Epstein Secrets

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

12 Who at the firm helped Scott create or operate the Epstein investments? EFTA00600188 April 18, 2011 Page 10 DRAFT 4 18 11 8:21 PM 19.13 Did Villegas know about JEE deals? 19.14 Know Michael Szafranski (or of him)? 19.14.1 If yes, explain role of Szafranski regarding JEE cases? 19.14.2 He was an

re In this IS roughly 70-lawyer firm? 19 30 31 A I think there were about 10. Q And who were the other shareholders? A Stuart Rosenfeldt, Russell Adler, Lea 22 Streltfeld, Steve Lippman. There were others -- Mare 23 think might have been -- - pretty sure Hunk was a 24 shareholder. I just do

tims' 165:14 video 55:6 166:16 videographer 2:21 4:1.12 55:2,5 131:2,5 146:9,12 169:5 videotaped 1:13 3:3 4:4 6:12 view 105:1 145:11 158:10 Villegas 138:13 violation 165:3 violently 92:21 visually 70:5 voice 84:6 voluntarily 106:13 106:19 168:20 volunteering 51:14 voting 14:20,25 vs 1:7

A00795602 Epstein v. RRA, et al. Page 16 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Berger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were asked of EPSTEIN which had no bearing o

a 249 page Amended Complaint naming additional Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David an, ebbie Villegas, Andrew Barnett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which fals