Epstein Secrets

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). 3. All e-mails, data, correspondence, memos, or similar documents between Scott W. Roths

pstein, Palm Beach County Case #502008CA028051XXXXMB), Jane Doe (Jane Doe v. Jeffrey Epstein, United States District Court Case #08-civ-80893-Marra/Johnson), and any other person who is or was represented by Rothstein Rosenfeldt & Adler that has not yet filed an action against Jeffrey Epstein, and any

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

pstein, Palm Beach County Case #502008CA028058XXXXMB), Jane Doe (Jane Doe v. Jeffrey Epstein, United States District Court Case #08-civ-80893-Marra/Johnson), and any other person who is or was represented by Rothstein Rosenfeldt & Adler that has not 2 EFTA00724397 yet filed an action against Jeffrey

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). 3. All e-mails, data, correspondence, memos, or similar documents between Scott W. Roths

pstein, Palm Beach County Case #502008CA028051XXXXMB), Jane Doe (Jane Doe v. Jeffrey Epstein, United States District Court Case #08-civ-80893-Marra/Johnson), and any other person who is or was represented by Rothstein Rosenfeldt & Adler that has not yet filed an action against Jeffrey Epstein, and any

e, and similar documents dated April 1, 2008 through August 1, 2010 by and between Bradley J. Edwards. Scott W. Rothstein, Marc hlurik, Cam Holmes, Mike Fisten and any one of the following regarding or mentioning Jeffrey Epstein in any way: (a) the U.S. Attorney's Office, (b) the State Attorney's Office, (

by privilege, then a privilege log must be prepared and attached to the response, or the privilege is waived See TIG Insurance Corp. of America v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001) (stating that failure to provide a reason for privilege and prepare a privilege log constitutes waiver of the p

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

ed on attorney-client work product privilege and no privilege log has been prepared. 14. Under the case of TIG Insurance Corporation of America v. Johnson, 799 So. 2d 339 (Fla. 4111 DCA 2001) and its progeny, states that the failure to timely provide a privilege log may be grounds to determine that a

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 e-mails, data, correspondence, memos, or similar documents between Scott W. Roths

tein, Palm Beach County Case #502008CA0280S8XXXXIVIB), Jane Doe (Jane Doe v. Jeffrey Epstein, United States District Court Case #08-civ-80893-Marra/Johnson), and any other person who is or was represented by Rothstein Rosenfeldt & Adler that has not yet filed an action against .leffre, Epstein, and any

ssume the guy was =n investigator for the other side in the civil case - the group that set y=u up. 2 EFTA_R1_01560831 EFTA02457192 His name is Mike Fisten and his company is Blueline Investigations. If he is someone who you encountered and he was a bad guy or out to get=you, I would not want to use h

as well. Some strange folks in that office. Anyway, I will=look forward to talking and while all the judges are going to be tough, Ju=ges Marra and Johnson so far have not been rubber stamps for government in=my case and that means something. David The information contained in this communication is co

ries of stories about your case. I assume the guy was =n investigator for the other side in the civil case - the group that set y=u up. His name is Mike Fisten and his company is Blueline Investigations. If he is someone who you encountered and he was a bad guy or out to get=you, I would not want to use h

as well. Some strange folks in that office. Anyway, I will=look forward to talking and while all the judges are going to be tough, Ju=ges Marra and Johnson so far have not been rubber stamps for government in=my case and that means something. 2 EFTA_R1_01570330 EFTA02463362 David **** ******* **

ries of stories about your case. I assume the guy was an investigator for the other side in the civil case - the group that set you up. His name is Mike Fisten and his company is Blueline Investigations. If he is someone who you encountered and he was a bad guy or out to get you, I would not want to use him

as well. Some strange folks in that office. Anyway, I will look forward to talking and while all the judges are going to be tough, Judges Marra and Johnson so far have not been rubber stamps for government in my case and that means something. David The information contained in this communication is co

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

radley Edwards RE:Epstein Joint W/P Priv. 11560-11562 10/02/2009 Bradley Edwards Katherine Jacquie FW:Meeting w/Stanley Arkin Joint W/P Priv. Johnson 11444-11448 09/28/2009 Bradley Edwards Amy Ederi FW:Epstein Depo Joint W/P Priv. 05823 09/04/2009 Adam Horowitz Jacquie Johnson RE:Epstein