Epstein Secrets

or Palm Beach County (hereinafter, the "State Attorney's Office") have conducted an investigation into the conduct of Jeffrey Epstein (hereinafter "Epstein"); IT APPEARING that the State Attorney's Office has charged Epstein by indictment with solicitation of prostitution, in violation of Florida Statu

24 25 CERTIFIED QUESTIONS Page Line 61 22 123 20 146 14 148 1 153 5 159 13 162 3 EFTA01695652 3 1 The videotaped deposition of JEFFREY 2 EPSTEIN in the above-entitled and numbered cause, 3 was taken before me, S a Registered 4 Professional Reporter and Notary Public for the 5 State of F

ive us your name. 9 A Jeffrey Epstein. 10 Q Mr. Epstein, you made a comment when you 11 came in the roo

to noon, with a majority of the days indicating between 9am and 10am. COUNT #2 On August 27, 2009, a FAA Certified Pilot who is in the employ of Jeffrey i E tein *th Jeffrey Epstein, and Jeffrey Epstein's at the West Palm Beach Airport. During a deposition of m ss on October 15, 2009, he testifie

Fourteenth Amendment and Fifth Amendment rights under the U.S. Constitution. The Court Reporter noted that she was just an eye witness to deponent Jeffrey Epst ' tting blatant perjury. She herself heard him say at least three times that he liked t By answering those questions in the manner he did and under o

Deposition if a civil matter where he is a defendant. Prior to the onset of the deposition, Epstein was seated in an office along with Attorney's Steven Jaffe and Court Reporter i=ii=i Jeffrey Epstein, engaged the attorney's in an unsolicited conversation where he stated "I like your other two, I don't l

Esq.? How about Mark Fistos, Esq.? Were they all secret co- conspirators who have managed to avoid justice for the past nine years? Justice that only Jeffrey Epstein and his counsel can deliver upon? Does Epstein plan to report his "bombshell" findings to 3 Edwards is somewhat confused as to how Epstein could hav

, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and ■l., individually, Defendants. RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION FOR COURT TO DECLARE RELEVANCE AND NON-PRIVILEGED NATURE OF DOCUMENTS AND REQUEST FOR ADDITIONAL LIMITED DISCOVERY, EVIDENTIARY HEARING, A

OUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

cause a media circus, taint the jury pool, and prevent the parties to the Malicious Prosecution action from picking a jury as presently scheduled. B. Epstein and His Counsel Have "Jumped the Shark."2 5. In his Notice of Filing Appendix. Epstein, through counsel, includes privileged materials under a sect

les of Epstein's legal army for over 5 years!; 7. Is Epstein accusing Matt Weissing, Esq. of being directly involved in Rothstein's Ponzi scheme? Steven Jaffe, Esq.? How about Mark Fistos, Esq.? Were they all secret co- conspirators who have managed to avoid justice for the past nine years? Justice that onl

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

vilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03015 04/24/2009 Steven Jaffe Susan Stirling Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissi

the discovery of admissible evidence; protected by privacy rights 02411-02413 05/12/2009 Attorneys at RRA Bradley J. Edwards Jane Doe II v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protect

the discovery of the admissible evidence; protected by privacy rights 01003-01005 10/12/2009 Bradley Edwards Paul Cassell Asset movement by Jeffrey Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protect

calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05403-05405 04/27/2009 Marc Nurik Bradley Edwards Jeffrey Epstein Wikipedia page Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; pr

0 09/13/2009 Bradley Edwards Paul Cassell "Is Jeffrey Epstein the new Madoff — Running a giant Ponzi

reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 27155-27159 10/23/2009 Attorneys at RRA Steven Jaffe PACER entries Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the 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

vilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 03015 04/24/2009 Steven Jaffe Susan Stirling Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissi

the discovery of admissible evidence; protected by privacy rights 02411-02413 05/12/2009 Attorneys at RRA Bradley J. Edwards Jane Doe II v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protect

the discovery of the admissible evidence; protected by privacy rights 01003.01005 10/12/2009 Bradley Edwards Paul Cassell Asset movement by Jeffrey Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protect

calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05403-05405 04/27/2009 Marc Nurik Bradley Edwards Jeffrey Epstein Wikipedia page Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; pr

0 09/13/2009 Bradley Edwards Paul Cassell "Is Jeffrey Epstein the new Madoff — Running a giant Ponzi

reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 27155-27159 10/23/2009 Attorneys at RRA Steven Jaffe PACER entries Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evi

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

hawn Gilbert Prior Legal Assistant to Brad Edwards Sid Garcia Counsel for other Epstein Victims Spencer Kuvin Counsel for other Epstein Victims Steven Jaffe Attorney RRA Stuart Mermelstein Counsel for other Epstein Victims EFTA00314202 MASTER CONTACT LIST REGARDING Privilege Log — Dated 2-23-2011 F

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

hawn Gilbert Prior Legal Assistant to Brad Edwards Sid Garcia Counsel for other Epstein Victims Spencer Kuvin Counsel for other Epstein Victims Steven Jaffe Attorney RRA Stuart Mermelstein Counsel for other Epstein Victims EFTA00314212 MASTER CONTACT LIST REGARDING Privilege Log — Dated 2-23-2011 F

. tb La) VIA EMAIL AND U.S. MAIL March 22, 2011 Robert B. Carney, Special Master 2281 Saratoga Lane West Palm Beach, FL 33409 Re: Edwards adv. Epstein Our File No.: Dear Judge Carney: 291874 (TALLAHASSEE OFFICE: THE TOWLE HOUSE 517 NORTH CALHOUN STREET TALLAHASSEE, FL. 32301-1231 P.O. BOX 1230

stant to Brad Edwards Sid Garcia Counsel for other Epstein Victims Counsel for other Epstein Victims Attorney RRA Counsel for other Epstein Victims Steven Jaffe Stuart Mermelstein HOUSE_OVERSIGHT_012709 --- PAGE BREAK --- MASTER CONTACT LIST REGARDING Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissin