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14 15 16 17 18 19 20 21 22 23 24 25 157 ,; '~ .. \i A O~i 1 Q, And I'm just asking you if you did have '. '· 'tt .} knowledge that Jeffrey Epstein.was having sex will) {_·_ liltle girls either on the plane or al a place that you i were laking him to or from on a daily basis, thal's what t he di
ed them as witnesses to assume ce1iain facts about which they have no knowledge, and he then asks their opinions about certain facts. See Exhibit B ~Epstein's Motion for Protective Order to Prohibit Inappropriate Deposition Questions. 4. There is no information which Mr. Zinoview has relating to the fa
ein and in terms of being able to name 13 not to answer any question that goes to his opinion 13 somebody that you would say you've observed with Jeffrey 14 of someone else's motivation or the truth of facts 14 Epstein and would classify that person as Jeffrey 15 to which he has no knowledge, 15
bit A, he works for Defendant, Jeffrey Epstein ("Mr. Epstein") as a driver and bodyguard. He did not know Mr.
enzo, court reporter 2 APPEARANCES OF COUNSEL On behalf of the Plalnliff L.M.: ROTI-lSTEtN, ROSENFELDT & ADLER BY: BRADLEY J, EDWARDS, ESQ. and MICHAEL WHEELER, ESQ., 401 East Las Olas Boulevard Suite 1650 Fort Laudordale, FL 33394 954-522•3456 [email protected] [email protected] On bohalf of Pl
TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: CROW Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S LIST OF TRIAL EXHIBITS, TRIAL WITNESSES AND EXPERT WITNESSES PURSUANT TO THE COURT'S ORDER DATED APRIL 2, 2013 Plaintiff/Counter-Defendant Jeffrey
IAL EXHIBITS, TRIAL WITNESSES AND EXPERT WITNESSES PURSUANT TO THE COURT'S ORDER DATED APRIL 2, 2013 Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") hereby files his list of trial exhibits, trial witnesses, and expert witnesses pursuant to this Court's Order Setting Jury Trial and Directing Pr
JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv
ions. 13. Complaint and Docket from L.M. v. Jef•ey Epstein; 09-CV-81092- COHN. 14. Subpoena(s)/Notice(s) f
tian Address unknown at this time 46. Priscilla Nascimento Address unknown at this time 47. Maribel Matiska Address unknown at this time 48. Michael Wheeler Department of Juvenile Justice 7 EFTA00691742 2737 Centerview Drive, Suite 3220 Tallahassee, FL 32399-0999 49. Bradley Berger Address unknow
TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: CROW Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S LIST OF TRIAL EXHIBITS, TRIAL WITNESSES AND EXPERT WITNESSES PURSUANT TO THE COURT'S ORDER DATED APRIL 2, 2013 Plaintiff/Counter-Defendant Jeffrey
IAL EXHIBITS, TRIAL WITNESSES AND EXPERT WITNESSES PURSUANT TO THE COURT'S ORDER DATED APRIL 2, 2013 Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") hereby files his list of trial exhibits, trial witnesses, and expert witnesses pursuant to this Court's Order Setting Jury Trial and Directing Pr
58) in Privilege Log Dated February 23, 2011 — Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman). TASK JE IN EMAIL 64. Alan Sakowitiz LOG) [ASK JE IN EMAIL1 (Investor/Whistleblower to FBI- NOT IN PRIVILEGE 65. A. J. Discala (NOT IN PRIVILEGE LOG) [JE ALREADY SAID INCLUDE HIM AS A WITNESS] M
JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv
nce rooms for 7/23/09 re: Epstein) WHY IS THIS IN BOLD FACE. SHE DID RESERVE THE ROOMS ACCORDING TO THE PRIVILEGE LOG?1 47. Maribel Matiska 48. Michael Wheeler 49. Bradley Berger 50. Shawn Gilbert 51. Ronald Wise 52. Wayne Black 53. Susan Stirling 54. Kendall Coffey 55. Seth Lehrman 56. Phaed
32 08/06/2009 Adam Horowitz Bradley J. Edwards Epsteins assets Joint-privilege 16 EFTA00310063 Privi
ATE TO FROM DESCRIPTION OBJECTION Confidential 07030 09/22/2009 Bradley J. Edwards Spencer Kuvin v. Epstein — defendant, Joint-privilege Jeffrey Epstein's response to plantiff 07090.07091 9/29/2009 Bradley J. Edwards Katherine W. Ezell Leslie Wexner Joint-privilege 07092 10/29/2009 Stuart Me
Edwards Adam Horowitz Jeffrey Epstein DUI W35755 Joint-privilege 02462 09/22/09 Spencer Kuvin Bradley J. Edwards III v. Epstein — Defendant, Jeffrey Epstein"s Response to Plantiff Motion for Protective Order Joint-privilege 02476-02477 09/25/2009 Spencer Kuvin Bradley J. Edwards LM v EPST
Katherine W. Bradley J. Edwards Is Mark Epstein JE's brother? Joint-privilege 18 EFTA00310065 P
levant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01296 10/02/2009 Mike Fisten Michael Wheeler Subpoena of Detective Recarey W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evi
2 08/06/2009 Adam Horowitz Bradley J. Edwards Epsteins assets Joint-privilege 16 EFTA00602850 Privi
man BATES DATE TO FROM DESCRIPTION OBJECTION Confidential 07030 09/22/2009 Bradley J. Edwards Spencer Kuvin IM v. Epstein — defendant, Jeffrey Epstein's response to plantiff Joint-privilege 07090-07091 9/29/2009 Bradley J. Edwards Katherine W. Ezell Leslie Wexner Joint-privilege 07092 10/29
