Epstein Secrets

mation derived from documents or data over which a claim of privilege was asserted by or on behalf of Rothstein Rosenfeldt Adler PA; Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.; or Bradley J. Edwards. MR. LINK: I think -- which subpoena duces tecum are you looking at, Jack? Which DRAFT !!

unsel to the bankruptcy trustee. A I don't recall. Q Did you ever come to learn that the trustee in the bankruptcy for the law firm Rothstein, Rosenfeldt & Adler, had been subpoenaed to produce emails contained on the server of that law firm? A I don't recall. DRAFT !!!! NOT PROOFREAD EFTA00804174 14

of the foregoing was sent by fax and U.S. Mail to the following addressees on this IF day of June, 2010: Gary M. Farmer, Jr., Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Attorneys for Defendant, Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss,

t Court, Southern District of Florida, Miami Division, under Your name, Florida Bar number and e-mail address while you were employed by Rothstein, Rosenfeldt & Adler ("RRA"). 19. Admit that the Complaint (DE #1) in Case No. 09-CV-81092 is two hundred thirty-four (234) pages, contains six hundred forty-four (644

B. 52. Admit that the individual who signed the Complaint (DE #1) in Case No. 09-CV-81092 is currently a partner at the law firm of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL. EFTA00722589 Epstein v. Rothstein. et al. Case No. 50 2009CA040800XXXXMB AG Epstein's First Request for Admissi

t Court, Southern District of Florida, Miami Division, under your name, Florida Bar number and e-mail address while you were employed by Rothstein, Rosenfeldt & Adler ("RRA"). 3. Admit that the Complaint (DE #1) in Case No. 09-CV-81092 is two hundred thirty-four (234) pages, contains six hundred forty-four (644

80069, 08-80119, 08- 80232, 08-80380, 08-80381, 08-80993, 08- 80994 C. Josefsberg, Esq. Katherine W. Ezell, Esq. 7 Edwards, Esq. Farmer , Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Phone: 954-524-2820 Fax: 954-524-2822 Counsel for Plain

in which he granted a protective order regarding the depositions of Michael Fisten and Rick Fandrey, investigators previously employed by Rothstein, Rosenfeldt & Adler ("RRA"). As the Court may recall, RRA represented Jane Doe prior to its implosion. 5 EFTA00728108 16. While Epstein sought to depose Mr. Fisten

tion derived from documents or data over which a claim of privilege was asserted by or on behalf of Rothstein, Rosenfeldt, Adler PA; Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.; or Bradley J. Edwards? MR. LINK: I think -- which subpoena duces tecum are you looking at, Jack? Which case? MR

of 165 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 in the bankruptcy for the law firm Rothstein, Rosenfeldt & Adler had been subpoenaed to produce emails contained on the server of that law firm? A I don't recall. Q Did it ever come to your attention that ema

supplements thereto, memorializing, any and all arrangements that you, any law firm through which you have provided legal services, Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman PL and/or any other lawyer and/or law firm have or at any time during the period in question had with any and all attorn

reimbursement of costs and expenses or in payment for legal services rendered. 9. A copy of all documents reflecting payments by you, Rothstein, Rosenfeldt & Adler, Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman PL and/or any other law firm through which you have provided legal services and/or an other law