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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
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:
FTA00190040 Epstein'. RRA, et at 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
se cases involving Epstein); b. Reached agreements to share attorneys fees with non-lawyers; c. Used investor money to pay plaintiffs (i.e., L.M., E.W. and Jane Doe) "up front" money such that plaintiffs would refuse to settle the Civil Actions; d. Conducted searches, wiretaps or intercepted conver
ed she worked at eleven (11) separate strip clubs, including Cheetah which RRA represented and in which ROTHSTEIN may have owned an interest; and E.W. also worked at Platinum Showgirls in Boynton Beach, which was the subject of a recent police raid where dancers were allegedly selling prescriptio
A00596503 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
se cases involving Epstein); b. Reached agreements to share attorneys fees with non-lawyers; c. Used investor money to pay plaintiffs (i.e., L.M., E.W. and Jane Doe) "up front" money such that plaintiffs would refuse to settle the Civil Actions; d. Conducted searches, wiretaps or intercepted conver
ed she worked at eleven (11) separate strip clubs, including Cheetah which RRA represented and in which ROTHSTEIN may have owned an interest; and E.W. also worked at Platinum Showgirls in Boynton Beach, which was the subject of a recent police raid where dancers were allegedly selling prescriptio
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
se cases involving Epstein); b. Reached agreements to share attorneys fees with non-lawyers; c. Used investor money to pay plaintiffs (i.e., L.M., E.W. and Jane Doe) "up front" money such that plaintiffs would refuse to settle the Civil Actions; d. Conducted searches, wiretaps or intercepted conver
ed she worked at eleven (11) separate strip clubs, including Cheetah which RRA represented and in which ROTHSTEIN may have owned an interest; and E.W. also worked at Platinum Showgirls in Boynton Beach, which was the subject of a recent police raid where dancers were allegedly selling prescriptio
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
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
TA00193786 Epstein'. 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
se cases involving Epstein); b. Reached agreements to share attorneys fees with non-lawyers; c. Used investor money to pay plaintiffs (i.e., L.M., E.W. and Jane Doe) "up front" money such that plaintiffs would refuse to settle the Civil Actions; d. Conducted searches, wiretaps or intercepted conver
ed she worked at eleven (11) separate strip clubs, Including Cheetah which RRA represented and in which ROTHSTEIN may have owned an interest; and E.W. also worked at Platinum Showgirls in Boynton Beach, which was the subject of a recent police raid where dancers were allegedly selling prescriptio
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
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?
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
S to strike. 14 THE MITNESS: Ho. Is BY MR. SCAROLA: IS Q If Jeffrey Epstein alleges in this 19 complaint against Bradley Edwards that III., E.W. or 24 Jane Doe voluntarily consented to their sexual 21 molestation, could Jeffrey Epstein have possibly made 22 that claim on the basis of any
ege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01940 09/10/2009 Russell Adler Bradley J. Edwards Witness Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery
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
ony, many RRA attorneys conferred and were involved with the prosecution of the Epstein Actions, including as described below: a) On May 3, 2009, Russell Adler ("Adler"), a name partner in RRA, who took part with Edwards in the prosecution of the Epstein Actions, sent an email to the staff and attorneys in
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
Entities connected to both Russell Adler and E.W.

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSONScott Rothstein
PERSONJack Goldberger
PERSONJane Doe
PERSONMaria Farmer
PERSON
Alan Dershowitz
PERSONJack Scarola
PERSON
Kenneth Marra
PERSON
Donald Trump
PERSONRobert D. Critton
PERSON
Paul Cassell
PERSON
Weissing
PERSON
Bill Clinton
PERSONthe Southern District
LOCATIONLeon Black
PERSON
Prince Andrew
PERSONJaffe
PERSON
Michael Fisten
PERSON