Epstein Secrets

from the U.S. Attorney's Office to Epstein's counsel (see ¶6) specifically in support of his contention that there was a 'joint attempt to minimize Epitein's civil exposure." 3 EFTA00208199 Case 9:08-cv-80736-KAM Document 177-1 Entered on FLSD Docket 06/06/2012 Page 16 of 22 Epstein v. Rothstein an

FLSD Docket 06/06/2012 Page 1 of 22 Tonja Haddad Coleman From: Sent: To: Subject: Thank you. Jack Scarola Tuesday, May 08, 2012 3:41 PM Re: Epstein discovery On May 8, 2012. at 3:27 PM. "Tonja Haddad Coleman" MINIMI > > Fine. > Tonja Haddad Coleman. Esq. > Tonja Haddad, P.A. > Justice Buildi

iffiCounter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. ORDER ON PLAINTIFF JEFFREY EPSTEIN'S MOTION TO COMPEL AND AMEND PROTECTIVE ORDER THIS MATTER came before the Court on PlaintiffJeffrey Epstein's Motion to Compel and Amend Protective

NO. 502009CA0408003OOO134B Judge David F. Crow JEFFREY EPSTEIN, PlaintiffiCounter-Defendant, v. SCOTT

ing but not limited to, Scott Rothstein, Russell Adler, Williaria Berger, Michael Fisten, Ken Jenne, David Boden, Deborah Villegas, Andrew Barnett, Patrick Roberts, Richard Fandry, Christina Kittennan, Gary Farmer and Bradley Edwards, on the one hand, and any of the following regarding Jeffrey Epstein: 2 EFT

ives or any other electronic format and any written transcriptions). 13. All conversations recorded from any telephones which purported to be from Jeffrey Epatein's attorneys including Roy Black, Alan Dershowitz or Jack Goldberger, that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives

ally, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. gPSTEIN'S REQUEST TO PRODUCE TO EDWARDS Defendant, JEFFREY EPSTEIN ('Epstein'), pursuant to Fla. R. Civ. P. 1.350, requests that Defendant, BRADLEY J. EDWARDS (*Edwards"), produce or make available for inspection documents r

CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN Complex Litigation, Ha. R. Civ. Pro.120

What the evidence is really going to show is that Mr. Epstein — at least dating back as far as our Investigati

d any investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (Including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 4. All emalls, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, and/or a

rrett, 742 So. 2d 451 (Fla. 5th DCA 1999. Therefore, if the answer was evident from the complaint eventually filed by Edwards ("to seek redress from Jeffrey Epstein"), it would not be privileged. Likewise, if L.M. had initially hired Edwards to consult him about a claim she never pursued, the subject might argua

lm Beach County Courthouse, 205 North Dixie Highway, Courtroom 9C, West Palm Beach, Florida 33401 on Friday, April 1, at 9:00 a.m., the following: EPSTEIN'S AMENDED AND SUPPLEMENTAL MOTION OF PLAINTIFF TO OVERRULE OBJECTIONS AND COMPEL DEFENDANT EDWARDS TO ANSWER QUESTIONS AND APPEAR FOR FURTHER DEPOS

NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, indivi

you put into Q-task regarding the claims against Mr. Epstein? Edwards had filed suits against Epstein on beha

tographs . ...? MR. SCAROLA: Same objection [work-product, attorney-client privilege] and instruction. Id. at 199, lines 25, 1-12. Q. [regarding Patrick Roberts] Did he ever perform investigation work on any of the Epstein files? MR. SCAROLA: Same objection [work-product, attorney-client privilege] and ins

ives or any other electronic format and any written transcriptions). 13. 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

Beach County Courthouse, 205 North Dixie Highway, Courtroom 9C, West Palm Beach, Florida 33401, on Tuesday, April 5, at 8:30 a.m., the following: EPSTEIN'S MOTION TO COMPEL/MOTION TO DETERMINE IF PRIVILEGE CLAIMS ARE WAIVED The following procedures must be noted on all specially set hearing notices i

NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, indivi

and/or Scott Rothstein relating to any aspect of Mr. Epstein's case. Objections were based on relevance and o

d any investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 4. All emalls, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, and/or a

ves or any other electronic format and any written transcriptions). 11. 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

, joint-venture or business enterprise involving RRA, Rothstein or a Rothstein-related entity that reference any claim (real or fabricated) against Epstein. 14. All emails exchanged between-any of the following individuals wherein Epstein, a Palm Beach billionaire or similar reference was mentioned:

n or agreement. C. "Plaintiff' means M. (I. v. Jeffrey Epstein, Palm Beach County Case #502008CA028051X

nd any Investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 3. All e-mails, data, correspondence, memos, or similar documents between Scott W. Rothstein, and/or any attorney or rep

ves or any other electronic format and any written transcriptions). II. 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

, joint-venture or business enterprise involving RRA, Rothstein or a Rothstein-related entity that reference any claim (real or fabricated) against Epstein. 14. All emails exchanged between-any of the following individuals wherein Epstein, a Palm Beach billionaire or similar reference was mentioned:

or agreement. C. "Plaintiff means L.M. (L.M. v. Jeffrey Epstein, Palm Beach County Case #502008CA028051X

nd any Investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 3. All e-mails, data, correspondence, memos, or similar documents between Scott W. Rothstein, and/or any attorney or rep

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

ents or other representatives of 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

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

nd any Investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 4. All e-mails, data, correspondence, memos, or similar documents between Scott W. Rothstein, and/or any attorney or rep

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and •., individually, Defendants. Complex Litigation, Fla. R.

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" means the Plaintiff. 6. "Holmes" "You" or "Yours" refers to Cara Holmes. 7. "Edwards" means Defendant Bradley J. Edwards. "Rothstein" means Defe

ler White & Burnett, M. Attorneys for Plaintiff! Jeffrey E stein FOWLER WHITE BURNETT M. Phillips Point 7

2008 to the present: a. Rothstein; b. Edwards; c. Russell Adler; d. William Berger; e. Mike Fisten; f. Ken Jenne; g. Wayne Black; h. Patrick Roberts; i. Patrick Diaz 2. All written communications between you and any of the following employees, independent contractors, attorneys, partners, sha

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

in Appellate attorney from Utah Investigator, former Broward Sheriff Investigator Media rep (?) Media rep (?) -1- EFTA00600049 Michael Sanka Patrick Roberts Nesbitt Kirkendahl Jason Richards Dexter Lee Maria Villafana Mark Epstein Judge Stone Deborah Villegas Bart' Bekkadan A.J. Discala Alfredo