Epstein Secrets

0/0X0A8AG Edwards' Response to Request for Production dated 4/12/10 COUNSEL UST Robert D. Critton, Jr., Esquire Michael J. Pike, Esquire Burman, Critton, Luttier & Coleman LLP 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 0 Attorneys for Jeffrey Epstein Jack Goldberger Atterbury, Gol

00 FAX 6618846818 SEARCY DENNEY @005/005 Case No,: 602009CAO40800/0X0A8AG Edwards' Response to Request for Production dated 4/12/10 COUNSEL UST Robert D. Critton, Jr., Esquire Michael J. Pike, Esquire Burman, Critton, Luttier & Coleman LLP 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 0 Attor

y or representative of RRA and any investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 4. All emalls, data, correspondence, memos, or similar documents between Bradley J. Edwa

11/2010 16:00 FAX 5616665616 SEARCY DENNEY Case No.: 502000CA040800XXXXMBAG Edwards' Response to Request for Production dated 02/10 COUNSEL LIST Robert D. Critton, Jr., Esquire Michael J. Pike, Esquire Burman, Critton, LutUer & Coleman LLP 303 Banyan Boulevard, Suite 400 West Palm Beach, FL 33401 Phone: (5

y or representative of RRA and any investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (Including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 4. All emalls, data, correspondence, memos, or similar documents between Bradley J. Edwa

lvd., Suite 400 West Palm Beach, FL 33401-4639 Depending on the testimony of witnesses and evidence presented by Edwards in his case in chief, Mr. Critton may be asked to testify as to the information about which he and his client, Jeffrey Epstein, were aware and upon which they relied in filing suit a

participants who worked on the "Epstein Cases" while they were being prosecuted by RRA, her work on the "Epstein Cases" and the Ponzi scheme. 18. Mike Fisten Blue Line Investigations 13762 West State Road #84 Suite 421 Davie, Florida 33325 Mentioned in various RRA documents, including the privilege lo

ed to lead to the discovery of admissible evidence; protected by privacy rights O4207-04215 09/04/2009 Attorneys at RRA Paul Cassell Letter to Critton RE: Protective Order W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; pr

evant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 00101 07/09/2009 Bradley Edwards Mike Fisten Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evid

Jaffe, Weissing, Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 02331-02334 05/08/2009 Susan Stirling Bradley Edwards Critton order Transcript Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible e

irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01973-01974 07/23/2009 Mike Fisten Bradley J. Edwards CMA vs. Epstein — new investigator info Work product; attorney/client privilege; irrelevant and not reasonably calcu

ed to lead to the discovery of admissible evidence; protected by privacy rights 04207-04215 09/04/2009 Attorneys at RRA Paul Cassell Letter to Critton RE: Protective W/P; Attorney Client Privilege; Irrelevant and Order not reasonably calculated to lead to the discovery of admissible evidence; pro

evant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 00101 07/09/2009 Bradley Edwards Mike Fisten Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evid

Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 02331-02334 05/08/2009 Susan Stirling Bradley Edwards Critton order Transcript Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible e

irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01973-01974 07/23/2009 Mike Fisten Bradley J. Edwards CMA vs. Epstein — new investigator info Work product; attorney/client privilege; irrelevant and not reasonably calcu

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

t 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? 17 A. No. 18 Q. Did you know o