HOUSE_OVERSIGHT_017521.jpg

1 of a single deposition, or the propounding of any
2 discovery in the Epstein cases. Do you have any
3 reason to doubt the accuracy of that testimony?
4 A. No, sir.
5 Q. I want you to assume that Brad has or will
6 testify that you did not provide any input whatsoever
7 into the handling of the legitimate Epstein cases. Do
8 you have any reason whatsoever to doubt the accuracy
9 of that testimony?
10 A. No, sir.
11 Q. I want you to assume that Brad has or will
12 testify that you never met any of the legitimate
13 plaintiffs in the Epstein cases. Do you have any
14 reason to doubt the accuracy of that testimony?
15 A. No, sir.
16 MS. HADDAD: I'm going to object to these
17 same questions you keep asking, because Mr. Rothstein
18 has testified at nauseam that he doesn't recall any
19 of this and now you are asking him to bolster
20 Mr. Edwards' either already given or purported
21 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
24 testify under oath that you never asked him once to
25 report back to you on any factual matters regarding
Page 122

1 the Epstein case. Do you have any reason to doubt the
2 accuracy of that testimony?
3 A. No, sir.
4 Q. I want you to assume that Brad has testified
5 repeatedly that he had absolutely no involvement in or
6 knowledge of any illegal activity engaged in by you or
7 any other RRA lawyer. Do you have any reason to doubt
8 the accuracy of that testimony?
9 A. No, sir.
10 Q. I want to talk to you briefly about your
11 personal perceptions of the significance 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 activities that you have been questioned about at any
15 stage of this very lengthy deposition, and you
16 knowingly concealed Brad Edwards' participation, what
17 do you understand the personal consequences to be as a
18 consequence of your having knowingly concealed Brad
19 Edwards' participation?
20 A. I'll be violating my agreement with the
21 United States government and I would run the risk of
22 dying in prison.
23 Q. If Brad Edwards, contrary to what you have
24 testified under oath and what Brad himself has
25 repeatedly said, knew about anything having to do with
Page 123

1 illegal activities at the RRA firm and you concealed
2 your knowledge of Brad Edwards' knowledge of that
3 illegal activity, what do you understand the
4 consequences of that false testimony to be?
5 A. I'll be violating my agreement with the
6 United States government and I would run the risk of
7 dying in prison.
8 MR. SCAROLA: Thank you. I don't have any
9 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

1 MR. GOLDBERGER: Do you think it will be
2 less than a month, two months?
3 MR. NURIK: I don't think it will be less
4 than a month. First of all, a lot depends on the
5 ability to get the transcript to him to review.
6 MR. GOLDBERGER: Right.
7 MR. NURIK: And that's a whole procedure,
8 it's not normal circumstances that we are dealing
9 with.
10 MR. GOLDBERGER: If time becomes an issue,
11 we'll approach you and ask you to expedite.
12 MR. SCAROLA: Mark, I will tell that from
13 our perspective time is an issue.
14 MR. NURIK: 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

32 (Pages 122 to 125)
FRIEDMAN, LOMBARDI & OLSON
305-371-6677
5ed93085-0554-447f-bcdd-ca2d8fe941df
HOUSE_OVERSIGHT_017521