Epstein Secrets

She's your current secretary/paralegal, or 2 do you have a secretary as well? 3 A. I don't understand your question. 4 Q. Do you have -- is Beth Williamson your 5 paralegal? 6 A. She's a paralegal at the law firm of Farmer, 7 Jaffe, Weissing, Edwards, Fistos & Lehrman. 8 Q. Does she primarily w

9 A. I didn't tell you that. 10 Q. Okay. Let me ask you then: Did you ever 11 use Qtask, you personally create a project as it 12 related to Jane Doe's case against Mr. Epstein? A. No. 14 Q. To your knowledge did you direct anyone 15 well, let me strike that. Did you direct anyone to 16 crea

A00599740 Page 80 A. I'm finished. 2 Q. Which case was he the referring lawyer, Mr. Howell? 4 A. Q. And he may be the referring lawyer on Jane 6 Doe, and ., you just don't know as you sit here, 7 or he is? 8 A. He referred .'s case. 9 Q. And the other two cases is he is shown as 10 the

g, Edwards, Fistos & Lehrman PL and/or any other law firm through which you have provided legal services and/or any other lawyer and/or law firm to Beth Williamson in connection with any claims asserted against Jeffrey Epstein state, identify, and describe the amount of the payment, the date of payment, the sou

ssing, Edwards, Fistos & Lehrman PL and/or any other law firm through which you have provided legal services from any other lawyer and/or law firm, Jane Doe, any other purported victims, any investigators, paraprofessionals, any other contractors, and any publicity agents, public relations firms, book pu

g, Edwards, Fistos & Lehrman PL and/or any other law firm through which you have provided legal services and/or any other lawyer and/or law firm to Beth Williamson in connection with any claims asserted against Jeffrey Epstein state, identify, and describe the amount of the payment, the date of payment, the sou

rds, Fistos & Lehrman PL and/or any other law firm through which you have provided legal services from any other lawyer and/or law firm, L.M., E.W., Jane Doe, any other purported victims, any investigators, paraprofessionals, any other contractors, and any publicity agents, public relations firms, book pu

um of Law [DE 138) EXHIBIT B EFTA_R1_01464813 EFTA02406993 Case 9:08-cv-80119-KAM Document 547-2 Entered on FLSD Docket 05/17/2010 Page 2 of 2 Beth Williamson From: Tama Beth Kudman Sent: Monday. January 25,MINI To: Beth Williamson Subject: Re: Regarding: Epstein - Depo of Jean Luc Brunel I have ju

9-KAM Document 547-2 Entered on FLSD Docket 05/17/2010 Page 1 of 2 CASE NO: 08-CV-80119-MARRA/JOHNSON Notice of Supplemental Authority on Plaintiff Jane Doe's Motion for an Order to Show Cause and for an Order to Compel and Incorporated Memorandum of Law [DE 138) EXHIBIT B EFTA_R1_01464813 EFTA02406993

levant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 25738 08/03/2009 William Berger Beth Williamson Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evid

97 05/12/2009 Bradley Edwards Katherine Ezell RE:Jane Doe II v. Epstein Joint W/P Priv. 06901 09/11/2009 Bradley Edwards Mercedes Estrada Re:Jane Doe No. 101 & Jane Doe No. 102 vs. Epstein-Cross Notice Of Depos Joint W/P Priv. 06902 09/15/2009 Bradley Edwards Mercedes Estrada RE: Jane Doe N

irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02548-02553 08/03/2009 Beth Williamson Bradley Edwards Federal Subpoena Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery o

to lead to the discovery of the admissible evidence; protected by privacy rights 05541 07/31/2009 Carolyn Edwards Bradley Edwards All depos in Jane doe's case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; pr

levant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 25738 08/03/2009 William Berger Beth Williamson Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evid

ted to lead to the discovery of admissible evidence;protected by privacy rights 01080-01081 06/22/2009 Robert C. Buschel Bradley J. Edwards Jane Doe brother Attorney/Client privilege and/or work product 01077 05/28/2009 Robert C. Buschel Bradley J. Edwards Doe family member Attorney/Client p

irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02548-02553 08/03/2009 Beth Williamson Bradley Edwards Federal Subpoena Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery o

to lead to the discovery of the admissible evidence; protected by privacy rights 05541 07/31/2O09 Carolyn Edwards Bradley Edwards All depos in jane doe's case Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; pr

corporated Memorandum of Law fDE 138) EXHIBIT B EFTA01660119 Case 9:08-cv-80119-KAM Document 547-2 Entered on FLSD Docket 05/17/2010 Page 2 of 2 Beth Williamson From: Tama Beth Kudman [FIIIII I] Sent: Monday, January 25, To: Beth Williamson Subject: Re: Regarding: Epstein - Depo of Jean Luc Brunel I

, 08-80380, 08-80381, 08-80994, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-81092 NOTICE OF SUPPLEMENTAL AUTHORITY ON PLAINTIFF JANE DOE'S MOTION FOR AN ORDER TO SHOW CAUSE AND FOR AN ORDER TO COMPEL AND INCORPORATED MEMORANDUM OF LAW fDE 4831 Plaintiff, Jane Doe, hereby gives notice

view and prepare for filing a "complaint in Federal Court similar to the one we did for LM." See email dated September 18, 2009 from Brad Edwards to Beth Williamson. This complaint was to be filed on behalf of EW, another of Edwards' clients in the Epstein Cases for whom he also had been litigating a state cour

ck Funding, LLC, et aL v. Scott W. Rothstein, et aL, Case No. 09-062943(19); Deposition Transcript of Jeffrey Epstein. 502008CA028058XXXXMB AB; and Jane Doe v. Jeffrey Epstein, 08-80893- CIV Marra/Johnson. Rothstein returned to South Florida in November 2009 to face federal criminal charges and civil cl