Epstein Secrets

9 1665 Palm Beach Lakes Boulevard, Suite 1001 $ 9:27 West Palm Beach, FL 33401 4 This is the videotaped deposition of 4 1561) 471-2995 5 Berger in the matter of Jeffrey 5 APPEARANCES: 6 For Plaintiff: 4 Epstein versus Scott Rothstein and Bradley 7 LINK 4 ROCKENBACH, . Edwards. 1555

November of 23 2009. 24 Q Approximately 18 months -- about year and a 25 half? represented another law firm in a breakup of firma 2 And the Scherer firm waa owed over a million 4 5 4 7 • In Coos. And the client, the other law firm, was reneging on paying that. And Scherer won at the tria

even though the offices I worked II before you would file it, right? 12 out of wore in Miami. And I have heard of the Conrad 12 A Right. 13 Scherer firm throughout my practice. II Q Would you note every single fact that 14 4) You said one of the things in your direct 14 existed at the tim

ts against 21 22 the trustee. That left us in a quandary. 72 23 23 We had a subpoena pending in State 24 24 Court. We had correspondence from Berger 25 25 Singcrman on behalf of the trustee dist they had °UM-LEITH & MAULDIN COURT REPORTERS, (305) 3584875 EFTA00206624 Case 9:08-cv-80893-KAM

d 24 pectedings wen had: 24 to me. 25 Rebated EN Malin Fit= 25 MR. LICHTMAN: Correct, Judge. Paget Page 4 I APPEARANCES: I THE COURT: Mr. Scherer. 2 3 DERV-RW/90SW" to 2 MR. SCHERER: Yes, sir, your Honor. CHARLES H. LICHTMAN, ESQUIRE 3 I'm William Soberer and Ern here on behalf of a 4

ts against 21 22 the trustee. That left us in a quandary. 72 23 23 We had a subpoena pending in State 24 24 Court. We had correspondence from Berger 25 25 Singcrman on behalf of the trustee dist they had °UM-LEITH & MAULDIN COURT REPORTERS, (305) 3584875 EFTA00213917 Case 9:08-cv-80893-KAM

d 24 pectedings wen had: 24 to me. 25 Rebated EN Malin Fit= 25 MR. LICHTMAN: Correct, Judge. Paget Page 4 I APPEARANCES: I THE COURT: Mr. Scherer. 2 3 DERV-RW/90SW" to 2 MR. SCHERER: Yes, sir, your Honor. CHARLES H. LICHTMAN, ESQUIRE 3 I'm William Soberer and Ern here on behalf of a 4

rts against 21 22 the trustee. That left us in a quandary. n 23 We had a subpoena pending in State 73 24 24 Court. We had correspondence from Berger 75 25 Singerman on behalf of the trustee dist they had OUELLETTE & MAULDIN COURT REPORTERS, EFTA00235301 Case 9:08-cv-80893-KAM Document 214-3

proccedino were had: 24 to me. 25 Repotted By: Mutant Franz= 25 MR. LICHTMAN: Correct, Judge. Page 2 Page 4 1 APPEARANOIS 1 THE COURT: Mr. Scherer. 7 3 BERGER 8/910BILMAN. try 2 MR. SCHERER: Yes, sir, your Honor. CHARLES H. WHOA" ESQUIRE 3 I'm William Scherer and I'm here on behalf of a

t, from Mr. Scherer's Complaint, it is the partners and people who held themselves out to be partners of the Roth -- Scott Rothstein, including Mr. Berger, Mr. Adler, Mr. Edwards and other people associated with the firm like Mr. Fisten, Diane Villegas, if that's how you pronounce her name, Russell Ad

e unsuspecting investors out of millions of dollars. The U.S. Attorney's Complaint alleges his firm engaged in a corrupt criminal enterprise. Mr. Scherer's Complaint alleges monstrous amounts of fraud and discovery abuse. I have no personal knowledge, separate from the attorney/client privileged inf