Epstein Secrets

aintiff and the law firm of RRA. 3. All e-mails, 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

ting to act on their behalf (including without limitation, A.J. 5 EFTA00616124 Case 09-34791-RBR Doc 1323 Filed 01/12/11 Page 6 of 8 Discala, Michael Legamaro and Dean ICretschmar), relating to, but not limited to, any case (real or fabricated) involving Jeffrey Epstein and any of the following: a. Scott

ions discussing investigative techniques and other Epstein matters; j) In the month of September, 2009, emails were exchanged between Edwards and William Berger ("Berger"), a partner at RRA who also participated in the Epstein actions, regarding Litigation Strategy. k) On September 11, 2009, Edwards sent a

look at the Epstein case files that Fisten and Jenne had stacked around the conference room. 17. On or about October 13, 2009, Illinois attorney, Michael Legamaro, and his client, hedge fund operator Thane Ritchie, were also invited to examine Epstein case files and a flight log displayed by Rothstein that al

ions discussing investigative techniques and other Epstein matters; j) In the month of September, 2009, emails were exchanged between Edwards and William Berger ("Berger"), a partner at RRA who also participated in the Epstein actions, regarding Litigation Strategy. k) On September 11, 2009, Edwards sent a

look at the Epstein case files that Fisten and Jenne had stacked around the conference room. 17. On or about October 13, 2009, Illinois attorney, Michael Legamaro, and his client, hedge fund operator Thane Ritchie, were also invited to examine Epstein case files and a flight log displayed by Rothstein that al