Epstein Secrets

t within his law firm and his client, that being Mr. Epstein. When further asked by the court, has Mr. Epstein

-RBR Doc 6482 Filed 10/19/18 Page 4 of 97 COURT: I disagree with you. .... Take that up in your state court litigation. (Apr. Tr. 43:19-45:6.) B. Epstein has Provided Sworn Testimony and His Attendance at the Show Cause Hearing is Not Necessary. The Court allowed Movants to take Epstein's deposition

bove cause, testified on his oath as follows: THE WITNESS: Yes. DIRECT EXAMINATION BY MR. SCAROLA: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each of your residence addresses? MR. GOLDBERGER: I think it's beyond the scope. I'm going to object to Fifth

ief Expedited Hearing Requested on or before October 24, 2018, so that the Court may rule prior to the October 26, 2018, hearing) Jeffrey Epstein ("Epstein") moves the Court, on an expedited basis, to be excused from attending the October 26, 2018, show cause hearing, and states: INTRODUCTION On April

n the United States Virgin Islands, August /‘(2018. I declare under penalty of perjury that the foregoing is true and correct. APPROV FORM: RNEY REY EPSTEIN EFTA00793497

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

BERGER, ESQUIRE For Defendants/Counter-Plaintiffs: SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. By JACK SCAROLA, ESQUIRE For Fowler White: CARLTON FIELDS, PA By JOSEPH IANNO, JR, ESQUIRE For L.M., E.W. and Jane Doe: S.J. QUINNEY COLLEGE OF LAW By PAUL G. CASSELL, ESQUIRE (Telephonically) ALSO PRES

bove cause, testified on his oath as follows: THE WITNESS: Yes. DIRECT EXAMINATION BY MR. SCAROLA: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each of your residence addresses? MR. GOLDBERGER: I think it's beyond the scope. I'm going to object to Fifth

wed to intervene in this action, now respectfully submits this Motion to Compel Jeffrey Epstein to Provide Answers to Deposition Questions. Because Epstein has improperly refused to answer multiple questions at his recent deposition, the motion should be granted. Relevant Factual Background The facts

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

he Agreed Order." DE 6366 at 5 (citing DE 1194). Mr. Epstein improperly refused to answer many questions about

BERGER, ESQUIRE For Defendants/Counter-Plaintiffs: SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. By JACK SCAROLA, ESQUIRE For Fowler White: CARLTON FIELDS, PA By JOSEPH IANNO, JR, ESQUIRE For L.M., E.W. and Jane Doe: S.J. QUINNEY COLLEGE OF LAW at the UNIVERSITY OF UTAH By PAUL G. CASSELL, ESQUIRE

r. Scarola 57 Certificate of Oath 62 Certificate of Reporter 63 Read & Sign Letter to Witness 64 EXHIBIT INDEX No. Description Page No 1 Jeffrey Epstein's Sworn Declaration 13 5 Bankruptcy Court Order 34 (Exhibits 2-4 are incorporated in the prior deposition, as agreed by Counsel.) Palm Beach Rep

ehalf of Jeffrey Epstein. MR. IANNO: Joseph Ianno, Carlton Fields on behalf of Fowler White. MR. GOLDBERGER: And Jack Goldberger on behalf of Mr. Epstein. MR. CASSELL: Paul Cassell, an attorney in Utah on behalf of L.M., E.W. and Jane Doe. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA0079360

to L.M. on that CD? MR. GOLDBERGER: I'm going to instruct Mr. Epstein to invoke his Fifth Amendment privileges as to that question, Mr. Cassell. Jeffrey, just say Fifth. THE WITNESS: Fifth. BY MR. CASSELL: Q When did you first learn about information regarding L.M. on that CD? A Sorry. The ques

MR. GOLDBERGER: And Jack Goldberger on behalf of Mr. Epstein. MR. CASSELL: Paul Cassell, an attorney in Utah

RE EDWARDS POTTINGER LLC 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 By Bradley Edwards, Esquire (Telephonically) For Fowler White: CARLTON FIELDS, PA 525 Okeechobee Boulevard, Suite 1200 West Palm Beach, FL 33401 By JOSEPH IANNO, JR, ESQUIRE Palm Beach Reporting Service, Inc. 561-471-2995

Are you aware of strong reservations having been expressed by Gary Farmer to turning over the discs containing potentially privileged materials to Jeffrey Epstein's legal counsel. MR. IANNO: You're asking if he was aware then or based on reading this? BY MR. SCAROLA: Q Are you aware, as you sit here today, t

Farmer Jaffe. MR. IANNO: Joseph Ianno, Carlton Fields, on behalf of Fowler White. MR. LINK: Scott Link and let Jennifer Lettman on behalf of Mr. Epstein. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00803635 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 2

EFTA00803632 L 1 2 3 4 APPEARANCES: For Jeffrey Epstein: LINK & ROCKENBACH, P.A. 1555 Palm Beac

Scott Link and let Jennifer Lettman on behalf of Mr. Epstein. Palm Beach Reporting Service, Inc. 561-471-2995

