Epstein Secrets

XMBAG, Judge Crow entered an order on April 19, 2010 (attached as I Exhibit H), in which he granted a protective order regarding the depositions of Michael Fisten and Rick Fandrey, investigators previously employed by Rothstein, Rosenfeldt & Adler ("RRA"). As the Court may recall, RRA represented Jane Doe pri

its implosion. 5 Case 9:08-cv-80119-KAM Document 536 Entered on FLSD Docket 04/29/2010 Page 6 of 8 16. While Epstein sought to depose Mr. Fisten and Mr. Fandrey regarding their knowledge of Scott Rothstein's Ponzi scheme, the Court nevertheless entered a protective order prohibiting their de

tating and belief that the communications to Mr. Epstein from his attorneys and staff, work product privileges. See Exhibit B; see also Affidavit of Robert D. Critton, Jr. attached as Exhibit D. 4. Mr. Cowles did not know, nor did he have any knowledge of, Mr. Epstein prior to his employment with Mr. Goldberger. See

which was sent. We also have requested days for the completion of Mr. Edwards' deposition, taking the deposition of A.J. DiScala, Michael Legamaro, Michael Fisten and Richard Fandrey. While we obtained April 19, 2010 for Fisten and Fandrey, the dates that you have given for the others are months away, i.e. Ju

ards' deposition, taking the deposition of A.J. DiScala, Michael Legamaro, Michael Fisten and Richard Fandrey. While we obtained April 19, 2010 for Fisten and Fandrey, the dates that you have given for the others are months away, i.e. June of 2010. I find it hard to believe that you are the only perso

mitations that have been placed on us by you, your client and other with regard to discovery which we want and need to complete. Cordially yours, Robert D. Critton, Jr. RDC/clz EFTA00605544

duals wherein Epstein, a Palm Beach billionaire or similar reference was mentioned: a. Scott Rothstein b. Russell Adler c. William Berger d. Michael Fisten e. Kenneth Jenne f. David Boden g. Deborah Villegas h. Andrew Barnett i. Patrick Rocberts j. Richard (Rick) Fandry k. Christina Kitterm

II respond to this subpoena as directed. DATED this 16th day of April, 2010. BY: CRITTON, JR. ( ttorneys for Defendant Jeffrey Epstein) Burman, Critton, Luttier & Coleman 303 Banyan Blvd., Suite 400 est Palm Beach, FL 33401 . CRITTON, JR., ESQ. For the Court EFTA00725168 EXHIBIT A DEFINITIONS

d. Tenth Floor CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served by U.S. Mail and facsimile on Mr. Robert D. Critton, Jr., 303 Banyan Blvd., Suite 400 West Palm Beach Fl; Mr. Marc Nurik, One East Broward Blvd., Suite 700, Ft. Lauderdale, FL 33301; Mr. Jack Scarola

t "A" at pp. 169-171, 185-186. Edwards counsel made clear that Edwards would not answer "any questions" related to the alleged investigation done by Fisten and other investigators. Therefore, it was clear that despite the fact that Mr. Edwards and Mr. Fisten discussed Epstein and the Jane Doe matters w

stein v. Epstein, 519 So.2d 1042 (Fla. 3d DCA 1988). The financial information sought here is clearly relevant. (b) Topic Specific Objections As to Michael Fisten Should Be Overruled and Edwards Should be Compelled To Return For Deposition to Testify to Same and to His Newly Filed Affidavit 6. Michael Fiste

5012 Fax Co-Counsel for Defendant Jeffrey Epstein BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard Suite 400 h, Ft 33401 Fax By: Robert D. Critton, Jr. Florida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) EFTA00728271

t "A" at pp. 169-171, 185-186. Edwards counsel made clear that Edwards would not answer "any questions" related to the alleged investigation done by Fisten and other investigators. Therefore, it was clear that despite the fact that Mr. Edwards and Mr. Fisten discussed Epstein and the Jane Doe matters w

stein v. Epstein, 519 So.2d 1042 (Fla. 3d DCA 1988). The financial information sought here is clearly relevant. (b) Topic Specific Objections As to Michael Fisten Should Be Overruled and Edwards Should be Compelled To Return For Deposition to Testify to Same and to His Newly Filed Affidavit 6. Michael Fiste

