Epstein Secrets

STOS, LEHRMAN, P.L. Attorneys for Plaintiff BY: BRADLEY J. EDWARDS, ESQ. HADDON, MORGAN AND FOREMAN, P.C. Attorneys for

fer facts to a jury, statements to a jury, that they are going to be then arguing are credible, and so we have this joinder motion, drafted by Mr. Edwards and Mr. Cassell, that they would like to introduce into evidence, whole cloth into evidence, that contains the legal arguments and the statements o

there's an additional argument from counsel. It was their motion, so if it is, then -- THE COURT: Yes. Okay. MR. EDWARDS: And by the way, this is Brad Edwards on behalf of Ms. but I believe it's their up. MS. MENNINGER: Your Honor, a couple more points. They are related to what was just articulated for

.L. Attorneys for Plaintiff BY: BRADLEY J. EDWARDS, ESQ. HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT REPORTERS, P.C. EFTA00592369 H3ulgiva (Case called) THE COURT: We have a problem, folks. By my count 4 5 6 7 8 9

, LEHRMAN, P.L. Attorneys for Plaintiff 20 BY: BRADLEY J. EDWARDS, ESQ. 21 HADDON, MORGAN AND FOREMAN, P.C. Attorneys

to 2 a jury, statements to a jury, that they are going to be then 3 arguing are credible, and so we have this joinder motion, 4 drafted by Mr. Edwards and Mr. Cassell, that they would like to 5 introduce into evidence, whole cloth into evidence, that 6 contains the legal arguments and the statem

tional 19 argument from counsel. It was their motion, so if it is, 20 then -- 21 THE COURT: Yes. Okay. 22 MR. EDWARDS: And by the way, this is Brad Edwards on 23 behalf of Ms. but I believe it's their up. 24 MS. MENNINGER: Your Honor, a couple more points. 25 They are related to what was just arti

ys for Plaintiff 20 BY: BRADLEY J. EDWARDS, ESQ. 21 HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant 22 BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. EFTA00794367 (212) 805-0300 EFTA00794368 2 H3ulgiva 1 2 (Case called) 3 THE COURT: W

as alleged, was almost unspeakable." App. p 569. Plaintiff's counsel piled on, offering their own opinions about Ms. Maxwell's guilt. For example, Bradley Edwards opined that Ms. Maxwell was "a main facilitator" of Epstein's crimes who "started the whole thing." App. p 569. And Sigrid McCawley praised the pro

about Ms. Maxwell's guilt. For example, Bradley Edwards opined that Ms. Maxwell was "a main facilitator"

, SCHILLER & FLEXNER, LLP 16 Attorney for Plaintiff BY: SIGRID S. MCCAWLEY 17 HADDON, MORGAN, AND FOREMAN, P.C. 18 Attorney for Defendant BY: LAURA A. MENNINGER 19 20 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00075527 Case 20-2413, Document40,08/20/2020. 2913550. Page52 o

tem 18 then is defamation litigation. And your Honor is aware that there was a separate lawsuit that's spun out of this situation where Cassell and Edwards filed a defamation action in Florida State Court against Alan Dershowitz. Alan. Dershowitz then counterclaimed. That was litigated in Florida Stat

forth because we think it's irrelevant. But if there was to be some kind of an attack launched on any of the members of the Boies Schiller Firm, of Brad Edwards, myself, we would ask that we be given leave to address that at sidebar, in-camera, or outside the presence of the jury SOUTHERN DISTRICT REPORTERS

IVERSITY OF UTAH For Plaintiff BY: PAUL G. CASSELL, ESQ. HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00612250 H3VOGIU1 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19

