Epstein Secrets

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

outh, Suite 1401 New York, NY 10001-0646 66. Thane Ritchie Address unknown at this time 67. Dean Kretschmar Address unknown at this time 68. Michael Legamaro [INCLUDED ON DARREN'S EMAIL; NOT SURE IF HE INTENDED TO INCLUDE HIM ON THIS LISEJ 69. Debra Villegas Address unknown at this time 70. Mark Epst

o add additional levels of security for the investors was good. So, it stayed in the package unless someone said they didn't want it. Q Now, the Epstein settlements were used by you based on actual cases with Jeffrey Epstein A Yes, on that. Q -- Palm Beach person? A Yes. Q Do you recall that?

So, it stayed in the package unless someone said they didn't want it. Q Now, the Epstein settlements were used by you based on actual cases with Jeffrey Epstein A Yes, on that. Q -- Palm Beach person? A Yes. Q Do you recall that? A Yes. Q And do you recall that my clients were D-3 investors who i

ents were used by you based on actual cases with Jeffrey Epstein A Yes, on that. Q -- Palm Beach perso

rls was fiction, it was a lie? A Not as far as Mr. Epstein is concerned but as far as the other people are

la and Von Allmen and other people of the Razorback group? A I do. Q Do you recall when they came to your office and you brought down boxes for Michael Legamaro to review? A The boxes were actually already in my office. Q Well, there's some testimony that you called and asked Ren Jenne and Fistas to brin

Fowler White Burnett ATTORNEYS AT LAW Mr. Jeffrey Epstein 301 East 66th Street Suite 10 B New York, NY 10065 Ref.: Jeffrey Epstein vs. Scott Rothstein, Bradley Edwards and L.M. INVOICE Espirito Santo

wler White Burnett ATTORNEYS AT LAW Mr. Jeffrey Epstein 301 East 66th Street Suite 10 B New York, NY 1

Fowler White Burnett ATTORNEYS AT LAW Mr. Jeffrey Epstein 301 East 66th Street Suite 10 B New Yo

while attending hearing of Jack Scarola in Palm Beach, FL on 2/16/11 LAS $ 72.81 03/11/11 Airfare expense incurred while attending deposition of Michael Legamaro in Chicago on 3/9-3/11/11 SA $ 1,642.40 03/11/11 Hotel expense incurred while attending deposition of Michael Legamaro in Chicago on 3/9-3/11/1

Fowler White Burnett )„ ATTORNEYS AT LAW Mr. Jeffrey Epstein 301 East 66th Street Suite 10 B New York, NY 10065 Ref.: Jeffrey Epstein vs. Scott Rothstein, Bradle Edwards and L.M. Espirito Santo Plaza Fou

r White Burnett )„ ATTORNEYS AT LAW Mr. Jeffrey Epstein 301 East 66th Street Suite 10 B New York, NY 1

Fowler White Burnett )„ ATTORNEYS AT LAW Mr. Jeffrey Epstein 301 East 66th Street Suite 10 B New Yo

k on 5/25/11 CEK $ 9.60 03/30/11 Madison Deposition Services LLC; Invoice# 5598 dated 3/30/2011 - Service re: Duplicate Deposition of Transcript Michael Legamaro SA $ 777.60 05/10/11 Palm Beach Copy Service, Inc.; Invoice# 92923 dated 5/10/2011 - Service re: Duplicate Light Litigation LAS $ 308.38 05/1

ves or any other electronic format and any written transcriptions). 12. All conversations recorded from any telephones which purported to be from Jeffrey Epstein's attorneys including Roy Black, Alan Dershowitz or Jack Goldberger, that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives

93-Marra/Johnson), and any other person who is or was represented by Rothstein Rosenfeldt & Adler that has not yet filed an action against .leffre, Epstein, and any employee, agent or attorney for any plaintiff and/or any other person acting for or on behalf of any plaintiff, or under her authority and

n or agreement. C. "Plaintiff means =. (MI. v. Jeffrey Epstein, Palm Beach County Case #502008CA0280S1X

ting to act on their behalf (including without limitation, A.J. 5 EFTA00616124 Case 09-34791-RBR Doc 1323 Filed 01/12/11 Page 6 of 8 Discala, Michael Legamaro and Dean ICretschmar), relating to, but not limited to, any case (real or fabricated) involving Jeffrey Epstein and any of the following: a. Scott

