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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
kers boxes which Rothstein used to bolster his concocted story in connection with the case styled Jane Doe v. Jeffrey Epstein, currently pending in the Southern District of Florida, when meeting with D3 representatives and/or any other potential Investors in order to induce those representatives invest in the Rothst
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
kers boxes which Rothstein used to bolster his concocted story in connection with the case styled Jane Doe v. Jeffrey Epstein, currently pending in the Southern District of Florida, when meeting with D3 representatives and/or any other potential Investors in order to induce those representatives invest in the Rothst
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
kers boxes which Rothstein used to bolster his concocted story in connection with the case styled Jane Doe v. Jeffrey Epstein, currently pending in the Southern District of Florida, when meeting with D3 representatives and/or any other potential Investors in order to induce those representatives invest in the Rothst
gest that any of the other documents claimed to be subject to the attorney-client privilege, actually are. For example, document Bates 19856, from Mike Fisten to Mike Fisten, described as "Investigation into Epstein's planes" (see Comp. Ex. A) is assertedly subject to the attorney-client privilege, but is
) and may be viewed as a waiver of the privilege or protection." 799 So. 2d at 340. The TIG court further observed that Local Rule 26.1(G)(3)(b), of the Southern District of Florida, spelled out the requirements for a valid privilege log, hi. at 341: Where a claim of privilege is asserted in objecting to any interro
umber Agents explained they were not there to arrest and stated she was not a target of any FBI investigation She was then provided with a copy the Southern District of Florida, Clemantis Street, West Palm Beach grand jury on June 3, 2008. stated that she would speak to her attorney and understood the conseque
Page: EFTA02857863_p276 →Australia, along with the Australian police for the debriefing. On March 9, 2011, AUSA Civil Attorneys Edwards and Jaffe, Private Investigator Mike Fisten (protect identity) and writer met for the interview at the United States Attorney's Office in Fort Lauderdale, Florida. UNCLASSIFIED 403 EFTA028
Page: EFTA02857863_p403 →Entities connected to both Mike Fisten and the Southern District

Jeffrey Epstein
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSONFBI
ORGANIZATION
Prince Andrew
PERSON
Bradley Edwards
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
George W. Bush
PERSON
New York
LOCATION
the United States District Court
ORGANIZATION
Alan Dershowitz
PERSONLeon Black
PERSONJack Goldberger
PERSON
Paul Cassell
PERSON
Scarlett Johansson
PERSONMaria Farmer
PERSON
Donald Trump
PERSON
Bill Clinton
PERSON
A. Marie Villafana
PERSON