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1h Amendment during her depositions in order to avoid answering pertinent questions. E.W. — worked at eleven (11) separate strip clubs, including Cheetah (7°) which RRA represented and ROTHSTEIN may have owned an interest; EFTA00725339 j) Epstein v. RRA, et al. Page 22 and E.W. also worked at Pl
lawyers have years of experience - former state attorney, civil practitioners, a circuit court judge — all of whom probably have served on various Florida Bar committees. Yet they claim a lack of knowledge when: a. The firm had 24 hour security in the form of Broward County Sheriff's officers on each floo
ent extremely during her depositions in order to avoid answering relevant questions. E.W. — worked at eleven (11) separate strip clubs, including Cheetah (7°) which RRA represented and in which ROTHSTEIN may have owned an interest; and E.W. also worked at Platinum Showgirls in Boynton Beach, which w
A lawyers have years of experience former state attorney, civil practitioners, a circuit court judge — all of whom probably have served on various Florida Bar committees. Yet they claim a lack of knowledge of any indication that problems with the firm existed when: a. RRA had 24 hour security in the form
y from the fact that many of the alleged "victims" on the referenced "list" were or are admitted prostitutes, dancers at strip clubs (Platinum Gold, Cheetah, Diamond Dolls, T's Lounge, Flashdance, etc.) or have criminal records or warrants for their arrests, to reference only a few issues about them. 2
80119-KAM Document 127 Entered on FLSD Docket 05/29/2009 Page 7 of 9 Doe 101 v. Epstein Page 7 Respectfully sub By: ROBERT D. ON, JR., ESQ. Florida Bar o. 224162 MICHAEL J. PIKE, ESQ. Florida Bar #617296 LUTHER & COLEMAN 515 N. Flagler Drive, Suite 400 West Palm Beach, FL 33401 ounse or en ant
ons in order to avoid answering relevant but problem questions for her; E.W. — testified 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
that RRA's trust accounts were maintained with a well established international banking institution, in accordance with the rules and regulations of the Florida Bar, and that access to balances in the trust accounts was allegedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and ot
ions in order to avoid answering vent but problem questions for her; (ii) k — testified 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
THSTEIN investors that RRA's trust accounts in ned with a well established international banking institution, in accordance with d regulations of the Florida Bar, and that access to balances in the trust accoun I egedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and other co
order to avoid answering relevant but problem questions for her; (ii) E.W. - testified 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
that RRA's trust accounts were maintained with a well established international banking institution, in accordance with the rules and regulations of the Florida Bar, and that access to balances in the trust accounts was allegedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and ot
in order to avoid answering relevant but problem questions for her; (ii) ■- testified she worked at eleven (11) separate strip clubs, Including Cheetah which RRA represented and in which ROTHSTEIN may have owned an interest; and N. also worked at Platinum Showgirls in Boynton Beach, which was t
that RRA's trust accounts were maintained with a well established international banking institution, in accordance with the rules and regulations of the Florida Bar, and that access to balances in the trust accounts was allegedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and ot
Entities connected to both Cheetah and Florida Bar

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSONScott Rothstein
PERSON
George W. Bush
PERSON
Alan Dershowitz
PERSON
United States
LOCATIONRobert C. Josefsberg
PERSONMichael J. Pike
PERSONthe Southern District
LOCATIONLeon Black
PERSON
Paul Cassell
PERSONJack Scarola
PERSON
Bill Clinton
PERSON
Adam D. Horowitz
PERSON
Donald Trump
PERSONRobert D. Critton
PERSONMaria Farmer
PERSON