. Jenne, in his role 
as your advisor or your political consultant, do you 
know if he was involved in any kind of illegality, 
illegal wire tapping or anything like that while he 
was at Rothstein? 
MR. SCAROLA: Excuse me, I'm going to 
object to the form of the question, vague and 
ambiguous. 
THE WITNESS: To my knowledge he was not. 
BY MR. GOLDBERGER: 
Q. To your knowledge, no? 
A. Correct. 
Q. Okay. You talked about having a bunch of 
fundraisers, I know you had a bunch of fundraisers 
that was kind of a deal at Rothstein. This was kind 
of a rock star law firm, right? I mean, you had lots 
of fundraisers, lots of parties, right? Was that the 
image you were trying to present? 
A. In reality that's the way we were. 
Q. Okay. 
A. A lot of young lawyers having a good time, 
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1 trying to make money. 
2 Q. And these young lawyers. would you consider 
3 Mr. Edwards to be a young lawyer or a middle-aged 
9 lawyer? 
5 A. Young lawyer. 
6 Q. Okay. Was he one of young lawyers that came 
7 to these fundraisers at your home? 
8 A. I don't recall whether he was there or not. 
9 I recall him being at some, but I didn't know if he 
1 0 was at all of them. 
1 1 Q. Okay. You do recall him coming to some of 
1 2 the fundraisers, though, correct? 
1 3 A. I recall him being at my home. It may have 
14 been for firm parties or other parties, it may have 
1 5 been for fundraisers there. 
1 6 Q. And that was during the time period that the 
17 Ponzi scheme was still going on. correct? 
18 A. Yes. 
1 9 Q. Did Adler ever the tell you about any 
2 0 discussions he had with Brad Edwards about the illegal 
2 1 part of the operations at Rothstein? 
22 A. Can you reask the question, please? 
23 Q. Sure. Sure. 
24 Did Russell Adler ever tell you -- Russell 
25 Adler is your co-conspirator, we've established that. 
Page 102 
1 Did Russell Adler in the furtherance of your 
2 conspiracy ever tell you he had discussed with Brad 
3 Edwards about the illegal activities at RRA? 
4 A. No. 
5 Q. Now,..you testified when asked about whether 
6 the press -- if.you were involved in asking the press 
7 to run with the E stein sto ou said something to 
8 the effect, "the wa I was selling the Ponzi scheme it 
9 would be overkill." 
10 I didn't understand your answer like you 
11 didn't understand some of my questions, so I'd like 
12 you to kind of tell me what you  meant by that. 
13 A. I was selling purportedly confidential 
14 settlements. Confidentiality was the hallmark of the 
15 Ponzi scheme, so too much publicity would have created 
1 6 a roblem for me in the sale of what was supposed to 
17 las smIeteIconfidentialseft1ement. 
18 Q. I think what you are telling me, and I don't 
19 want to misstate what I think you are telling me, but 
20 is it true that you felt some publicity would be okay 
21 but too much would be counter to the purposes of the 
22 conspiracy. Is that a fair statement? 
23 A. The way I was thinking about it at the time 
24 this was going on was that some_publicity would assist 
25 kis_sl.aLzilisl th_aLth5Le 
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was a real case goirjg on, but that within that 1 woad 
have to create some sort of fictions in ordeno_aelL 
the fakeyroduct.  
Q. Okay. At the time that you decided to use 
the Epstein case as part of your illicit Ponzi scheme 
theme,Ithink you testified earlier today, when you 
were in some dire straights, you needed an influx of 
money, right? 
A. Yes. 
Q. That's when you decided to use the Epstein 
matters, correct? 
A. Yes. 
Q. Okay. And you knew, I assume, being the 
Ponzi scheme mastermind here, that you needed to make 
sure that you had at least a working knowledge of the 
Epstein case so that you could answer questions to the 
investors. I recognize that you left the room and 
told them to look at it, but you had to some knowledge 
of the case, right? 
MR. SCAROLA: Counsel, that's a 
misrepresentation of what the earlier testimony was. 
object, no proper predicate. 
MR. GOLDBERGER: Okay, let's go through the 
whole thing again. 
MR. SCAROLA: No, you are not going to go 
Page 109 
through the whole thing again. Just because we have 
tolerated two lawyers asking questions, does not mean 
3 we are going to tolerate two lawyers asking the same 
questions. 
