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of a single deposition, or the propounding of any discovery in the Epstein cases. Do you have any i reason to doubt the accuracy of that testimony?
A. No, sir,
Q. l_want you. to assume that Brad has or will testify that you did not provide any input whatsoever into the handling of the Jegitimate Epstein cases. Do you have any reason whatsoever to doubt the accuracy of that testimony?
A. No, sir.
Q. |] want you to assume that Brad has or will 2 ENE YOU 10 eee at 2rd he we
testify that you never met any of the legitimate plaintiffs in the Epstein cases. Do you _have a
reason to doubt the accuracy of that testimony? A. No, sir.
MS. HADDAD: ]'m going to object to these same questions you keep asking, because Mr. Rothstein has testified at nauseam that he doesn't recal] any of this and now you are asking him to bolster Mr. Edwards’ either already given or purported 4 testimony when he's testified he doesn't recall it. : BY MR. SCAROLA: |
Q. | want you to assume that Brad has or will
testify under oath that you never asked him once to report back to you on any factual matters repardi
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the Epstein case. Do you have any reason to doubt the
accuracy of that testimony? A. No, sir.
Q. 1] want you to assume that Brad has testified repeatedly that he had absolutely no involvement i in or ‘Knowledge of an ie il activity d any other RRA la Do you have any 1 reason to doubt the accuracy of that testimony?
A. No, sir.
Q. J want to talk to you briefly about your personal perceptions of the significance of the testimony that you are giving today. If Brad Edwards had, in fact, been a participant in any of the illegal ‘activities that you have been questioned about at any stage of this very lengthy deposition. and you
knowingly concealed Brad Edwards’ participation, what do you understand the personal consequences to be as a conset q uence of your having knowingly concealed Brad
Edwards participation?
A. I'l] be violating my agreement with the United States government and ] would run the risk of dying in prison,
Q. If Brad Edwards, contrary to what you have testified under oath and what Brad himself has
repeatedly said, knew about anything having to do with Page 123
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seater emcee
conseUenees of that false testimony to be to be?
A. J'll be violating my agreement with the United States government and ] would run the risk of. dying in prison,
MR. SCAROLA: Thank you. | don't have any further questions.
THE WITNESS: Thank you, sir.
MR. NURIK: Mark, 1 don't know what your time frame is on your hitigation, but the ability to receive the transcript, review it and prepare an errata sheet within what is normally the time allotted under the court rules cannot be accomplished in this case.
MR. GOLDBERGER: How much time are you generally --
MR. NURIK: | don't know.
Actually, the first set of errata sheets have just been prepared and finalized for the first deposition in December. I'm not suggesting it will take that long this time, but if you can give me an idea of what your time responsibilities are with the court, what the time limits are --
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MR. GOLDBERGER: Do you think it will be less than a month, two months?
MR. NURIK: J don't think it will be jess 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.
MR. GOLDBERGER: If time becomes an issue, we'll approach you and ask you to expedite.
MR. SCAROLA: Mark, ] will tell that from our perspective time is an issue.
MR. NURIK: Have at it then, Jack. Do what you need to do to get it done.
MR. SCAROLA: There is a long pending motion for summary judgment on Brad’s behalf that has been delayed for purposes of taking this deposition. We are very anxious to be able to call that motion for summary judgment up for hearing, so whatever can be done reasonably to expedite the preparation of this portion of this transcript would be appreciated.
We understand there are limitations beyond your control, but to the extent you can do it, that would be helpful. Thank you. Page 125
32 (Pages 122 to 125)
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