Edwards Adam Horowitz Jeffrey Epstein oat W35755 Joint-privilege 02462 09/22/09 Spencer Kuvin Bradley J. Edwards I■ v. Epstein — Defendant, Jeffrey Epstein"s Response to Plantiff •'s Motion for Protective Order Joint-privilege 02476-02477 09/25/2009 Spencer Kuvin BradleyJ. Edwards LM v
Katherine W. Bradley J. Edwards Is Mark Epstein JE's brother? Joint-privilege 18 EFTA00602852 P
levant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 01296 10/02/2009 Mike Fisten Michael Wheeler Subpoena of Detective Recarey W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evi
TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: CROW Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S LIST OF TRIAL EXHIBITS, TRIAL WITNESSES AND EXPERT WITNESSES PURSUANT TO THE COURT'S ORDER DATED APRIL 2, 2013 Plaintiff/Counter-Defendant Jeffrey
IAL EXHIBITS, TRIAL WITNESSES AND EXPERT WITNESSES PURSUANT TO THE COURT'S ORDER DATED APRIL 2, 2013 Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") hereby files his list of trial exhibits, trial witnesses, and expert witnesses pursuant to this Court's Order Setting Jury Trial and Directing Pr
JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv
NOT IN PRIVILEGE LOG) 4 EFTA00655524 43. Steven Jaffee 44. Marc Nurik 45. Nora Batian 46. Priscilla Nascimento 47. Maribel Matiska 48. Michael Wheeler 49. Bradley Berger 50. Shawn Gilbert 51. Ronald Wise 52. Wayne Black 53. Susan Stirling 54. Kendall Coffey 55. Seth Lehrman 56. Phaed
THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: CROW PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S LIST OF TRIAL EXHIBITS, TRIAL WITNESSES AND EXPERT WITNESSES Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") hereby files his list of tria
TIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S LIST OF TRIAL EXHIBITS, TRIAL WITNESSES AND EXPERT WITNESSES Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") hereby files his list of trial exhibits, trial witnesses, and expert witnesses pursuant to this Court's Order Setting Jury Trial and Directing Pr
JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv
nknown at this time 46. Priscilla Nascimento Address unknown at this time 47. Maribel Matiska EFTA00587272 Address unknown at this time 48. Michael Wheeler Department of Juvenile Justice 2737 Centerview Drive, Suite 3220 Tallahassee, FL 32399-0999 49. Bradley Berger Address unknown at this time 50
starting his own. Together with another lawyer at the firm, Brad Edwards, Berger worked on the cases of two alleged underage victims of billionaire Jeffery Epstein's sexual dalliances in his Palm Beach mansion. The women are currently suing Epstein, and the lawyers represent them on a contingency fee basis, Berg
e cases of two alleged underage victims of billionaire Jeffery Epstein's sexual dalliances in his Palm Beach mansion. The women are currently suing Epstein, and the lawyers represent them on a contingency fee basis, Berger said. Epstein's legal team is exploring accounts that Rothstein fraudulently ped
hat happened to these players, you're wondering? In June, the three former ABT officials — Maj. Pat Roberts, Lt. Michael Fisten and Senior Attorney Michael Wheeler — have gone to work for the law firm that represents the Cheetah: Rothstein, Rosenfeldt and Adler. Roberts had supervised the Cheetah investigation
OLA BARNHART Fr-SHIPLEYp. MAIL March 22, 2011 Robert B. Carney, Special Master 2281 Saratoga Lane West Palm Beach, FL 33409 Re: Edwards adv. Epstein Our File No.: 291874 Dear Judge Carney: OTAI LAHARSFE OFFICE- Attached please find the Master Contact List pursuant to your Interim Report in this
o Spencer Kuvin Maribel Matiska RRA Paralegal Mark Fistos Attorney RRA Mercedes Estrada Katherine Ezell's Assistant MG Client (Epstein Case) Michael Wheeler Attorney RRA Mike Fisten Investigators RRA N.R. Client communication Nora Batian RRA Staff Pasqual "Pat" Diaz Investigators RRA Pat Roberts
TOWLE HO SE TALLAHASSEE. FL 32331-1231 TALLAHASSEE, March 22, 2011 Robert B. Carney, Special Master West Palm Beach, FL 33409 Re: Edwards adv. Epstein Our File No.: Dear Judge Camey: Attached please find the Master Contact List pursuant to your Interim Report in this matter. Sincerely, Dictate
nt to Spencer Kuvin Maribel Matiska RRA Paralegal Mark Fistos Attorney RRA Mercedes Estrada Katherine Ezell's Assistant Client (Epstein Case) Michael Wheeler Attorney RRA Mike Fisten Investigators RRA Client communication Nora Batian RRA Staff Pasqua] "Pat" Diaz Investigators RRA Pat Roberts Inve
Entities connected to both Jeffrey Epstein and Michael Wheeler

Richard Kahn
PERSON
Marc Rich
PERSONLarry Visoski
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATION
JPMorgan Chase
ORGANIZATION
Lawrence Krauss
PERSON
Stephen Hawking
PERSONJack Goldberger
PERSON
Sarah Kellen
PERSON
Prince Charles
PERSONJane Doe
PERSON
Martha Stewart
PERSON
Tom Pritzker
PERSON