MR. GOLDBERGER: Your objection is noted. 
BY MR. GOLDBERGER: 
Q. Okay. So let's talk about your need to use 
the Epstein case to further your conspiracy. You 
needed an influx of money, did you not? 
A. Yes. 
Q. Okay. You decided to use the Epstein case 
for that purpose, right? 
A. Yes. 
Q. And in order to use the Epstein case, you 
were going to meet with the investors and pitch the 
Epstein case with the investors, correct? 
A. Yes. 
Q. And in an effort to pitch the case to the 
investors, you had to have some knowledge of the case, 
did you not? 
A. Some level of knowledge, yes, sir. 
Q. Okay. And in order to gain that knowledge, 
you spoke to your co-conspirator, Russell Adler; is 
that correct? 
A. That's one of the things I did. 
7 
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Q. Okay. And do you remember what Adler told 
2 you specifically about the Epstein case that helped 
3 you have a basis of information to sell it to the 
4 investors? 
5 A. Other than him telling me that it was a 
6 billionaire pedophile, other than him telling me about 
7 the flight manifest, don't have a specific 
8 recollection of what else he told me. 
9 Q. Did you actually look at the flight manifest 
1 0 at sometime, Mr. Rothstein? 
1 1 A. Yes, sir. 
12 Q. And what was it about those flight manifests 
1 3 that you felt would help you pitch the Epstein case to 
1 4 the investor? 
1 5 A. I don't remember who specifically was on it, 
16 but Iremember it looking juicy. 
17 Q. You don't know who was on it? 
1 8 A. 1 don't recall. 
1 9 Q. Did you add any names to that manifest at 
2 0 any time? 
2 1 A. I had -- you mean physically write names on 
22 there? 
23 Q. Any way you want to interpret -- did you --
29 not physically write any names on the manifest, but 
25 did you tell the investors that there were names on 
Page 106 
the manifest that were actually not on the manifest? 
2 A. I told the investors that there were other 
3 people that appeared on manifests,] don't recall 
4 whether it was that manifest or other manifests, and 1 
5 got the names of those people from Russ Adler. 
6 Whether or not they actually appeared on the manifest 
7 or another manifest, 1 do not know. 
8 Q. What names did you get from Russ Adler? 
9 A. 11.....21.1ALligyjastme_tita1.B i I ew on 
1 0 eildndeen 10 
11 Mr.  Enstein's_plaa. 11 
12 Q. And is it your testimony today that you 12 
13 never looked at the manifest to see whether Bill 13 
14 Clinton or Prince Andrew's name were really on the 14 
15 manifest that you were going to use to pitch the 15 
16 investors? 16 
17 A. It was my understanding they didn't have all 17 
18 the manifests. 18 
19 Q. Okay. Did you ever ask for the manifests 19 
20 that purportedly had the name of Bill Clinton or 20 
21 Prince Andrew on it? 21 
22 A. 1 probably did, but I don't have a specific 22 
23 recollection one way or the other. 1 23 
24 Q. When you say you didn't have all the 24 
25 manifests, were all the manifests in your office -- 25 
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were all the manifests within the law firm of RRA and 
you simply didn't have them in your office? 
A. I have no idea one way or the other. 
Q. Okay. 
A. I did not have them. 
Q. You were told by Russell Adler that you 
didn't have -- that you physically didn't have all the 
manifests, correct? 
A. That's correct. 
Q. But you don't know whether they were in the 
building somewhere, these other supposed manifests? 
A. I have no idea one way or the other. 
Q. You never asked for proof that Bill Clinton 
or Prince Andrew's name were on a manifest somewhere? 
A. I didn't say that. I may very well have 
asked Adler or Ken Jenne to find the other manifests. 
Q. Were you ever shown a manifest with the name 
Bill Clinton or the name Prince Andrew on them? 
A. I do not recall one way or the other whether 
I saw that or not. I remember Adler telling me about 
it and then me repeating that information to the 
investors based upon Mr. Adler's representations to 
me. 
Q. Now, you testified that you were told that 
the Epstein cases were "legitimate cases. Do you 
Page 108 
remember that testimony you gave this morning? 
A. Yes. 
Q. And you remember your testimony that you 
were told they were legitimate cases by both Russ 
Adler and Brad Edwards, do you remember that? 
