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

stina ICitterman k. Dean Kretschmar 1. Michael Legamaro 16. All documents related to or referencing potential deponents in the Jane Doe, M. or E.W., cases used in connection with Investor meetings and/or general Investor solicitation into the Rothstein Ponzi Scheme. 17. Any employment agreemen

oquialism, discussion, conversation or agreement. C. "Plaintiff means =. (MI. v. Jeffrey Epstein, Palm Beach County Case #502008CA0280S1XXXXMB), E.W. (E.W. v. Jeffrey Epstein, Palm Beach County Case #502008CA0280S8XXXXIVIB), Jane Doe (Jane Doe v. Jeffrey Epstein, United States District Court Case

or Epstein (wire taps, bugs, other listening and watching)? 21.9.6 What is Blue Line R & D? 21.10 Knowledge of skills and involvement of: 21.10.1 Mike Fisten 21.10.2 Ken Jenne 21.10.3 Patrick 21.10.4 Rick Fandry 22. Criminal History - have you ever been convicted of a crime? If yes, when and for what

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?

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

as g. Andrew Barnett 9 EFTA00722468 h. Bradley Edwards 15. All documents related to or referencing potential deponents in the Jane Doe,. or E.W., cases used in connection with Investor meetings and/or general Investor solicitatio the Rothstein Ponzi Scheme. 16. Any employment agreements or

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

quialism, discussion, conversation or agreement. C. "Plaintiff' means L.M. (LM. v. Jeffrey Epstein, Palm Beach County Case #502008CA028051XXXXMB), E.W. (E.W. v. Jeffrey Epstein, Palm Beach County Case #502008CA028058XXXXMB), Jane Doe (Jane Doe v. Jeffrey Epstein, United States District Court Case #

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

oc 1063 Filed 10/13/10 Page 7 of 8 h. Bradley Edwards 15. All documents related to or referencing potential deponents in the Jane Doe, L.M. or E.W., cases used in connection with Investor meetings and/or general Investor solicitation into the Rothstein Ponzi Scheme. 16. Any employment agreemen

ny, did Ghislaine Maxwell have to [your three clients]? MR. SCAROLA: Objection, work product. Instruct you not to answer. Id. at 155.6 Q. Who did [Mike Fisten] go to California to interview? MR. SCAROLA: That is work product and I instruct you not to answer. Id. at 170. Q. Did Mr. Fisten interview a per

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

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

uialism, discussion, conversation or agreement. C. "Plaintiff' means L.M. (LM. v. Jeffrey Epstein, Palm Beach County Case #502008CA028051,OOO(MB), E.W. (EVV. v. Jeffrey Epstein, Palm Beach County Case #502008CA028058)OOOO48), Jane Doe (Jane Doe v. Jeffrey Epstein, United States District Court Case

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 the admissible evidence; protected by privacy rights 07025-07027 10/29/2009 Bradley Edwards Paul Cassell ■. and E.W. v. Epstein — Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evide