Epstein Secrets

as made available for her deposition, which she was in April, 2010. See Affidavit of Michael J. Pike attached as Exhibit F and 10/13/09 E-mail from Spencer Kuvin attached as Exhibit G. While counsel for Jane Doe did not confirm this agreement in writing, he represented same in the aforementioned telephone co

hed as Exhibit F and 10/13/09 E-mail from Spencer Kuvin attached as Exhibit G. While counsel for Jane Do

XMBAG, Judge Crow entered an order on April 19, 2010 (attached as I Exhibit H), 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 pri

its implosion. 5 Case 9:08-cv-80119-KAM Document 536 Entered on FLSD Docket 04/29/2010 Page 6 of 8 16. While Epstein sought to depose Mr. Fisten and Mr. Fandrey regarding their knowledge of Scott Rothstein's Ponzi scheme, the Court nevertheless entered a protective order prohibiting their de

as made available for her deposition, which she was in April, 2010. See Affidavit of Michael J. Pike attached as Exhibit F and 10/13/09 E-mail from Spencer Kuvin attached as Exhibit G. While counsel for Jane Doe did not confirm this agreement in writing, he represented same in the aforementioned telephone co

hed as Exhibit F and 10/13/09 E-mail from Spencer Kuvin attached as Exhibit G. While counsel for Jane Do

OOOCMBAG, Judge Crow entered an order on April 19, 2010 (attached as Exhibit H), 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 pri

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 and Mr. Fandrey regarding their knowledge of Scott Rothstein's Ponzi scheme, the Court nevertheless entered a protective order prohibiting their de

ads). Finally, at the deposition of Detective Recarey of the Palm Beach Police Department, on March 19, 2010, the following exchange occurred: Mr. Kuvin: Okay. And what were the dates of the surveillance? Witness: [Referencing his Report] It appears she met with members of the B.S.F. unit, Burglary

st which delineates alleged victims. Once the NPA was made public, Judge Colbath, with the agreement of the Palm Beach Post, Brad Edwards, Esq. and Spencer Kuvin, Esq. agreed that the "list" would remain private. As such, Request for Production Numbers 7, 9 and 10 seeks information that may violate others thi

ld this court order production of same after an in camera inspection) must be redacted to secure the names of unsuspecting third-parties. Moreover, Michael Fisten (formerly an employee of RRA and now an employee/independent contractor of Mr. Edwards' firm) acted, upon information and belief, as a broker or mid

ads). Finally, at the deposition of Detective Recarey of the Palm Beach Police Department, on March 19, 2010, the following exchange occurred: Mr. Kuvin: Okay. And what were the dates of the surveillance? Witness: [Referencing his Report] It appears she met with members of the B.S.F. unit, Burglary

t of the Palm Beach Post, Brad Edwards, Esq. and Spencer Kuvin, Esq. agreed that the "list" would remain private

ld this court order production of same after an in camera inspection) must be redacted to secure the names of unsuspecting third-parties. Moreover, Michael Fisten (formerly an employee of RRA and now an employee/independent contractor of Mr. Edwards' firm) acted, upon information and belief, as a broker or mid

he Federal Bureau of Investigations 19. Spencer Kuvin, Esquire 1800 S. Australian Avenue, #400 West P

stodian of United States Attorney's Office for the Southern District of Florida 18. Records Custodian of the Federal Bureau of Investigations 19. Spencer Kuvin, Esquire 1800 S. Australian Avenue, #400 West Palm Beach, Florida 33409 2-3 Expected to testify about the malicious prosecution elements of absenc

erg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 83. David Co field (David Seth Kokin) LAS VEGAS, NV 89135 84. 85 Michael Fisten Weston, FL 86 Russell Adler Delray Beach, FL 87. Marie Alessi BOYTON BEACH, FL 33472 88. Janusz Banasiak 358 EL BRILLO WAY PALM BEACH FL,

rles Gerald 4/19/10 Prose Court Rep Noticed by Kuvin Goldsmith 9:30 a.m. 250 S. Australian (RDC)

10 Veritext Corp. Noticed by Custodian — New York 10:30 a.m. 1250 Broadway, Suite 2400 Mermelstein Strategy Group NY, NY 10001 Epstein v. Michael Fisten 4/19/10 101 Business Noticed by Jess RRA 10:00 a.m. Center, 101 NE Third Ave., #1500 Ft. Lauderdale, FL Epstein v. Richard Fandry 4/19/10

rles Gerald 4/19/10 Prose Court Rep Noticed by Kuvin Goldsmith 9:30 a.m. 250 S. Australian (RDC)

10 Veritext Corp. Noticed by Custodian — New York 10:30 a.m. 1250 Broadway, Suite 2400 Mermelstein Strategy Group NY, NY 10001 Epstein v. Michael Fisten 4/19/10 101 Business Noticed by Jess RRA 10:00 a.m. Center, 101 NE Third Ave., #1500 Ft. Lauderdale, FL Epstein v. Richard Fandry 4/19/10

Q. And this was shortly before the fu•st day of 10 the current deposition? 11 A. Yes. 12 Q. And you wrote a report about meeting with 13 Mr. Kuvin? 19 A. Ult•hult 15 Q. And that tt.po. t is available to us as a public 16 record? 17 A. Yes. It's with the case number. 18 Q. And the case

stigation? 11 A. Not that I'm aware of. 12 Q. Did he ever tell you that he had any 13 communications with Mr. Jenne, or Mr. Fandrey or 14 Mr. Fisten? 15 A. Not that fin aware of. 16 Q. And have you ever seen any note, report, 17 document, memorandum, e-mail or log entry in the Palm 18 Beac