Epstein Secrets

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

esentative of RRA regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Henne, Patrick Roberts or Rick (Rich) Fandrey). 4. All agreements or documents of any nature which were provided to or received from an Investor or potential Investor relating to any case (rea

plaintiffs from attempting to depose other paralegals, secretaries, legal assistants, investigators or even attorneys employed by Epstein? As Judge Johnson noted, "while the scope of discovery is broad, it is not without limits." See DE #377. Jane Doe is clearly attempting to exceed the limits of permi

. As the Court may recall, RRA represented Jane Doe prior to its implosion. 5 EFTA00728108 16. While Epstein sought to depose Mr. Fisten and Mr. Fandrey regarding their knowledge of Scott Rothstein's Ponzi scheme, the Court nevertheless entered a protective order prohibiting their depositions until

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

esentative of RRA regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Henne, Patrick Roberts or Rick (Rich) Fandrey). 4. All agreements or documents of any nature which were provided to or received from an Investor or potential Investor relating to any case (rea

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

on or entity) regarding Jeffrey Epstein of Which inentkins Jeffrey Epstein (including • Mike Fisten, Rermeth Jenne, Patrick Robe:KS or Ritil (Rich) Fandrey). 2. On May 11, 2010, Edwards served his response to this request by stating: 3. Objection as to communications to or from investigators as that

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

esentative of RRA regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Henne, Patrick Roberts or Rick (Rich) Fandrey). 5. All agreements or documents of any nature which were provided to or received from an Investor or potential Investor, as well as, their agents