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e 14-16; and Same objection as well as attorney-client privilege and instruct you not to answer. 198/21-23] Q: Did you ever authorize or direct Mr. Jenne to perform any investigation on the Epstein files? Id. at page 201; line 4-6. MR. SCAROLA: Same objection, same instruction. Id. at page 201; line
AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o
reet, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00799405 lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., has Mr. Howell participated in the case; that is, has he done work on the case? Id. at page 90; lines 20-23. A: Yes. Id. at page 90; line 24. Q:
ies 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 and felon) assisted ROTHSTEIN in making these offers by providing confidential, privileged and work- prod
se cases involving Epstein); b. Reached agreements to share attorneys fees with non-lawyers; c. Used investor money to pay plaintiffs (i.e., L.M., E.W. and Jane Doe) "up front" money such that plaintiffs would refuse to settle the Civil Actions; d. Conducted searches, wiretaps or intercepted conver
ed she worked at eleven (11) separate strip clubs, including Cheetah which RRA represented and in which ROTHSTEIN may have owned an interest; and E.W. also worked at Platinum Showgirls in Boynton Beach, which was the subject of a recent police raid where dancers were allegedly selling prescriptio
ies 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 and felon) assisted ROTHSTEIN in making these offers by providing confidential, privileged and work- prod
se cases involving Epstein); b. Reached agreements to share attorneys fees with non-lawyers; c. Used investor money to pay plaintiffs (i.e., L.M., E.W. and Jane Doe) "up front" money such that plaintiffs would refuse to settle the Civil Actions; d. Conducted searches, wiretaps or intercepted conver
ed she worked at eleven (11) separate strip clubs, including Cheetah which RRA represented and in which ROTHSTEIN may have owned an interest; and E.W. also worked at Platinum Showgirls in Boynton Beach, which was the subject of a recent police raid where dancers were allegedly selling prescriptio
e 14-16; and Same objection as well as attorney-client privilege and instruct you not to answer. 198/21-23] Q: Did you ever authorize or direct Mr. Jenne to perform any investigation on the Epstein files? Id. at page 201; line 4-6. MR. SCAROLA: Same objection, same instruction. Id. at page 201; line
AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o
Attorney-Client and work-product privileges. Id. at page 89; lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., 3 It is significant to note that other jurisdictions have sanctioned counsel for just this behavior during deposition. See e.g. Van Pilsum v. Iow
ies 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 and felon) assisted ROTHSTEIN in making these offers by providing confidential, privileged and work- prod
se cases involving Epstein); b. Reached agreements to share attorneys fees with non-lawyers; c. Used investor money to pay plaintiffs (i.e., L.M., E.W. and Jane Doe) "up front" money such that plaintiffs would refuse to settle the Civil Actions; d. Conducted searches, wiretaps or intercepted conver
ed she worked at eleven (11) separate strip clubs, Including Cheetah which RRA represented and in which ROTHSTEIN may have owned an interest; and E.W. also worked at Platinum Showgirls in Boynton Beach, which was the subject of a recent police raid where dancers were allegedly selling prescriptio
inent (Clinton, Trump, Dershowitz, etc.) 19.17 Were you aware of investors coming in and looking at Epstein files? 19.18 ever meet any? 19.19 Did Jenne or Fisten tell you they brought in files? 19.20 know Michael Legamaro? Hear of him? Who is he? 20. Does he know a 20.1 If so, did he ever talk t
Paul Cassell? If yes, since when and how did you meet? 14.10 A Mr. Howell? same as for Cassell. 14.11 3 files: State court was ■. (Jane Doe # 2), E.W. (Jane Doe #1) and . 14.12 Who staffed the Epstein files? 14.12.1 BE testified that you Judge Stone, Bill Berger and Rob Buschell worked on cases?
ion on the Epstein files? A. SCAROLA: Same objection and instruction. 201/3-6 201/19-24 201/25 202/4-11 Q. Did you ever authorize or direct Mr. Jenne to perform any investigation on the Epstein files? A. SCAROLA: Same objection and instruction. Q. If you're unaware of the existence of the entity
answer the threshold "yes" or "no" question: Did [Mr. Howell] ever relate that to you." Id. 9. Edwards in one instance when asked what his client E.W. told him on the phone, himself claimed privilege. Id. at 90. Later, when asked "for what purpose did Ms. L.M. originally hire you?," his attorney o
team of investigators on the Epstein Actions, including Michael Fisten ("Fisten") and former Broward County Sheriff and convicted felon Ken Jenne ("Jenne"). 12. Fisten and Jenne were the primary investigators assigned to Edwards, and routinely reported to Edwards and Rothstein regarding their invest
state court civil action on behalf of L.M. 31. On or about October 17, 2009, Edwards, who had filed a state complaint against Epstein on behalf of E.W., emailed his assistant to file a federal complaint against Epstein on behalf of E.W like the one he had filed in federal court on behalf of L.M.. 3
ies 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 and felon) assisted ROTHSTEIN in making these offers by providing confidential, privileged and work- prod
ed she worked at eleven (11) separate strip clubs, including Cheetah which RRA represented and In which ROTHSTEIN may have owned an interest; and E.W. also worked at Platinum Showgirls in Boynton Beach, which was the subject of a recent police raid where dancers were allegedly selling prescriptio
Entities connected to both Jenne and E.W.

Jeffrey Epstein
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSONScott Rothstein
PERSONJane Doe
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSON
Kenneth Marra
PERSONJack Scarola
PERSONMaria Farmer
PERSON
Donald Trump
PERSONRobert D. Critton
PERSON
Paul Cassell
PERSON
United States
LOCATION
Bill Clinton
PERSONthe Southern District
LOCATION
Lauderdale
LOCATION
Palm Beach County
LOCATIONLeon Black
PERSON
Marc Rich
PERSON