A. I never said that Mr. Edwards or Mr. Adler 
said, "Scott, these are legitimate cases." I didn't 
question them as to their legitimacy. 
Q. You did testify that you talked to Brad 
Edwards about the Epstein cases; is that correct? 
MR. SCAROLA: No, counsel, that is a 
misrepresentation of the earlier testimony. 
MR. GOLDBERGER: No, it's not. 
BY MR. GOLDBERGER: 
Q.  Did you talk to Brad Edwards about the 
Epstein cases? 
A. I do not recall one way or the other.  That  
- 
was my prior testimony, that's still in testimon 
-don't -- I do not recall. 
Q. We'll let the record speak --
A. l know I spoke to Adler about it. 
Q. We'll let the record speak for itself. Your 
testimony, as I am questioning you now, is that you do 
not recall whether you spoke to Brad Edwards about the 
Epstein cases; is that correct? 
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1 A. If you are including within that me walking 
2 past Brad in the hall and saying, "Hey. Brad how are 
3 you? How is the Epstein stuff going?" Then its very 
4 likely that I talked to him about it in that manner. 
5 But lhave no specific recollection one way or the 
6 other as to having any lengthy conversations with 
Mr. Edwards about the case. 
8 I had a co-conspirator who was deeply 
9 involved in the Ponzi scheme that I could go to to get 
10 any information I wanted, NIL Adler. I didn't need to 
11 go to Mr. Edwards. 
12 Q. So if you had a question of your 
13 co-conspirator, Russell Adler, about the Epstein case, 
14 you would go ask Adler and would Adler always have the 
15 answer for you or would he say he would get you the 
16 answer? 
17 A. Both. 
18 Q. When he didn't have the answer, do you know 
19 who he was getting the answer from? 
20 MR. SCAROLA: Objection, predicate. 
21 THE WITNESS: I don't know who he was 
22 getting it from and I may have contacted other people 
23 in the office who were working on the file to ask. I 
24 may have asked Mr. Jenne,Imay have asked Ms. 
25 Holmes, I many have asked a whole myriad of people. 
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1 BY MR. GOLDBERGER: 
2 Q. So Ms. Holmes was working on the Epstein 
3 cases? 
4 A. It's my refreshed recollection from seeing 4 
5 one of those e-mails that she must have been. 5 
6 Q. Okay. And Ms. Holmes you said was a former 
7 federal law enforcement officer, was that your 
8 testimony? 
9 A. Yes. 
10 Q. You don't know whether she was FBI or IRS, 10 
11 correct? 11 
12 A. I don't remember. 12 
13 Q. Okay. And upon reflection, do you know 13 
14 whether she was hired without your say-so based on 14 
15 what Mr. Jenne told you or did you meet with her? 15 
16 A. No, I actually -- I remember meeting with 16 
17 Ms. Holmes. 17 
18 Q. Okay. What do you remember about that 18 
19 meeting? 19 
20 A. I remember talking about her relative who 20 
21 was a judge. I remember her telling me about her time 21 
22 in law enforcement. I just don't remember which 22 
23 agency. 23 
24 Q. Did she tell you why she left law 24 
25 enforcement? 25 
Page 111 
A. She may have, I don't recall one way or the 
other. 
Q. Did you ever ask Ms. Holmes to use any of 
her prior contacts in law enforcement to assist you in 
the Ponzi scheme to get information for you? 
A. The question is kind of convoluted because 
the way you are asking it, it seems like you are 
intimating that Ms. Holmes knew. I may have asked 
Ms. Holmes to get me information that I was going to 
utilize with my co-conspirators in the Ponzi scheme, 
but Ms. Holmes did not know that there was a Ponzi 
scheme going on. 
Q. All right. So you may have asked Ms. Holmes 
to try and get some information for you from her 
contacts in law enforcement, but it's your testimony, 
and I don't dispute it, it's your testimony that she 
knew nothing about the Ponzi scheme, correct? 
A. I may have, I may not have. I do not 
remember and she absolutely knew nothing about the 
Ponzi scheme. 
Q. Okay. Now, we talked about Brad Edwards 
getting paid and the multilevel ways in which you 
determined what a person's salary was. Do you know 
whether Brad Edwards got any bonuses along the way 
once the Epstein case was used as part of the Ponzi 
Page 112 
scheme? 
A. He did not. 
Q. So he was --
A. If he got a bonus, it was something he 
earned. 
Q. Did you make a determination as to what that 
bonus would be? 
A. If he got a bonus, I would have been 
instrumental in determining it. You can determine if 
he got a bonus by looking at our financial records,1 
don't have an independent recollection one way or the 
other. 
Q. So you don't know whether he got a bonus at 
all, correct? 
A. That's correct. 
Q. So1 assume that if he got a bonus you 
wouldn't know whether it occurred before or after the 
Epstein case was used as part of the Ponzi scheme? 
A. I don't know if he got a bonus, which means 
I wouldn't know the time frame. 
Q. But we would learn -- you are instructing 
us, we would learn that by looking at when the Epstein 
case was brought into the Ponzi scheme and we learn 
that by looking at these -- what was the group that it 
was used to pitch to? 
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1 A. Clockwork. 1. 
2 Q. So we would look at when the Clockwork group 2 
3 was brought into this and the Epstein case was used 3 
then and then we would look at the payroll records to 
5 see whether Mr. Edwards got a bonus after the 5 
6 Clockwork group was brought into the Ponzi scheme. 6 
correct? 7 
8 A. From a timing perspective, yes. But 
9 Mr. Edwards had nothing to do with the Ponzi scheme, 
10 nor was he rewlr_d_e_daltinik_without his 10 
11 _knowledge for helnip me with the Ponzi scheme. If he 11 
12 .1yas rewarded it was because he deserved,] felt he 12 
1 3 deserved a reward, havin nothing to do with the Ponzi 13 
19 scheme. The bulk of this law firm had nothing to do 14 
15 with the Ponzi scheme. 15 
16 Q. I think you testified already, though, that 16 
17 money was fundable in the firm, right? I mean, you 17 
18 know, illegal money was used for legitimate purposes, 18 
19 correct? r19 
20 A. Yes. 20 
21 Q. Okay. So, for example, investigations that 21 
22 were done with the Epstein case, it's very possible 22 
23 that legitimate Ponzi money was used to finance those 23 
24 investigations? 24 
25 A. I'd be guessing. It's certainly possible 25 
Page 114 
1 because all the money went into a whole series of 
2 pots, and if you look at, most of the pots were trust 
3 accounts. If you look back, you look to see what my 
4 CFO, who was also a co-conspirator was doing, she was 
5 pulling the money from wherever she needed to to fund 
6 whatever she needed to fund. 
MR. LAVECCHIO: Off the record a second. 
8 [Discussion off the record.] 
9 BY MR. GOLDBERGER: 
10 Q. Let me circle back to what you needed to 
11 learn about the Epstein cases to help make your pitch 
12 to the investors. 
13 You talked about the manifest already, 
1 4 correct, the flight manifest? 
15 A. Yes. 
16 Q. Okay. What else did you want to learn about 
17 the case or what else did you learn about the case so 
18 that you were conversant when you spoke to the 
19 investors about the Epstein case? 
20 A. 1 recall asking someone what the causes of 
21 action were. 
22 Q. Okay. Did you understand what they were? 
23 A. I likely did at the time, I don't remember 
24 what they were now. 
25 Q. Okay. Do you know which case we are talking 
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about? By the way, you had a number of Epstein cases 
in-house, do you know which case you were talking 
about? 
A. As I sit here today, no, sir, I don't 
remember. 
Q. Was it a state case or a federal case? 
A. I don't remember one way or the other. 
Q. All right. 
A. I utilized all those boxes all together. 1 
don't remember which  one I sold them. 
Q. And the exhibits --
A. It's something completely fictitious that  
Q. The exhibit that you were shown earlier, 
Exhibit Number 1, that's the long multi-page federal 
lawsuit. Do you know whether that was part of the 
information that you reviewed or shown to the 
investors when you were pitching to them? 
A. I do not remember one way or the other. 
Q. Okay. Now, did you make any effort to learn 
from your co-conspirator who the plaintiffs were in 
this case, what kind of women they were? 
A. Only that they were underage. 
Q. Did an one tell you that these women had --
some of these women had a history of prostitution? 
Page 116 
A. They may have told me that, I wouldn't have 
cared one way or the other, 
Q. Why would you not have cared about that, 
Mr. Rothstein? 
A. It had nothin to do with the sale of the 
Ponzi scheme settlements,. 
