Epstein Secrets

l. 18. On or before July 1, 2010, you arranged for a private investigator to 19. The private investigator hired by you to conduct surveillance on Jane Doe 20. When you filed this lawsuit against Bradley J. Edwards, you knew that it had no basils in fact. 4 EFTA00722356 09/18/2010 15:16 PAZ SEARCY

09/16/2010 15:13 FAX SEARCY DENNEY lit 001/008 #21874/mep JEFFREY EPSTEIN, Plaintiff, vs. S TT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants. IN

position You testified under oath (at page 12), there are only three cases in existence against Jeffrey Epstein in which You represent a plaintiff (Jane Doe, ands. 2. Admit that the testimony described in Request No. 1 is false. 3. Admit that in Your March 23, 2010 deposition you testified under oath

aza 1395 Brickell Avenue, 14th Floo Miami, Florida 33131 By: '. Sanchez, Esq. da Bar No. 195677 EFTA00722572 07/07/2010 13:39 FAX 5616845816 SEARCY DENNEY 1001/004 #2,1874/mep JEFFREY EPSTEIN, Plaintiff, vs.' SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually

k with 18 them? 19 MR. EDWARDS: Object to the form. 20 THE WITNESS: Yes. Yes, l did. 21 BY MR. CRITTON: 22 Q. All right. And then it says: 'Jane Doe's 23 status as a victim of a Federal offense was confirmed 24 when she was interviewed by Federal agents on May 28th. 25 2008." Page 138 1. co

Ws No. 5 13 (Order) 14 15 16 17 18 19 20 21 22 23 24 25 PAGE 163 Page 132 1 On behalf of the Plaintiff= 2 JACK P. HILL, ESQUIRE SEARCY DENNEY SCAROLA BARNHART & SHIPLEYS. 3 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 4 5 On behalf of the B.B.: 6 ADAM J. LANGNO, ES

M. v. Jeffrey Epstein, Palm Beach County Case #502008CA028051XXXXMB), E.W. (E.W. v. Jeffrey Epstein, Palm Beach County Case #502008CA028058XXXXMB), 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

idence; vague; overbroad, without waiving objection, there are no fee agreements with any investor. EFTA00724403 05/11/2010 18:59 FAX 5016845810 SEARCY DENNEY Case No.: 502009CA041)800XXXXMBAO Edwards' Response to Request for Production dated 4/12110 0002/005 7. None. 8. None. 9. Objection, relevan

) in the name of other individuals to conceal those assets from potential judgment creditors. I 16. When civil lawsuits were filed against you by Jane DoeMM., you knew that the lawsuits would likely result in substantial judgments against you if they proceeded to trial. 17. When you filed your suit a

09/16/2010 15:13 FAX 5616845816 SEARCY DENNEY lit 001/008 #21874/mep JEFFREY EPSTEIN, Plaintiff, vs. S TT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants. IN

AL 10104 FORREST HILL BLVD WELLINGTON, FL 33414 150. All witnesses that Defendants have listed on their Witness List not objected to by Plaintiff, Jane Doe. 151. All rebuttal witnesses. 152. All People on Jeffrey Epstein's Inmate Visitor Log while he was in jail. WITNESS TESTIMONY EXPECTED TO BE PRESE

3301 30. 31. 32. do Adam Horowitz FARMER, JAFFE, WEISSING, ET AL. 425 N ANDREWS AVE., SUITE 2 FT. LAUDERDALE, FL 33301 33 * do Jack Scarola SEARCY DENNEY, ET AL. EFTA00798047 DESCRIPTION OF WITNESSES 2139 PALM BEACH LAKES BLVD. West Palm Beach, FL 33409 34. c/o Robert Josefsberg, Esq. PODHURST

8-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-801092 VIDEO-CONFERENCED AND VIDEOTAPED DEPOSITION OF JANE DOE Wednesday, September 30, 2009 9:37 a.m. - 6:10 p.m. One Clearlake Centre 250 South Australian Avenue, 1st Floor West Palm Beach, Florida 33401 Re

ures) 15 16 17 18 19 20 21 22 23 24 25 Marked off the record.) Page 262 1 On behalf of the Plaintiff CM.A.: 2 JACK P. HELL, ESQUIRE SEARCY DENNEY SCAROIA BARNHART & SHIPLEY, PA 3 2139 Palm Beach Lalces Boulevard West Pabn Beach, Oneida 33409 4 5 On o . 6 ADAM J. LANGEt40, ESQUIRE LEO

ims under, as appropriate, state and federal law. These RICO claims alleged that it was no accident that young girls like his clients L. , E.W. and Jane Doe ended up in EPSTE1N's mansion where he sexually abused them. Inst d, the RICO claims contended that EPSTEIN ran an entire criminal organization that

02/01/2012 16:11 FAX 5616845816 SEARCY DENNEY liboovois JEF v REY EPSTEIN, Plaintiff, SCOTT ROTHSTELN, individually, BRAD I LEY J. EDWARDS, individually, and individually, Defendant, 1

frey Epstein, defendant. CMA, plaintiff, versus Jeffrey Epstein, defendant. And Jane Doe, plaintiff, versus Jeffrey Epstein, et al, defendant. And Jane Doe -- is there a shorter thing that we can do here? It's also missing this one right here. MR. MERMELSTEIN: Do we have a problem with saying Jane Do

he above cause. 6 6 _ _ - 7 e On behalf of the Defendant Bradley Edwards: JACK SCAROLA, ESQUIRE 7 VIDEOGRAPHER: We are now on video record. SEARCY DENNEY SCAROLA BARNHART& SHIPLEY B This is media number one in the videotaped 9 9 deposition of Jeffrey Epstein in the matter of io 10 Jeffrey Epste