Epstein Secrets

the manner in which the cases were handled while Edwards was a partner at RRA: Q: The one meeting that you had in Mr., Mr. Rothstein's office with Russell Adler and some unknown person on the phone, were you given any direction at that time that certain discovery should be done or certain tactics should be

nswering. Id. at page 89; lines 4-8. Q: With regard to E.W. you filed a case — well, let me ask you this: Do you know how E.W. come to contact Mr. Howell? Did he ever relate that to you? Id. at page 89; lines 9 -12. MR. SCAROLA: If it's in information that you obtained from your client, I instruct y

R. SCAROLA: If it's in information that you obtained from your client, I instruct you not to answer. If it's information that you obtained from Mr. Howell, I also instruct you not to answer. Both instructions are on the basis of attorney-client and work-product privileges. Id. at page 89; lines 3-19.

the manner in which the cases were handled while Edwards was a partner at RRA: Q: The one meeting that you had in Mr., Mr. Rothstein's office with Russell Adler and some unknown person on the phone, were you given any direction at that time that certain discovery should be done or certain tactics should be

nswering. Id. at page 89; lines 4-8. Q: With regard to E.W. you filed a case — well, let me ask you this: Do you know how E.W. come to contact Mr. Howell? Did he ever relate that to you? Id. at page 89; lines 9 -12. MR. SCAROLA: If it's in information that you obtained from your client, I instruct y

R. SCAROLA: If it's in information that you obtained from your client, I instruct you not to answer. If it's information that you obtained from Mr. Howell, I also instruct you not to answer. Both instructions are on the basis of attorney-client and work-product privileges. Id. at page 89; lines 3-19.

RT REPORTING AGENCY, INC. EFTA00599725 Page 65 1 before joining them? 2 A. People that I would consider to be my friend, yes. Q. Who. A. Russell Adler. 6 Q. And how did you know Mr. Adler? A. We worked out at the same gym for about, 8 approximately four or five years. 9 Q. What were you do

RA, if those cases had resolved 11 during that time period, RRA, you would have paid 12 RRA that portion to which you were been entitled and 13 Howell and a Cassell would have gotten their 14 percentage? 15 A. Correct. 16 Q. And with regard to, with the new firm, the 17 Farmer, Jaffe firm,

ose cases there was a, 13 there is also another lawyer that was involved -- 14 well, let me strike that. In one or more of those 15 cases is Mr. Howell involved, or was he at the time 16 you were a solo practitioner? 17 A. What do you mean by involved? 18 Q. Involved, was he a referring lawye

Fowler WhiteATBmuNEr,p S meLtAt,)p MEMORANDUM TO: File FROM: Susan H. Aprill DATE: April 18, 2011 RE: Outline of deposition of Russell Adler, former RRA partner FILE NO.: 80743 DRAFT 4 18 11 8:21 PM Epstein v. Rothstein & Edwards Outline for Russell Adler Deposition, 4-20-11 @ 9:30 a

d BE bring active filed cases agst JEE to RRA when he joined? 14.9 Did you know 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