Q. Okay. Were you told by anyone whether any 
of the women involved as plaintiffs in the case may 
have worked at adult clubs in the past? I mean strip 
clubs, let's call it what it is. 
A. I may have been told that one way or the 
other. But againziLhadpothing to do with the Ponzi 
scheme sale of fake settlements. 
_ 
Q. As part of the information that you were 
told by you co-conspirator, Russell Adler, were you 
told that some of the plaintiffs that you had in-house 
had travelled on Mr. Epstein's airplane? 
A. I believe Russ did tell me that. 
Q. You know, in fact, that that was not true, 
correct? 
A. lhave no idea one way or the other, nor did 
I care. 
Q. But your co-conspirator told you that, 
right? 
A. Mr. Adler did, in fact, tell me that certain_ 
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FRIEDMAN, LOMBARDI & OLSON 
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1 of the underage women had travelled on Mr. Epstein's 
2 .2.1_2a; 
3 Q. Did you ever meet any of the plaintiffs? 
4 MR. SCAROLA: That's question that's been 
5 asked and answered. 
6 THE WITNESS: I do not have a specific 
7 recollection of ever meeting them. 
8 MR. SCAROLA: You are exhausting my 
9 indulgence. 
10 MR. GOLDBERGER: Fair enough. 
1 1 MR. SCAROLA: You've exhausted my 
12 indulgence. 
13 BY MR. GOLDBERGER: 
19 Q. Do you know whether any of your 
15 investigators at the firm had any kind of high tech 
16 surveillance equipment or, you know, wire tapping 
17 equipment? 
18 A. I believe they did. 
19 Q. Do you know whether this was legal stuff or 
20 illegal staff? 
2 1 A. I did not know, nor did I care. 
22 Q. Do you know if any of that stuff was used to 
23 either wire tap or surveil Mr. Epstein? 
24 A. I do not know one way or the other. 
25 Q. What sort of equipment did you know that 
Page 118 
they had, meaning your investigators? 
2 A. I had told Mr. Jenne and others involved in 
3 the investigation arm of RRA to get whatever equipment 
4 they thought they needed and to get the best stuff 
5 that they could get. What they actually did, I can't 
6 tell you. 
7 Q. You know as part of the Epstein litigation, 
8 and I'm talking about now after your using it in the 
9 Ponzi scheme, do you know whether anyone at your firm 
10 attempted to depose ex-President Bill Clinton? 
11 A. I don't recall that, sir. 
12 Q. Okay. How about Donald Trump, same 
13 question? 
14 A. I don't recall that. As a matter of fact, 
15 we had represented Trump in some things, we had some 
16 pretty close ties with him, so I can't imagine that 
17 they would have done that with my authority. 
18 Q. Okay. 
19 A. I don't recall that. 
20 Q. Do you know whether Adler would have --
21 would Adler have the authorize to do that without 
22 getting your permission? 
23 A. The authority, no. Might he have tried, 
24 yes. 
25 Q. Okay. How about Alan Dershowitz, do you 
Page 119 
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have any knowledge of your firm's attempt during the 
Ponzi scheme to depose Alan Dershowitz? 
A. No. sir. I don't have a recollection of one 
way or the other. 
Q. Okay. The name Kendal] Coffey was brought 
up before. Do you know who Kendall Coffey is? 
A. Yes. 
Q. Who do you know him to be? 
A. Former U.S. attorney, current criminal 
defense lawyer. 
Q. Was he a friendship of the firm's? 
A. Represented RRA when I fled the country. 
Q. So he was a friend of the firm, or a friend 
of yours at least, right? 
A. He wasn't a friend of mine. 
Q. A friend of the firm? 
A. No idea. 
Q. He represented them when I fled the country. 
I remember him coming in and doing like a show and 
tell in my office on TV. 
MR. GOLDBERGER: Patience gets rewarded. 
I'm done. 
Thank you, Mr. Rothstein. That's all the 
questions that] have. 
THE WITNESS: You are welcome. 
Page 120 
CROSS EXAMINATION 
BY MR. SCAROLA: 
Q. Mr. Rothstein, again, Jack Scarola on behalf 
of Brad Edwards.. I want you to assume that Brad has 
testified under oath that you never had a substantive  
discussion with him re arding the Epstein case. Do 
Lop have any basis whatsoever to question the accuracy 
,of that tQliimax? 