IT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800X.XXXMB-AG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. SECOND AMENDED COMPLAINT The Plaintiff, Jeffrey

, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. SECOND AMENDED COMPLAINT The Plaintiff, Jeffrey Epstein, ("Epstein"), by and through his undersigned attorneys, files this action against the Defendants, Scott Rothstein, ("Rothstein") and Bradley J. Edwards ("Edwa

O. 502009CA040800X.XXXMB-AG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, indivi

look at the Epstein case files that Fisten and Jenne had stacked around the conference room. 17. On or about October 13, 2009, Illinois attorney, Michael Legamaro, and his client, hedge fund operator Thane Ritchie, were also invited to examine Epstein case files and a flight log displayed by Rothstein that al

IT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800X.XXXMB-AG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. SECOND AMENDED COMPLAINT The Plaintiff, Jeffrey

, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. SECOND AMENDED COMPLAINT The Plaintiff, Jeffrey Epstein, ("Epstein"), by and through his undersigned attorneys, files this action against the Defendants, Scott Rothstein, ("Rothstein") and Bradley J. Edwards ("Edwa

O. 502009CA040800X.XXXMB-AG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, indivi

look at the Epstein case files that Fisten and Jenne had stacked around the conference room. 17. On or about October 13, 2009, Illinois attorney, Michael Legamaro, and his client, hedge fund operator Thane Ritchie, were also invited to examine Epstein case files and a flight log displayed by Rothstein that al

: Susan H. Aprill DATE: April 18, 2011 RE: Outline of deposition of Russell Adler, former RRA partner FILE NO.: 80743 DRAFT 4 18 11 8:21 PM Epstein v. Rothstein & Edwards Outline for Russell Adler Deposition, 4-20-11 @ 9:30 am 1. Introduction 1.1 Name 1.2 Home address; business address 1.

e do? 12.1.2 what level of atty? DRAFT 4 18 11 8:21 PM 13. 14. JEE CASES 14.1 Did you ever work on any cases at RRA against a defendant named JE? 14.2 Starting when? 14.3 Did you know who JEE was prior to working on any case? 14.4 How? 14.5 What did you know of him at first? From what

are of investors coming in and looking at Epstein files? 19.18 ever meet any? 19.19 Did Jenne or Fisten tell you they brought in files? 19.20 know Michael Legamaro? Hear of him? Who is he? 20. Does he know a 20.1 If so, did he ever talk to her, give her an interview, etc.? 21. Did he ever instruct RRA inve

by Fax and U.S. Mail Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Re: Epstein v. Rothstein, et al. Dear Mr. Scarola: I am in receipt of your March 17, 2010 letter providing my client and his attorneys with your F.S. §57.105

issues is critical in evaluating your Notice and Mr. Epstein's case against Mr. Edwards. Additionally, as pa

aluate the Notice which was sent. We also have requested days for the completion of Mr. Edwards' deposition, taking the deposition of A.J. DiScala, Michael Legamaro, Michael Fisten and Richard Fandrey. While we obtained April 19, 2010 for Fisten and Fandrey, the dates that you have given for the others are mont

DRAFT OF: February 18, 2011 EPSTEIN NAMES IN APPEARING IN VARIOUS DEPOSITIONS FROM RUSSELL Jack Simone Gary Farmer Steve Lippman Robert Buschel Russell Mix Frank Veilson Jacky

n Kretchmar Doug Van Allman Ted Morse Ed Morse Richard Pearson Stevin Levin Ira Sochet Mark Melvin Jack Samoney Lawrence King Steve Jackel Michael Legamaro Kevin Draber David Boden Andrew Barnett Alan Sakowitz Mark Nurik Mark Fistos Tommy Mottola Officer Recarey Interviewed by Michael Fisten In