Epstein Secrets

PSTEIN, ROTHSTEIN, the Litigation Team and, at times, L.M., E.W., Jane Doe in the Civil Actions against EPSTEIN: a) Included claims for damages in Jane Doe's federal action in excess of $50,000,000.00 rather than simply alleging the jurisdictional limits. b) Made Jane Doe available for TV media intervie

LER ("ADLER"), is an individual residing in County, Florida and is licensed to practice law in the State of Florida. At all times relevant hereto, ADLER was the third-named partner of RRA and thus was an employee, agent, associate, partner, shareholder, and/or other representative of RRA. EFTA007253

ion Team and, at times, L.M. in the Civil Action against EPSTEIN: EFTA00725306 Epstein v. RRA, et al. Page 19 a) Included claims for damages in Jane Doe's federal action in excess of $50,000,000.00 rather than simply alleging the jurisdictional limits. b) Made Jane Doe available for TV media intervie

esentation involving alleged Epstein settlements (current and future) and other alleged matters. 4. ROTHSTEIN and others in RRA, including, BERGER, ADLER and EDWARDS, abused the legal process, by not simply aggressively litigating existing cases, but conducting discovery and making media presentation

d, my sister, my current 2 boyfriend. 3 Q. Current boyfriend is who? 4 A. 5 Q. Okay. 6 A. My ex-boyfriend and who else -- and 7 friends, Jane Doe No. 7, That's it. 8 Q. Who is your closet friend? 9 A. Jane Doe No. 7. 10 Q. Okay. So she knows? 11 A. Yeah. 12 Q. Who's your second-close

t Reporting 23 24 25 0309 1 APPEARANCES: 2 On behalf of the Plaintiff, L.M. and E.W.: 3 MICHAEL J. WHEELER, ESQUIRE ROTHSTEIN, ROSENFELDT, ADLER 4 401 East Las Olas Boulevard Suite 1650 5 Fort Lauderdale Florida 33301 Phone: 6 7 On behalf of Jane Does 1 through 8: 8 ADAM D. HOROWITZ

t Las OHS 130.40Velt1 5 Page S41[91650 ran Lo, ie. FL 31394 6 DIRECT EXAMINATION By Mr. Edwards #5 7 CROSS-EXAMINATION On betel d Planter Jane Doe 2 through s By Ms. Ezell *190 T mERUELSTE1N 6 HOROWITZ. PA 9 CROSS-EXAMINATION By Mr. Willits #195 10 BY: JESSICA D. ARBOUR. ATTORMEY.AT4AW.

16 19 20 21 22 23 24 25 2 4 1 APPEARANCES OF COUNSEL 1 INDEX OF EXAMINATION e I On banal a the Flambe L.M.. ROTHSTEIN. 110SENFELDT a ADLER 2 BY: BRADLEY J. EDWARDS. ESO. 3 WITNESS: 4 111X1MICHAEL WHEELER. ESO.. 4 LARRY EUGENE MORRISON 401 East Las OHS 130.40Velt1 5 Page S41[9

sanctions pursuant to Rule 30(dX2) aril (3)(A) and (C) (referencing Rule 37(aX5)), Federal Rules of Civil Procedure and compelling the deposition of Jane Doe No. 4 within fifteen (15) days and as grounds therefore would state: 1. On August 16, 2009, the deposition of Jane Doe No. 4 was noticed for Septe

dant, Jaffna' Efancia• 17 Os beialfeglAlailEV: It William J. BERGS* ESQUIRE 17 MR. HOROWITZ: This is Adam iiceowiM. 235.131STE04110612070.156. ADLER 18 We're canceling todays deposition. Before It mai sr Las ode anew/4 9.M 1650 19 appearing here today, we had a stipulation with 22 Pet La

has met her burden, should the Court consider adopting such extraordinary relief. On its face, the motion does not meet the necessary burden as to Jane Doe 4, or Jane Does 2, 3, 5, 6, or 7. Discussion of Law Requiring the Denial of the Requested Protective Order Rule 26(c)(1XE), Fed.R.Civ P. (2009), gove

0 14 15 Was 33401.5012 33401-5012 15 16 Ph011t 16 17 10 Out behatfallA4 and SW: W1111A1411. BERGER. ESQUIRE 17 ROTHSTEIN. FtOSENFELDT. ADLER 18 19 401 Bs Lau OW Boakard Are 1650 19 20 Pod latillara 3330) 20 21. Tom 21 22 Oa Oshatfolf04A.: 22 23 JACK P. H11/, ESQUIRE SEARC

has met her burden, should the Court consider adopting such extraordinary relief. On its face, the motion does not meet the necessary burden as to Jane Doe 4, or Jane Does 2, 3, 5, 6, or 7. Discussion of Law Requiring the Denial of the Requested Protective Order Rule 26(c)(1XE), Fed.R.Civ P. (2009), gove

15 Wm Aim Bach Mode 33401.5012 15 16 Mom :561.6591300 16 17 On Wolf 441.64 and EW: 17 is WULAM3. BERGER 83Q4.4112 RCTIZSTEIN, FtOSENFELDT. ADLER 18 29 401 hoar Ohs Ilookurd 19 Suiie 1650 20 Pori Liadordok Florida 33301 20 21. Phone 934.m3456 21 22 Om Wulf a 04A: 22 23 /AM P. 30