A. I do not. 
Q. I .wz2Ly.a_i to asst21115_±.M Brad has or will 
fy un der oath that while ou were c22piagp 
e-mails, you never attended a singtelelLtimate 
ii.Lear_ditmtbs legitimate 
Epstein cases. Do   have any basis whatsoever to 
question the accuracy of that testimony? 
A. No, sir„ 
Q. I want you to assume that Brad has or will 
testify under oath that you never directed t _e  
of any documents in the Epstein case, includin the 
July federal complaint that's been marked as an 
exhibit to your deposition._122...a.s2p 
whatsoever to uestion the accurac of that testimon ? 
A. No, sir. 
Q. I wantyou to assume that Brad has or will  
testify under oath thatyou never directed the taking. 
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1 of a sin le de osition. or the TO oundin_a2fEty 
2 disc_oystle_lpstein cases. Do_you have any 
3 reason to doubt the accuracy of that testimonV 
4 A. No, sir. 
5 Q. 12naliaLlaaLs_a-asti2Lt has or will 
6 testify that you did not provide any input whatsoever 
7 into tbs..12oltlifjs..gjlipstein cases. Do  
8 you have an reason whatsoever to doubt the accurac,y 
9 of thatiLilaopy.? 
10 A. No sir. 
11 Q. I want you to assume that Brad has or will 
1 2 Iss_tifylatay_g_u_mysualln_y of the legitimate 
1 3 plaintiffs in the Epstein cases. Do you have any 
1 4 reason to doubt the accuracy of that testimony? 
15 A. No, sir. 
1 6 MS. HADDAD: I'm going to object to these 
1 7 same questions you keep asking, because Mr. Rothstein 
1 8 has testified at nauseam that he doesn't recall any 
1 9 of this and now you are asking him to bolster 
2 0 Mr. Edwards' either already given or purported 
2 1 testimony when he's testified he doesn't recall it. 
22 BY MR. SCAROLA: 
23 Q. I want you to  assume that Brad has or will 
2 9 testify under oath that you never asked him once to 
2 5 .12y2It o yalpaai2Lf_a_Etual matters rearding. 
Page 122 
the Epstein case. Do you have an reason to doubt the 
2 acculaa_of that. testimony? 
3 A. No, sir. 
4 Q. I want you to assume that Brad has testified 
5 repeatedly that he had absolute! no involveinent in or 
6 knowled 
7 a2L9.1ter RItA la er.  Do you have any i_s_a.s_oato doubt 
B Ill.ILE.1.9111l at testimon ? 
9 
10 Q. iwanttota1ktjieflaoopr 
o ou 
11 personal perce tions of the si ificance of the 
12 testimony that you are giving today.  If Brad Edwards 
13 had in fact, been a participant in any of the illegal 
14 an 
15 _sALoILL- s ve 1 mtlyllsgoligusaracjim 
16 knowingly=alscl Esima_prds' arlztiat 
17 do you understand the ersonal conse uences to be as a 
18 
1 9 Edwardsjarticipation?  
20 A. HI be violatinnent 
21 United States overnment and I would run the risk of 
22 dying in prison.  
23 Q. If Brad Edwards, contrary to what you have 
29 testified under oath and what Brad himself has 
25 to do with 
Page 123 
e of any ille al activity en a ed in by you or 
conse uence of your havine knowinely concealed Brad 
repeated] said knew about anythg havin 
illegal activities at thEIL_R fjp2Lanlyou concealed 
your knowled e of Brad Edwards' knov,..1g.e_of that 
illegal activiL, what do you understand the 
4 consequences of that false testirporly_to be? 
5 A. jJviolatiiiinaeentwjtht 
6 United Statesgovemment and]  
7 styginrison. 
MR. SCAROLA: Thank you. I don't have any 
further questions. 
10 THE WITNESS: Thank you, sir. 
11 MR. NURIK: Mark, I don't know what your 
12 time frame is on your litigation, but the ability to 
13 receive the transcript, review it and prepare an 
14 errata sheet within what is normally the time 
15 allotted under the court rules cannot be accomplished 
16 in this case. 
