Epstein Secrets

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

Litigation Team knew or should have known of the improper purpose that ROTHSTEIN was pursuing in the continuation of thMheme, ROTHSTEIN used RRA's Litigation Team in the EPSTEIN cases to put issues and evidence unrelated to and unnecessary to the claims pled in th Actions, but significantly beneficial to lu

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 Product;attorney client 28 EFTA00602862 Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos &

privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 00150 04/24/2009 Litigation Team Rob Buschel Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of adm

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

privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 00150 04/24/2009 Litigation Team Rob Buschel Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of adm