Epstein Secrets

d all email communications by/between any attorney and/or employee of the former Rothstein law firm, including but not limited to, Scott Rothstein, Russell Adler, Williaria Berger, Michael Fisten, Ken Jenne, David Boden, Deborah Villegas, Andrew Barnett, Patrick Roberts, Richard Fandry, Christina Kittennan,

by privilege, then a privilege log must be prepared and attached to the response, or the privilege is waived See TIG Insurance Corp. of America v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001) (stating that failure to provide a reason for privilege and prepare a privilege log constitutes waiver of the p

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

to Take Charge of Property of \4 7/ Epst1 dn to Post a $15 million Bond to Secure Potential ent, in Jane Doe v. Epstein Case No. 08-CV-80893- arra/Johnson. The motion was reported in the press as was the ultimate goal (i.e., to "pump" the cases for investor following). However, the Court found "Plaint

ant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 03088 04/11/2009 Epstein Litigation Russell Adler Litigation Strategy Work Productattorney client 28 EFTA00310075 Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & L

radley Edwards RE:Epstein Joint W/P Priv. 11560-11562 10/02/2009 Bradley Edwards Katherine Jacquie FW:Meeting w/Stanley Arkin Joint W/P Priv. Johnson 11444-11448 09/28/2009 Bradley Edwards Amy Ederi FW:Epstein Depo Joint W/P Priv. 05823 09/04/2009 Adam Horowitz Jacquie Johnson RE:Epstein