6
Shared Docs
6
Same-Page
7 / 6
Mentions
you represented Jane Doe. .. whether she was considered a victim by the U.S. Attorney's Office?" and then re-phrased: ". . .[D]id you learn whether [Jane Doe 1] was listed as a, or deemed to be a victim by the U.S. Attorney's Office?" Id. at 100-104. Although contrary to law, Mr. Scarola's stated position
ROLA: I am going to object. That calls for attorney-client privilege. 100/9-14 Q. At the time do you know whether, at the time that you represented Jane Doe 1, do you know whether her name, whether she was considered a victim by the United States Attorney's Office? 100/15-23 A. SCAROLA: If that informati
tographs . ...? MR. SCAROLA: Same objection [work-product, attorney-client privilege] and instruction. Id. at 199, lines 25, 1-12. Q. [regarding Patrick Roberts] Did he ever perform investigation work on any of the Epstein files? MR. SCAROLA: Same objection [work-product, attorney-client privilege] and ins
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
nd any Investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 3. All e-mails, data, correspondence, memos, or similar documents between Scott W. Rothstein, and/or any attorney or rep
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
d any investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (Including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 4. All emalls, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, and/or a
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
nd any Investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 3. All e-mails, data, correspondence, memos, or similar documents between Scott W. Rothstein, and/or any attorney or rep
asserting liens against recoveries in: a. b. c. L.M. v. Epstein, Case No. 502008CA028051)OOO(MB E.W. v. Epstein, Case No. 502008CA028058XXXXMB Jane Doe v, Epstein, Case No. 08-CV-80119-MARRA/JOHNSON Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S. Ma
d any investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 4. All emalls, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, and/or a
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
nd any Investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 4. All e-mails, data, correspondence, memos, or similar documents between Scott W. Rothstein, and/or any attorney or rep
Entities connected to both Jane Doe and Patrick Roberts

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Scarlett Johansson
PERSON
Alan Dershowitz
PERSONthe Southern District
LOCATIONMaria Farmer
PERSONRobert D. Critton
PERSON
George W. Bush
PERSONMichael J. Pike
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSONScott Rothstein
PERSON
A. Marie Villafana
PERSONJack Scarola
PERSON
Prince Andrew
PERSONRoy Black
PERSON
Donald Trump
PERSON