E OF REPORTER 157 9 i VOLUME 2 (Pages 158 - 258) | VIDEOTAPED DEPOSITION OF TONY FIGUEROA 10 ; lime TFS TONY FIGUEROA | dd. Cross-Examination by Mr. Edwards 162 i Pages 1- 157 Redirect Examination by Ms. Menninger 218 ' 12 Recross-Examination by Mr. Edwards 243 Taken at the Instance of the Defendant Furth

osition wou e waived. Page 2 Page 4 1 APPEARANCE OF COUNSEL 1 INDEX OF EXHIBITS | 2 2 | 3 3 4 ON BEHALF OF THE PLAINTIFF: MARKED BY THE DEFENDANT:) 5 BRADLEY J. EDWARDS, Esquire Defendant's Exhibit 1 42 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 5 (Palm Beach County Sheriff's Reports - i 6 425 North And

[email protected] 8 Defendant's Exhibit 3 7 9 (Two Pictures of Apartment Building) i 9 10 ON BEHALF OF THE DEFENDANT: Defendant's Exhibit 4 83 il LAURA A. MENNINGER, Esquire 0 (Palm Beach County Sheriff's Reports - | Haddon, Morgan and Foreman, P.C. Case Number 02075321) 12 oe Fas ae 03 Defendant's Exhibit 5 134

tem 18 then is defamation litigation. And your Honor is aware that there was a separate lawsuit that's spun out of this situation where Cassell and Edwards filed a defamation action in Florida State Court against Alan Dershowitz. Alan Dershowitz then counterclaimed. That was litigated in Florida State

forth because we think it's irrelevant. But if there was to be some kind of an attack launched on any of the members of the Boies Schiller Firm, of Brad Edwards, myself, we would ask that we be given leave to address that at sidebar, in-camera, or outside the presence of the jury SOUTHERN DISTRICT REPORTERS

THE UNIVERSITY OF UTAH For Plaintiff BY: PAUL G. CASSELL, ESQ. HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. SOUTHERN DISTRICT R (212) 805- PORT 0300 ERS, HOUSE_OVERSIGHT_011304 10 id. 12 13 14 L5 16 ne) 18 life) 20 21 22 23 24 25

confidante. She is a self-described advocate. In many instances throughout this ordeal, Ms. Churcher was acting as a source of information to Mr. Edwards, who is another lawyer who has entered an appearance in this case, and to law enforcement. The Shield Law only applies when journalists are asked

Attorneys for Plaintiff BY: SIGRID S. McCAWLEY MEREDITH L. SCHULTZ HADDON MORGAN AND FOREMAN, P.C. Attorneys for Defendant BY: JEFFREY PAGLIUCA LAURA A. MENNINGER DAVIS WRIGHT TREMAINE LLP Attorneys for Respondent Sharon Churcher BY: ERIC J. FEDER LAW OFFICES OF Attorneys BY: GREGORY L. RACHEL S. GREGOR

24 185-15. Copy of a transcript of the Scarola/Edwards 25 interview of April 7, 2011. Unseal in full.

, SCHILLER & FLEXNER, LLP 16 Attorney for Plaintiff BY: SIGRID S. MCCAWLEY 17 HADDON, MORGAN, AND FOREMAN, P.C. 18 Attorney for Defendant BY: LAURA A. MENNINGER 19 20 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. EFTA00074941 Case 20-2413, Document 10-9,07/30/2020, 2896538, Page2 of 17 K7N9GIUD

hen is defamation litigation. And your Honor 10 is aware that there was a separate lawsuit that's spun out of 11 this situation where Cassell and Edwards filed a defamation 12 action in Florida State Court against Alan Dershowitz. Alan 13 Dershowitz then counterclaimed. That was litigated in Florid

UTAH For Plaintiff 18 BY: PAUL G. CASSELL, ESQ. 19 HADDON, MORGAN AND FOREMAN, P.C. Attorneys for Defendant 20 BY: JEFFREY S. PAGLIUCA, ESQ. LAURA A. MENNINGER, ESQ. 21 22 23 24 25 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00794556 2 H3VOGIU1 1 (Case called) 2 THE COURT: Like all of