Epstein Secrets

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro.1201 Plaintiff, v. Case No. 50 2009 CA 040800XXXXMB AG SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWA

ive as necessary in order to bring within the scope of each request all documents which might otherwise be construed to be outside its scope. 5. "Epstein" refers to Jeffrey Epstein, the Plaintiff in the captioned lawsuit. 6. " , "you" or "yours" refers to 7. "Edwards" means Bradley J. Edwards, a de

L CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro.12

atives of or persons purporting to be affiliated with RRA, including without limitation, Mike Fisten, Ken Jenne, Wayne Black, Patrick Patrick Diaz, Rick Fandry, Cara Holmes, William Berger, Russell Adler and Mark Nurik, or any other representatives of or persons purporting to be affiliated with RRA or repre

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro.1201 Plaintiff, v. Case No. 50 2009 CA 040800XXXXMB AG SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWA

ive as necessary in order to bring within the scope of each request all documents which might otherwise be construed to be outside its scope. 5. "Epstein" refers to Jeffrey Epstein, the Plaintiff in the captioned lawsuit. 6. 7. "Edwards" means Bradley J. Edwards, a defendant in the captioned lawsuit

L CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro.12

or persons purporting to be affiliated with RRA, including without limitation, Mike Fisten, Ken Jenne, Wayne Black, Patrick Roberts, Patrick Diaz, Rick Fandry, Cara Holmes, William Berger, Russell Adler and Mark Nurik, or any other representatives of or persons purporting to be affiliated with RRA or repre

: 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

g)? 21.9.6 What is Blue Line R & D? 21.10 Knowledge of skills and involvement of: 21.10.1 Mike Fisten 21.10.2 Ken Jenne 21.10.3 Patrick 21.10.4 Rick Fandry 22. Criminal History - have you ever been convicted of a crime? If yes, when and for what? C:WserAill0JAVIMApplkdatocallAticsosoll1Windowsffempor