Epstein Secrets

uld not respond on the basis of privilege. Id. at page 288; line 15-21. A: Privilege. Id. at page 288; line 22. Counsel for Epstein then discusses Ken Jenne: Q: Did Mr. Jenne, did you ever direct Mr. Jenne to do any investigation on the Epstein cases? Transcript of Deposition dated March 23, 2010, at pa

AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o

reet, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00799405 lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., has Mr. Howell participated in the case; that is, has he done work on the case? Id. at page 90; lines 20-23. A: Yes. Id. at page 90; line 24. Q:

uld not respond on the basis of privilege. Id. at page 288; line 15-21. A: Privilege. Id. at page 288; line 22. Counsel for Epstein then discusses Ken Jenne: Q: Did Mr. Jenne, did you ever direct Mr. Jenne to do any investigation on the Epstein cases? Transcript of Deposition dated March 23, 2010, at pa

AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o

Attorney-Client and work-product privileges. Id. at page 89; lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., 3 It is significant to note that other jurisdictions have sanctioned counsel for just this behavior during deposition. See e.g. Van Pilsum v. Iow

s, bugs, other listening and watching)? 21.9.6 What is Blue Line R & D? 21.10 Knowledge of skills and involvement of: 21.10.1 Mike Fisten 21.10.2 Ken Jenne 21.10.3 Patrick 21.10.4 Rick Fandry 22. Criminal History - have you ever been convicted of a crime? If yes, when and for what? C:WserAill0JAVIM

Paul Cassell? If yes, since when and how did you meet? 14.10 A Mr. Howell? same as for Cassell. 14.11 3 files: State court was ■. (Jane Doe # 2), E.W. (Jane Doe #1) and . 14.12 Who staffed the Epstein files? 14.12.1 BE testified that you Judge Stone, Bill Berger and Rob Buschell worked on cases?

ion of Jeffrey Epstein? MR. SCAROLA: Same objection [work-product, attorney-client privilege]. Id., at 201. Q. [D]id you ever authorize or direct Ken Jenne to perform any investigation on the Epstein files? MR. SCAROLA: Same objection [work-product, attorney-client privilege] and instruction. 12. Co

answer the threshold "yes" or "no" question: Did [Mr. Howell] ever relate that to you." Id. 9. Edwards in one instance when asked what his client E.W. told him on the phone, himself claimed privilege. Id. at 90. Later, when asked "for what purpose did Ms. L.M. originally hire you?," his attorney o

irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01787-01788 09/04/2009 Ken Jenne Bradley J. Edwards 1. Accountants 2. Motion for IME Work product; attorney/client privilege; irrelevant and not reasonably calculated to lea

ed to lead to the discovery of the admissible evidence; protected by privacy rights 07025-07027 10/29/2009 Bradley Edwards Paul Cassell ■. and E.W. v. Epstein — Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evide

A employed a team of investigators on the Epstein Actions, including Michael Fisten ("Fisten") and former Broward County Sheriff and convicted felon Ken Jenne ("Jenne"). 12. Fisten and Jenne were the primary investigators assigned to Edwards, and routinely reported to Edwards and Rothstein regarding thei

state court civil action on behalf of L.M. 31. On or about October 17, 2009, Edwards, who had filed a state complaint against Epstein on behalf of E.W., emailed his assistant to file a federal complaint against Epstein on behalf of E.W like the one he had filed in federal court on behalf of L.M.. 3