Epstein Secrets

y Plaintiff and the law firm RRA. 3. All emails, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell Adler and/or any attorney or representative of RRA and any investor or third party (person or entity) regarding Jeffrey Epstein or whic

n Avenue South Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659.8300 Fax (561)-835-8691 Attorneys for Jeffrey Epstein Gary M. Farmer, Jr. Fanner, Jaffe, WelssIng, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954) 524-2820 Fax: (964) 524-

os & Lehrman SATES DATE 12 FROM DESCRIPTION 91116010N discovery of admissible evidence; protected by privacy rights 25815-25822 06/01/2009 William Berger Bradley Edwards Depo information W/P; Attorney Client Privilege; Irrelevant and riot reasonably calculated to lead to the discovery of admissibl

Privilege Log — Dated 2-23-2011 Fanner. Jaffe. Weissing. Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION 9BJECTI2ti not reasonably calculated to lead to the discovery of a

Fowler White? MR. LINK: If you remember, you can answer that question. THE WITNESS: Sometime in February. BY MR. SCAROLA: Q Are you aware that William Berger was deposed in the state court civil proceeding? A I don't recall. Q Do you know who William Berger is? Palm Beach Reporting Service, Inc. 561-

taining information derived from documents or data over which a claim of privilege was asserted by or on behalf of Rothstein, Rosenfeldt, Adler PA; Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.; or Bradley J. Edwards? MR. LINK: I think -- which subpoena duces tecum are you looking at, Jack?