17 MR. GOLDBERGER: How much time are you 
18 generally-.-
19 MR. NURIK: I don't know. 
20 Actually, the first set of errata sheets 
21 have just been prepared and finalized for the first 
22 deposition in December. I'm not suggesting it will 
23 take that long this time, but if you can give me an 
24 idea of what your time responsibilities are with the 
25 court, what the time limits are --
Page 124 
MR. GOLDBERGER: Do you think it will be 
less than a month, two months? 
MR. NURIK: i don't think it will be less 
than a month. First of all, a lot depends on the 
ability to get the transcript to him to review. 
MR. GOLDBERGER: Right. 
MR. NURIK: And that's a whole procedure, 
it's not normal circumstances that we are dealing 
with. 
10 MR. GOLDBERGER: If time becomes an issue, 
11 we'll approach you and ask you to expedite. 
12 MR. SCAROLA: Mark, will tell that from 
13 our perspective time is an issue. 
14 MR. NUM: Have at it then, Jack. Do what 
15 you need to do to get it done. 
16 MR. SCAROLA: There is a long pending 
17 motion for summary judgment on Brad's behalf that has 
18 been delayed for purposes of taking this deposition. 
19 We are very anxious to be able to call that motion 
20 for summary judgment up for hearing, so whatever can 
21 be done reasonably to expedite the preparation of 
22 this portion of this transcript would be appreciated. 
23 We understand there are limitations beyond your 
24 control, but to the extent you can do it, that would 
25 be helpful. Thank you. 
Page 125 
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activities that you have been uestioned about at 
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MS. HADDAD: Its scheduled in a month, 
Mark. 
MR. NUR1K: We'll cooperate. 
MR. SCAROLA: Thank you very much. 
[Thereupon, the taking of the deposition was 
concluded at 12:37 p.m.] 
SCOTT ROTHSTEIN 
1 1 Sworn to and subscribed 
before me this day 
12 of , 2012. 
Notary Public, State 
of Florida at Large. 
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1 CERTIFICATE 
2 STATE OF FLORIDA ) 
COUNTY OF MIAMI-DADE ) 
3 
1, Pearlyck Martin, a Notary Public in and 
4 for the State of Florida at Large, do hereby certify 
that, pursuant to a Notice of Taking Deposition in 
5 the above-entitled cause, SCOTT ROTHSTEIN seas by me 
first duly cautioned and sworn to testify the whole 
6 truth, and upon being carefully examined testified as 
is hereinabove shown, and the testimony of said 
7 witness was reduced to typewriting under my personal 
supervision and that the said Video Conference 
deposition constitutes a true record of the testimony 
given by the witness. 
9 
10' 
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12 
1 further certify that the said Video 
Conference deposition was taken at the time and place 
specified hereinabove and that 1 am neither of 
counsel nor solicitor to either of the parties in 
said suit nor interested in the event of the cause. 
WITNESS my hand and official seal in the 
13 City of Miami, County of Dade, State of Florida. this 
day of June 19, 2012. 
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Pearlyck Martin 
Page 126 
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2 
FRIEDMAN, LOMBARDI & OLSON 
Sore 924, Biscayne Building 
19 West Flagler Street 
Miami, Florida 33130 
Telephone (305) 371-6677 
June 21, 2012 
IN RE EPSTEIN VS EDWARDS 
SCOTT ROTHSTEIN C/O MARC NUR1K 
One East Broward Boulevard. Seventh Floor 
Ft. Lauderdale, Florida 33301 
Dear SCOTT ROTHSTEIN: 
With reference to ihe deposition of 
10 yourself taken on June 14, 2012, in connection with 
the above-captioned case, please be advised that the 
11 transcript of the deposition has been completed and 
is awaiting signature_ 
12 
Please arrange to stop by our office for 
13 the purpose of reading and signing the deposition. 
Our office hours are 9:00 am to 400 p.m, Monday 
1 4 through Friday. Please telephone in advance. 
15 You may, however, read a copy of the 
transcript, provided by any of the attorneys 
16 connected with the case, denoting any corrections by 
page and Fine number on a separate sheet of paper. 
17 This correction page must be signed by you and 
notarized and returned to us for filing with the 
38 original. 
39 If this has not been taken care of 
however, within lire next 30 days, or by the time of 
20 trial, whichever COITICS first, I shall then conclude 
that the reading, subscribing and notice of filing 
have been waived and shall then proceed to deliver 
the original of the transcript to ordering attorney 
without further notice. 
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Pearlyck Martin 
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