11 EDWARDS POTTINGER LLC 12 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 13 By Bradley Edwards, Esquire 14 For Fowler White: 15 CARLTON FIELDS, PA 525 Okeechobee Boulevard, Suite 1200 16 West Palm Beach, FL 33401 By JOSEPH IANNO, JR, ESQUIRE 17 18 ALSO PRESENT 19 Above & Beyond Repr

RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor. CASE NO.: 09-34791-RBR CHAPTER 11 MOTION FOR RELIEF FROM AMENDED ORDER ID.E. 1068t AND TO COMPEL JEFFREY EPSTEIN TO PAY FOR THE PRODUCTION OF ALL DOCUMENTS IN RESPONSE TO HIS REOUEST Movants, LM and Bradley J. Edwards, move this Court for relief from Amended O

omen who allege that they were sexually exploited, sexually abused, and otherwise victims of intentional and despicable conduct of Jeffrey Epstein. Epstein's conduct has been the subject of several lawsuits vigorously litigated by Mr. Edwards, as well as similar lawsuits filed by other well-known attor

IEF FROM AMENDED ORDER ID.E. 1068t AND TO COMPEL JEFFREY EPSTEIN TO PAY FOR THE PRODUCTION OF ALL DOCUMEN

. Shraiberg, Esq. 2385 NW Executive Drive Suite 300 Boca Raton, Florida 33431 [email protected] (VIA CM/ECF and EMAIL) Henry S. Wulf, Esq. CARLTON FIELDS, P.A. 525 Okeechobee Blvd., Suite 1200 West Palm Beach, Florida 33401 E-Mail: [email protected] (VIA CM/ECF and EMAIL) EMESS Capital, LLC

2 of 10 privilege and/or attorney work product. II. Background 3. Movant, L.M. is a party plaintiff in a civil lawsuit' against party defendant Jeffrey Epstein in which she alleges that Epstein sexually exploited, abused, and/or assaulted her when she was a minors. The parties recently reached a confidentia

ereof, states as follows: I. Introduction 1. Jeffrey Epstein, through his counsel, seeks to pull the wool over the eyes of this honorable Court. Epstein asks this Court to usurp the properly exercised jurisdiction of the Circuit Court over a subpoena duces tecum issued by the state court in connectio

STETTIN OF PRIVILEGED DOCUMENTS AND TESTIMONY TO JEFFREY EPSTEIN Movant, L.M., moves this Court pursuant

Fax: 561-998-0047 [email protected] EFTA00780315 Case 09-34791-RBR Doc 818 Filed 07/19/10 Page 10 of 10 Henry S. Wulf, Esq. (VIA EMAIL) CARLTON FIELDS, P.A. 525 Okeechobee Blvd., Suite 1200 West Palm Beach, Florida 33401 Telephone: (561) 659-7070 Facsimile: (561) 659-7368 E-Mail: hwulf@carltonl

, FJW on behalf of LM states as follows: I. BACKGROUND A. The Pending Summary Judgment and Protective Order Motions As this Court is well aware, Jeffrey Epstein (a convicted sex offender) has sued one of his alleged victims, ■ as well as attorney, Bradley J. Edwards, Esq.', in Florida state court for cond

rds, Esq.', in Florida state court for conduct that allegedly occurred in the course of Edwards' representation of multiple young female victims of Epstein's sexual abuse. While an employee of the now defunct Rothstein, Rosenfeldt, Adler firm and with his current firm, Edwards filed and pursued civil la

ctive Order Motions As this Court is well aware, Jeffrey Epstein (a convicted sex offender) has sued one o

Esq. Government Center 115 South Andrews Avenue Fort Lauderdale, FL 33301 E-Mail: [email protected] (VIA CM/ECF and EMAIL) Henry S. Wulf, Esq. CARLTON FIELDS, •. 525 Okeechobee Blvd., Suite 1200 West Palm Beach. Florida 33401 E-Mail: (VIA CM/ECF and EMAIL) EMESS Capital, LLC do Bruce A. Katzen, Esq.

by Mr. Link at the time of his first review of the files. A That's correct. Q And then a subsequent request was made for all of Fowler White's Epstein-related files, and a second delivery occurred of all of the files, correct? MR. IANNO: Object to form. THE WITNESS: With the exception of -- Palm

describe the contents of the folders. Q I understand that. But Fowler White was closing its files because it had concluded its representation of Jeffrey Epstein as of that time, correct? A Correct. Q So as far as Fowler White knows, since it had concluded its representation of Jeffrey Epstein and was c

s because it had concluded its representation of Jeffrey Epstein as of that time, correct? A Correct.

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 TO: JAMES N. HURLEY, ESQUIRE c/o JOSEPH IANNO, ESQUIRE CARLTON FIELDS, PA 525 Okeechobee Boulevard, Suite 1200 West Palm Beach, FL 33401 RE: ROTHSTEIN ROSENFELDT ADLER, P.A. At the conclusion of your deposition give