Counsel for Defendant Jeffrey Epstein BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 303 Banyan Boulevard Suite 400 West Palm Beach, FL 33401 Fax By: Robert D. Critton, Jr. Florida Bar #224162 Michael J. Pike Florida Bar #617296 (Counsel for Defendant Jeffrey Epstein) EFTA00728264

red private investigators to perform investigative work in anticipation and furtherance of litigation. 8. Several private investigators, including Michael Fisten and Richard Fandry, were hired by RRA to perform investigative work on the L.M. case, in anticipation and furtherance of litigation. 9. As has be

, Suite 2 Fort Lauderdale, 301 Attorney nt L.M. By: Gary Farmer, Jr. Florida Bar No.: 914444 EFTA00728316 Notice of Hearing COUNSEL LIST Robert D. Critton, Jr., Esquire Michael J. Pike, Esquire Burman, Critton, Luttier & Coleman LLP 303 Banyan Boulevard, Suite 400 West Palm FL 33401 Phone: Fax:

mer, Jr. Florida Bar No.: 914444 EFTA00728316 Notice of Hearing COUNSEL LIST Robert D. Critton, Jr., Esquire Michael J. Pike, Esquire Burman, Critton, Luttier & Coleman LLP 303 Banyan Boulevard, Suite 400 West Palm FL 33401 Phone: Fax: Attorneys for Jeffrey Epstein Jack Goldberger Atterbury

-n? A. I know an individual whose last name is 8 Fisten. 9 Q. All right. What's his first name, the one 10 you know? 11 A. Mike. 12 Q. Michael Fisten? 13 A. Yes. 14 Q. Mike Fisten ever do any work for you when 15 you worked as a solo practitioner at any time prior 1.6 to you joining RRA?

99726 Page 66 Q. Right. Did you ever have an investigator work for you? 4 A. Yes. 5 Q. Okay. Do you know an individual by the 6 name of Fisten, F-i-s-t-e-n? A. I know an individual whose last name is 8 Fisten. 9 Q. All right. What's his first name, the one 10 you know? 11 A. Mike

Prose Court Reporting Job No.: 1333 PROSE COURT REPORTING AGENCY, INC. EFTA00599662 Page 2 1 APPEARANCES: 2 On behalf of the Plaintiff: 3 ROBERT D. CRITTON, JR., ESQUIRE BURMAN, CRITTON, LUTTIER & COLEMAN, LLP 4 Boulevard West Palm Beach, Florida 334O1 Phone: 7 and JACK ALAN GOLDBERGER, ESQUIRE

belief, ROTHSTEIN and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff an

naming additional Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Villegas, Andrew Bamett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about th

iew Mr. Josefsberg's outstanding bills on a line-by-line basis and attempt to reach a non- adversarial resolution of all outstanding fee issues. Mr. Critton also transmitted to Mr. Josefsberg an Agreement for Special Master to Determine Amount of Attorneys' Fees and Costs ("Special Master Agreement), si

ld this court order production of same after an in camera inspection) must be redacted to secure the names of unsuspecting third-parties. Moreover, Michael Fisten (formerly an employee of RRA and now an employee/independent contractor of Mr. Edwards' firm) acted, upon information and belief, as a broker or mid

l of record identified on the following Service List in the manner specified by CM/ECF on this 141 day of April, 2010. Respectfully submitted, Br ROBERT D. CRITTON, JR., ESQ. Florida Bar No. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLE

f illegal activities, wire taps, and methods by the Rothstein firm while Mr. Edwards had basically been bringing these cases. The investigator, Mr. Fisten, who's mentioned in the Complaint, represented himself as an FBI agent, falsely represented himself as an FBI agent. BY MR. SCAROLA: Q. Do you ha

. I don't understand it. Explain it to me. MR. PIKE: To the extent you can answer that question without disclosing my conversations with you or Mr. Critton's conversations with you, as well as my work product, you can answer the question. THE WITNESS: I believe that as part of the scheme to defraud inv