Epstein Secrets

3, 2009. Jane Doe is represented by the law firm Rothstein, Rosenfeldt & Adler ("RRA"), which as been in the news regarding alle

______ __:! EPSTEIN'S RESPONSE IN OPPOSITION TO JANE DOE'S MOTIONS FOR PROTECTIVE ORDER BARRING SECOND DEPO

scheduled for November 13, 2009. Nevertheless, as Jane Doe's deposition will most likely occur during the we

xhibit H), in which he granted a protective order regarding the depositions of Michael Fisten and Rick Fandrey, investigators previously employed by Rothstein, Rosenfeldt & Adler ("RRA"). As the Court may recall, RRA represented Jane Doe prior to its implosion. 5 Case 9:08-cv-80119-KAM Document 536 Entered on FLSD Doc

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

s ".." (App. 1). The gravamen of the Complaint was that after Edwards had filed those cases against Epstein, he had briefly joined the law firm of Rothstein, Rosenfeldt & Adler, P.A. ("RRA"), which subsequently imploded after Rothstein was charged with (and later pled guilty to), operating a Ponzi scheme (App.1). Rothstein

OF FLORIDA FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, -VS- SCOTT individually, Intervenors.' ROTHSTEIN, BRADLEY J. individually, and and JANE DOE, Respondents CASE NO. 4D18-0762 RESPONSE TO EMERGENCY PETITION FOR WRIT OF MANDAMUS SEARCY DENNY SCAROLA BARNHART & SHIPLEY, P.A. 2139 Palm Bea

through these and -- let me zoom in. On this top line are all of those circumstances subsequent to 4/9/09 when Bradley Edwards became a member of Rothstein, Rosenfeldt & Adler, which counsel says gave raise to a reasonable suspicion that Bradley Edwards was a knowing participant in the Ponzi scheme and was using fabrica

st line. "RRA and the attorneys in the civil actions" -- Please remember, the civil action is a defined term in the complaint. It's L.M., E.W. and Jane Doe's claims -- "needed to create a fiction that included extraordinary damages. However, the actual facts behind her action would never support such e