Epstein Secrets

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

S 7.25, F 12.59, S 24.40, W 29.92, N 7.66, W 31.74, N 24.00, F 49.07 TO POB AKA: BAY 1 PORTSIDE with a Folio Number of 5042 23 28 0010; (RP13) 1012 East Broward Boulevard, Fort Lauderdale, Florida, hereafter also referred to as "Defendant RP13," includes all buildings, improvements, fixtures, attachments and easement

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 Barnett, 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

7.25, E 12.59, S 24.40, W 29.92, N 7.66, W 31.74, N 24.00, E 49.07 TO POB AKA: BAY 1 PORTSIDE with a Folio Number of 5042 23 28 0010; (RP 13) 1012 East Broward Boulevard, Fort Lauderdale, Florida, hereafter also referred to as "Defendant RP13," includes all buildings, improvements, fixtures, attachments and easement

t 14. RRA employed a number of investigators used in the prosecution of the Epstein Actions. Those investigators included, but were not limited to Michael Fisten ("Fisten") and Ken Jenne, ("Jenne"), employees of RRA. Fisten and Jenne were the primary investigators assigned to Edwards and to whom they reporte

yed a number of investigators used in the prosecution of the Epstein Actions. Those investigators included, but were not limited to Michael Fisten ("Fisten") and Ken Jenne, ("Jenne"), employees of RRA. Fisten and Jenne were the primary investigators assigned to Edwards and to whom they reported to cond

, FLORIDA 33401 • EFTA00295807 Epstein v Rothstein, Edwards CASE NO. 502009CA040800XXXXMBAG Amended Complaint Law Offices of Marc S. Nurik, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301; and Jack Scarola, Esquire, Searcy Denney Scarola et al., 2139 Palm Beach Lakes Boulevard, P.O. Drawer 3626,

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

S 7.25, E 1159, S 24.40, W 29.92, 14.7.66, W 31.74, N 24.00, E 49.07 TO POB AKA: BAY 4 PORTSIDE with a Folio Number of 5042 23 28 0010; (RP13) 1012 East Broward Boulevard, Fort Lauderdale, Florida, hereafter also referred to as "Defendant RP13," includes all buildings, improvements, fixtures, attachments and easement

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 Baden, 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

7.25, E 12:59, S 24.40, W 29.92, N 7.66, W 31.74, N 24.00, E 49.07 TO POB AKA: BAY -1 PORTSIDE with a Folio Number of 5042 23 28 0010; (RP13) 1012 East Broward Boulevard, Fort Lauderdale, Florida, hereafter also referred to as "Defendant RP13," includes all buildings, improvements, fixtures, attachments and easement

ase No. 09-CV-81092. 32. Admit that Ken Jenne was involved in the decision to file the Complaint (DE #1) in Case No. 09-CV-81092. 33. Admit that Michael Fisten was involved in the decision to file the Complaint (DE #1) in Case No. 09-CV-81092. 34. Admit that in paragraph 9 of the Complaint (DE #1) in Case

West Palm Beach, FL 33401-5012 Fax: 561-835-8691 Co-Counsel for Defendant Jeffrey Epstein MARC S. NURIK, ESQ. & Law Offices of Marc S. Nurik One East Broward Boulevard Suite 700 Fort Lauderdale, FL 33301 954-745-3556 Fax Attorneys for Defendant Scott Rothstein FOWLER WHITE (Add firm/attorney info) EFTA0072259

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

Lakes Boulevard West Palm Beach, Florida 33409 Phone: Fax: Attorneys or e endant, Bradley Edwards Marc Nurik Law Offices of Marc S. Nurik One East Broward Boulevard, Suite 700 Fort Lauderdale, FL 33301 Phone: Fax: Counsel for Scott -Rothstein Copies Furnished to: Judicial Assistant to Judge Crow with motion

Who did [Mike Fisten] go to California to interview? MR. SCAROLA: That is work product and I instruct you not to answer. Id. at 170. Q. Did Mr. Fisten interview a person by the name of Michael Sanka? MR. SCAROLA: That is work product and I instruct you not to answer. Q. Did Mr. Fisten interview a

EREBY CERTIFY that a true and correct copy of the foregoing was emailed and ft-- mailed this of clay of February, 2011 to Marc S. Nurik, Esq., One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301; and Jack Scarola, Esquire, 2139 Palm Beach Lakes Boulevard, P.O. Drawer 3626, West Palm Beach, FL 33409. f5

erg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 83. David Co field (David Seth Kokin) LAS VEGAS, NV 89135 84. 85 Michael Fisten Weston, FL 86 Russell Adler Delray Beach, FL 87. Marie Alessi BOYTON BEACH, FL 33472 88. Janusz Banasiak 358 EL BRILLO WAY PALM BEACH FL,

155. 156. Alfredo Rodriguez 11349 SW 86TH LN, Miami, FL C/O Federal Public Defender or Bureau of Prisons 157. Scott Rothstein do Mark Nurik One East Broward Boulevard, Suite 700 Fort Lauderdale, Florida 33301 EFTA00798057 2. Each contested factual issue expected to be addressed by the witness, including identif