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persons purporting to be affiliated with RRA, including without limitation, Mike Fisten, Ken Jenne, Wayne Black, Patrick Patrick Diaz, Rick Fandry, Cara Holmes, William Berger, Russell Adler and Mark Nurik, or any other representatives of or persons purporting to be affiliated with RRA or representing them
rting to be affiliated with RRA, including without limitation, Mike Fisten, Ken Jenne, Wayne Black, Patrick Patrick Diaz, Rick Fandry, Cara Holmes, William Berger, Russell Adler and Mark Nurik, or any other representatives of or persons purporting to be affiliated with RRA or representing themselves to have k
urporting to be affiliated with RRA, including without limitation, Mike Fisten, Ken Jenne, Wayne Black, Patrick Roberts, Patrick Diaz, Rick Fandry, Cara Holmes, William Berger, Russell Adler and Mark Nurik, or any other representatives of or persons purporting to be affiliated with RRA or representing them
be affiliated with RRA, including without limitation, Mike Fisten, Ken Jenne, Wayne Black, Patrick Roberts, Patrick Diaz, Rick Fandry, Cara Holmes, William Berger, Russell Adler and Mark Nurik, or any other representatives of or persons purporting to be affiliated with RRA or representing themselves to have k
l documents which might otherwise be construed to be outside its scope. 5. "Epstein" means the Plaintiff. 6. "Holmes" "You" or "Yours" refers to Cara Holmes. 7. "Edwards" means Defendant Bradley J. Edwards. "Rothstein" means Defendant Scott Rothstein. "RRA" or the "Firm" means Rothstein Rosenfeldt Adle
llance, incidents of misconduct or claims against Epstein from September 2008 to the present: a. Rothstein; b. Edwards; c. Russell Adler; d. William Berger; e. Mike Fisten; f. Ken Jenne; g. Wayne Black; h. Patrick Roberts; i. Patrick Diaz 2. All written communications between you and any of t
on meeting. On July 23, 2009, Priscila Nascimento, one of the secretaries to Rothstein, was advised of the scheduled meeting; e) On July 29, 2009, Cara Holmes, an attorney at RRA working on the Epstein cases, and a former agent for the Federal Bureau of Investigation, sent an email to Edwards stating that
ions discussing investigative 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 a
on meeting. On July 23, 2009, Priscila Nascimento, one of the secretaries to Rothstein, was advised of the scheduled meeting; e) On July 29, 2009, Cara Holmes, an attorney at RRA working on the Epstein cases, and a former agent for the Federal Bureau of Investigation, sent an email to Edwards stating that
ions discussing investigative 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 a
Entities connected to both Cara Holmes and William Berger

Jeffrey Epstein
PERSONScott Rothstein
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSONLeon Black
PERSONJack Goldberger
PERSONJack Scarola
PERSON
Alan Dershowitz
PERSONJane Doe
PERSONRussell Adler
PERSONMaria Farmer
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSON
Donald Trump
PERSON
Ken Jenne
PERSONSpencer Kuvin
PERSON
Michael Fisten
PERSONMike Fisten
PERSONBerger
PERSONthe Southern District
LOCATION