Epstein Secrets

nvestigative techniques and other Epstein matters; j) In the month of September, 2009, emails were exchanged between Edwards and William Berger ("Berger"), a partner at RRA who also participated in the Epstein actions, regarding Litigation Strategy. k) On September 11, 2009, Edwards sent an email t

assets to avoid paying any judgments that may be obtained by RRA clients against Epstein; g) On August 13, 2009 an email was sent from Rothstein to Mark Nurik ("Nurik"), an attorney at RRA, regarding legal research on causes of action against Epstein. On - 6 - FOWLER WHITE BURNETT P.A. • 901 PHILLIPS POI

ORIDA 33401 • (561) 802-9044 EFTA00584200 Epstein v Rothstein, Edwards Case No.: 502009CA040800XXXXMBAG Second Amended Complaint that same day, Nurik sent an email to Rothstein regarding discussions about Epstein. Also on August 13, 2009, Adler sent an email to Rothstein regarding legal research o

nvestigative techniques and other Epstein matters; j) In the month of September, 2009, emails were exchanged between Edwards and William Berger ("Berger"), a partner at RRA who also participated in the Epstein actions, regarding Litigation Strategy. k) On September 11, 2009, Edwards sent an email t

assets to avoid paying any judgments that may be obtained by RRA clients against Epstein; g) On August 13, 2009 an email was sent from Rothstein to Mark Nurik ("Nurik"), an attorney at RRA, regarding legal research on causes of action against Epstein. On that same day, Nurik sent an email to Rothstein reg

as sent from Rothstein to Mark Nurik ("Nurik"), an attorney at RRA, regarding legal research on causes of action against Epstein. On that same day, Nurik sent an email to Rothstein regarding discussions about Epstein. Also on August 13, 2009, Adler sent an email to Rothstein regarding legal research o

cheme. EFTA00795602 Epstein v. RRA, et al. Page 16 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Berger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were asked of EPSTEIN which

CERTIFICATE OF SERVICE I certify that on this 3rd day of November, 2009, with the agreement and consent of Defendant Scott W. Rothstein's counsel, Mark Nurik, Esq., a true and correct copy of the above and foregoing was served via email on Mr. Nurik, at [email protected]. This 3rd day of November, 2009.

consent of Defendant Scott W. Rothstein's counsel, Mark Nurik, Esq., a true and correct copy of the above and foregoing was served via email on Mr. Nurik, at [email protected]. This 3rd day of November, 2009. 'Si Fla LA M. Baia.i 9 COFFEY B URLINGTON OFFICE IN THE. GROVE, PENTHOUSE 2699 SOU I H

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

f them wore appealed. I wa➢ reversed a number of times. 23 0 Rough gue➢➢? 24 A I Couldn't tell you. I couldn't tell you how 2S many [limos. Nurik or Rothstein -- did they feel bullied or 2 threatened by Epstein lawyer➢? MR. SCAAOLA: Objection, predicate. 4 THE WITNESS: You are assuming tha

cheme. EFTA00596503 Epstein v. RRA, et al. Page 16 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Berger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were asked of EPSTEIN which

and consent of Defendant Scott W. Rothstein's counsel, Mark Nurik E a true and correct copy of the above and foregoing was served via email on Mr. Nurik, at This 3rd day of November, 2009. s; S 9 COFFEY B URLINGTON OI+ICk IN THE DROVE. PENTHOUSE 2699 SOUTH SAYSHORE DRIVE MIAMI, FLORIDA 33 133

can access it. 16 Q. So, if it was, as an example, if it was, 17 if you were the lead person and you invited 18 Mr. Adler and you invited Mr. Berger in and 19 Mr. Rothstein in, there, when you punched up the 20 Qtask on the screen, I would see Mr. Rothstein's 21 picture. I would see yours. I

9680 Page 20 1 behalf; that is, who purports to represent 2 Mr. Rothstein since you left the firm that day? 3 A. No. 4 Q. Do you know Mr. Nurik? 5 A. Yes. 6 Q. Do you recog -- are you aware that he 7 represents Mr. Rothstein? A. Yes. 9 Q. Okay. Have you spoken with him since that

cheme. EFTA00729418 Epstein v. RRA, et al. Page 16 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Berger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were asked of EPSTEIN which

d consent of Defendant Scott W. Rothstein's counsel, Mark Nurik Es , a true and correct copy of the above and foregoing was served via email on Mr. Nurik, at This 3rd day of November, 2009. M.P ICSAM 9 COFFEY B 1./RLINGTON OFFICE IN THE GROVE, PENTHOUSE 2699 SOUTH BAYSHORE DRIVE MIAMI, FLORIDA