Epstein Secrets

10 the Epstein investigation? 11 A. Not that I'm aware of. 12 Q. Did he ever tell you that he had any 13 communications with Mr. Jenne, or Mr. Fandrey or 14 Mr. Fisten? 15 A. Not that fin aware of. 16 Q. And have you ever seen any note, report, 17 document, memorandum, e-mail or log entry in

tirt & P.A. 1820513ismne Boulevard B.B. Susie 2218 4 Plaintiff Miami, Phone S 1, 6 ws- VOLUME al OF IV 7 8 Oa behalf of the Plaintiff, Jame Doe No. IL ISIDRO MAKIJEI. GARCIA, ESQUIRE GARCIA, MAINS& BOO-RINGER 9 224 Dan Awnuo Suite 90) West 33401 Dcfaxlinta. 10 tilde Phan( 9 11 in

tein would ask them to take off all 23 BY MR. WEINBERG: • 23 thek clothes, and they would take off as much clothes 24 • Q. Page 9 on So Ms. Jane Doe 4's 24 as they felt comfortable with and we re not forced to 25 . aaffidavit. date of birth is and she was 18 at the time of 25 take off

m what they did with the 14 $200 they received? 15 A. I might have. I can't recall at this time if 16 I did or didn't. 17 Q. Did you ever ask lane Doe 103 — strike that. 18 • • Jane Doe I.03 told you that she had received a 19 significant amount of money because she said she bad 20 • gone to

and leaving in a 4 touch — former Chief Reiter was in touch with various 4 vehicle registered to an investigator named Richard 5 reporters? 5 Fandrey? 6 A. I don't believe so. 6 MS. ARBOUR: Form. 7 Q. Did he talk to you about having been 7 THE WITNESS: No, sir. 8 interviewed by Mr. Connol

Doe 103 was one of the witnesses who was 19 at the center of the State investigation, correct? 20 A. One of them, yes. 21 Q. And you knew that Jane Doe 103 had a MySpace 22 page that was one of the MySpace profiles that was 23 provided to the State Attorney by Mr. Epstein's then 24 counsel, Pro

3 A. Correct 4 Q. And she made a phone call to you to complain 5 about the service? 6 A. Correct. 7 Q. And what was the conversation between Jane Doe 8 103 and you on that occasion? 9 A. It was finals week and she could not leave and 10 not take her final to come down for the grand jury. I 11

5 Case 9:08-cv-80119-KAM Document 536 Entered on FLSD Docket 04/29/2010 Page 6 of 8 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

Rule 26(c), Federal Rules of Civil Procedure, moves for a protective order to prohibit the deposition of Story Cowles, and states: 1. Plaintiff, Jane Doe (Case No. 08-80893), noticed the deposition of Story Cowles for May 12, 2010 (Notice and Subpoena attached as Exhibit A). 2. Mr. Cowles was hired

ition, taking the deposition of A.J. DiScala, Michael Legamaro, Michael Fisten and Richard Fandrey. While we obtained April 19, 2010 for Fisten and Fandrey, the dates that you have given for the others are months away, i.e. June of 2010. I find it hard to believe that you are the only person capable of

ical in evaluating your Notice and Mr. Epstein's case against Mr. Edwards. Additionally, as part of a preservation order sought and obtained in the Jane Doe case, a case principally handled by Mr. Edwards both prior to his employment/association with RRA, during his employment/association wit

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

oquialism, 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 who is or was represented by Rot

. 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

Rule 26(c), Federal Rules of Civil Procedure, moves for a protective order to prohibit the deposition of Story Cowles, and states: I. Plaintiff, Jane Doe (Case No. 08-80893), noticed the deposition of Story Cowles for May 12, 2010 (Notice and Subpoena attached as Exhibit A). 2. Mr. Cowles was hired

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

uialism, 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 who is or was represented by Rot

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

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 #08-civ-80893-Marra/Johnson), and any other person who is or was represented by Rot