Epstein Secrets

ns any oral or written statement, dialogue, colloquialism, discussion, conversation or agreement. C. "Plaintiff' means M. (I. v. Jeffrey Epstein, 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

tative 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. Rothstein, and/or an

any oral or written statement, dialogue, colloquialism, discussion, conversation or agreement. C. "Plaintiff means L.M. (L.M. v. Jeffrey Epstein, 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

tative 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. Rothstein, and/or an

ns any oral or written statement, dialogue, colloquialism, 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, Unit

tative 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. Rothstein, and/or an

the marketing effort of the Ponzi scheme. EFTA00190040 Epstein'. RRA, et at Page 16 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Berger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were a

Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Villegas, Andrew Barnett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about the number of cases/

e marketing effort of the Ponzi scheme. EFTA00596503 Epstein v. RRA, et al. Page 16 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Berger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were a

Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Villegas, Andrew Bamett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about the number of cases/

e marketing effort of the Ponzi scheme. EFTA00729418 Epstein v. RRA, et al. Page 16 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Berger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were a

Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Villegas, Andrew Barnett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about the number of cases/

e marketing effort of the Ponzi scheme. EFTA00795602 Epstein v. RRA, et al. Page 16 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Berger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were a

l Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David an, ebbie Villegas, Andrew Barnett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about the number of cases/

e marketing effort of the Ponzi scheme. EFTA00286297 Epstein v. RRA, et al. Page 16 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Berger and Russell Adler (another named partner In RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were a

Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Vilieges, Andrew Barnett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about the number of cases/

Team's clients, E.W., L.M. or Jane Doe. EFTA00193786 Epstein'. RRA, et al. Page 16 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Berger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were a

Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Villegas, Andrew Bamett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about the number of cases/

the marketing effort of the Ponzi scheme. EFTA00223282 Epstein 1RRA, et al. Page S6 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Borger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were a

Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Baden, Debbie Villegas, Andrew Bamett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about the number of cases/