Epstein Secrets

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

vidence that would be inadmissible at trial, so long as it is reasonably calculated to lead to the discovery of admissible evidence. Rule 1.280(b), Fla.R.Civ.P. (2008). Wherefore, Epstein requests that this court grant the relief requested herein, including, but not limited to, ordering that Edwards retu

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

vidence that would be inadmissible at trial, so long as it is reasonably calculated to lead to the discovery of admissible evidence. Rule 1.280(b), Fla.R.Civ.P. (2008). Wherefore, Epstein requests that this court grant the relief requested herein, including, but not limited to, ordering that Edwards retu

-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

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50 2009CA040800XXXXMB AG Complex Litigation, Fla.R.Civ.Pro. 1201 JEFFREY EPSTEIN, Plaintiff, -vs- VOLUME I OF II SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and III. individual

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

s and the defenses in the litigation"). W. The information simply falls under the "highly protected category of opinion work-product." Id; see also Fla.R.Civ.Pro. 1.280. Also, Counsel for Jane Does 2-8 in the Federal companion cases apparently obtained a copy of the file retained by the Palm Beach State