Epstein Secrets

time and place aforesaid, when and whore the following proceedings wore reported by: Elaine V. Williams Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 (561) 471-2995 1 a 4 ) a so II 12 13 10 15 16 17 10 19 20 21 22 23 as as PROCEEDINGS 71

ARA BERARD ROCKENBACH, ESQUIRE By SCOTT J. LINK, ESQUIRE For Defendant/counter-Plaintiff: SEARCY, DENNEY, SCAROLA, BARNHART 4 SHIPLEY, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 By JACK SCAROLA, ESQUIRE By DAVID P. VITALE JR., ESQUIRE By KAREN TERRY, ESQUIRE For Non-Parties L.N., E.M. 4 Jane Doe

fashion so that, 25 NR. LINK: He la, yea. And we reached out ' 34 36 , motor one, first and foremen[ once all the cards I Joe Ackerman. Kr. Ackerman. Sorry. We reached . are on the table, the law favors settlement, and it 2 out to Mr. Ackerman. may come tO fruition, and has more often than no

er white. They have no memory of it. *o we, LIA, Mr. $•Carole -- that the Court had a specific interest in and has 23 THE COURT: Excuse 04. LA MX. Ackerman atilt I always taken the position that all cards are going 24 actively practicing? to bo on the table in a timely fashion so that, 25 NR. LINK

in the matter of Jeffrey 5 APPEARANCES: 6 For Plaintiff: 4 Epstein versus Scott Rothstein and Bradley 7 LINK 4 ROCKENBACH, . Edwards. 1555 Palm Beach Lakes Boulevard, Suite 301 0 9 West Palm Beach, FL 33401 By SCOTT J. LINK, ESQUIRE , This deposition is being hold 2255 Glades Road, Suite 218-A, Boca Piton,

THE VIDEOGRAPHER: This is the 23rd day 2 Sonja D. Hall 2 of February 2028. The time is approximately Palm Beach Reporting Service, Inc. 9 1665 Palm Beach Lakes Boulevard, Suite 1001 $ 9:27 West Palm Beach, FL 33401 4 This is the videotaped deposition of 4 1561) 471-2995 5 Berger in the matter of Jeffrey 5

ll of when were involved at some point 21 In time in the representation of Jeffrey Epstein, 32 Correct? 33 A Yea. 24 Q I think I missed Mr. Ackerman on that list. 23 Mr. Ackerman as well. 136 I BY NE. SCAROLA: 2 Q Lot me restate the question. 3 what extent, if any, would it be necessary

9 accident 94:23 95:17 account 29:15 accountable 107:14 accounts 29:1,2,5 accurate 114:13 accused 46:23 151:9 accusing 50:11 achieved 122:3 Ackerman 90:18 134:24.25 135:1.2 acknowledge 56:24 acknowledged 135:6 acquainted 15:14 acquired 19:13 act 53:24 acted 136:5 acting 134:3 action 8:2

via email this 19th day of March, 2018: Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter- Plaintiff Bradley I Edwards Philip M. Burlington Nichole J. Segal Burlington & Rocke

their very own creation by either attorney-client or work product. If the disc somehow improperly came into the possession of Fowler White and Mr. Ackerman (of which Mr. Cassell has not even the slightest of proof), then the most one could say is that for eight years Fowler White and Mr. Ackerman held

y, no competent lawyer could review the materials that are now sealed and not insist on an in camera review of their contents. Fowler White and Mr. Ackerman's failure to do so makes it much less likely that they knew what was on the disc. There can be no urgency created by the revelation of eight-year-ol

eks /24 new exhibits have been added to the Elaine V. Williams r) exhibit list of the defendant Epstein. Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 t4 And jolt. co provide cone general background, West Palm Beach, FL 33401 (561) 471-2995 2, sae of Mich your Honor nay recall, the

I agree that that wa➢ something 12 like Mr. Scarola -- 23 that the Court had a specific interest in and has 13 THE COURT: Excuse rm. Is Mr. Ackerman still 24 always taken the position that all cards are going 24 actively practicing? 25 to be on the table in a timely fashion ➢o that, 25 NR

mulated 85:6 accurate 99:4,10 accurately 67:4 accusations 27:7 30:15 96:12,14 accusatory 30:16 accuse 91:6 accused 7:11,13 68:3,4 86:25 88:1 Ackerman 8:1 35:23 36:1,1,2 56:23 Ackerman's 48:25 acknowledged 5:11 86:1 87:12 Act 16:1 acted 27:10 action 23:20 50:2 83:24 84:2,3 85:13 86:14 89:1

eks /24 new exhibits have been added to the Elaine V. Williams r3 exhibit list of the defendant Epstein. Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 t4 2, And jolt. CO provide cone general background, babi of Mich your Honor nay recall, there was an 2 4

I agree that that wa➢ something 12 like Mr. Scarola -- 23 that the Court had a specific interest in and has 13 THE COURT: Excuse rm. Is Mr. Ackerman still 24 always taken the position that all cards are going 24 actively practicing? 25 to be on the table in a timely fashion ➢o that, 25 NR

mulated 85:6 accurate 99:4,10 accurately 67:4 accusations 27:7 30:15 96:12,14 accusatory 30:16 accuse 91:6 accused 7:11,13 68:3,4 86:25 88:1 Ackerman 8:1 35:23 36:1,1,2 56:23 Ackerman's 48:25 acknowledged 5:11 86:1 87:12 Act 16:1 acted 27:10 action 23:20 50:2 83:24 84:2,3 85:13 86:14 89:1

ee Boulevard, Suite 1200 West Palm Beach, FL 33401 Examination of the witness taken before Sonja D. Hall Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 (561) 471-2995 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00803632 L 1 2 3 4 APPEARANCES:

By SCOTT J. LINK, ESQUIRE 5 By JENNIFER LETTMAN, ESQUIRE 6 For Bradley Edwards: 7 SEARCY, DENNEY, SCAROLA, BARNHART & 8 SHIPLEY, P.A. 2139 Palm Beach Lakes Boulevard 9 West Palm Beach, FL 33409 By JACK SCAROLA, ESQUIRE 10 For Farmer Jaffe: 11 EDWARDS POTTINGER LLC 12 425 N Andrews Avenue, Suite 2 Fort La

we are not going to get into the general procedures of Fowler White on how they file things. BY MR. SCAROLA: Q Other than making Mr. Knight, Mr. Ackerman and Ms. Sanchez aware of the provisions of this order, did Fowler White do anything else at all in order to assure that the provisions of the orde

Fowler White Burnett ),-;,4 ATTORNEYS AT _AV, October 8, 2010 Via E-mail only Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., #700 Fort Lauderdale, FL 33301 Re: Jeffrey Ep

s report. At that time, I will deliver it to Judge Crow. If you have any questions, please contact me. Otherwise thank you. Sinc y yours, seph . Ackerman, Jr. Enclosures W.WO431ever Swots 201 ?twit -Mr Sultana EFTA00722376 IN THE CIRCUIT COURT OF THE I• tr t kENTH JUDICIAL CIRCUIT, IN AND FOR PAL