Epstein Secrets

650 652 1 APPEARANCES (Continued): 1 Thereupon. the proceedings continued at 9:04 a.m. 2 2 VIDEOGRAPHER: Are now on the video 3 On behalf of Jeffrey Epstein: 3 record. This is the 13th day of January. 2016. 4 DARREN K. INDYKE. PLLC 4 The time is 9:04 am. This is the videotaped 575 Lexington Ave.. 4

uld allow him to answer it. He's 670 672 1 those allegations? 1 trying to be responsive to the question. 2 A. I don't think he was aware that Jeffrey 2 Please proceed. 3 Epstein had nude an allegation of that kind. 3 A. One of them was a Conner president or 4 Q. At the time when David Marku

670 672 1 those allegations? 1 trying to be responsive to the question. 2 A. I don't think he was aware that Jeffrey 2 Please proceed. 3 Epstein had nude an allegation of that kind. 3 A. One of them was a Conner president or 4 Q. At the time when David Markus called you 4 chairman or at

ou 8 Rothstein did not do anything without conferring 8 Brad Edwards was the brains behind the Scott 9 with Brad Edwards. were you representing Jeffrey 9 Rothstein operation? 10 Epstein? 10 A. I cant give you a name of somebody who 11 A. Yes. 11 said those precise words outside the privilege. 1

YKE: If Mr. Dershowitz is 4 I. 4 referring to Mr. Epstein. then I would object 5 BY MR. EDWARDS: 5 to —

endant. VIDEOTAPE CONTINUED DEPOSITION OF ALAN M. DERSHOWITZ VOLUME 5 Pages 648 through 781 Wednesday, January 13, 2016 9:04 a.m. - 11:59 a.m. Tripp Scott 110 Southeast 6th Street Fort Lauderdale, Florida Stenographically Reported By: Kimberly Fontalvo, RPR, CLR Realtime Systems Administrator www.

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

cayne Tower Suite 3700 Two South Biscayne Boulevard Miami, Florida 33131 (VIA U.S. MAIL and EMAIL) John G. Bianco, Esq. John M. Mulli, Esquire Tripp Scott 110 Southeast Sixth Street Fifteenth Floor Fort Lauderdale, Fl. 33301 jgb®trippscott.com (VIA CM/ECF and EMAIL) Alison W. Lehr, Esq. Grisel Al

LORIDA Fort Lauderdale Division www. flsb.uscourts.gov IN RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor. Case No. 09-3479 I-BKC-RBR Chapter 11 JEFFREY EPSTEIN'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS FROM TRUSTEE PURSUANT TO DOCUMENT PRODUCTION PROTOCOL ESTABLISHED BY DE #672 JEFFREY EPSTEIN ("EPSTEIN"),

EPSTEIN'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS FROM TRUSTEE PURSUANT TO DOCUMENT PRODUCTION PROTOCOL ESTABLISHED BY DE #672 JEFFREY EPSTEIN ("EPSTEIN"), by and through undersigned counsel, respectfully moves this Honorable Court pursuant to the provisions of Fed.R.Civ.37(a) (which is incorporated

Debtor. Case No. 09-3479 I-BKC-RBR Chapter 11 JEFFREY EPSTEIN'S MOTION TO COMPEL PRODUCTION OF DOCUMEN

he Honorable Herbert Stettin One Biscayne Tower, # 3700 Two South Biscayne Blvd. Miami, FL 33131 (Via U.S. Mail and email) John G. Bianco, Esq. Tripp Scott 110 S.E. Sixth Street, 15th FL Ft. Lauderdale, FL 33301 Alison W. Lehr, Esq. Assistant U.S. Attorney 99 N.E. 4th Street, 7th FL Miami, FL 33132

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

MAIL) One Biscayne Tower Suite 3700 Two South Biscayne Boulevard Miami, Florida 33131 John G. Bianco, Esq. (VIA CM/ECF) John M. Mulli, Esquire Tripp Scott 110 Southeast Sixth Street Fifteenth Floor Fort Lauderdale, Fl. 33301 [email protected] 7 Alison W. Lehr (VIA EMAIL) Assistant United States

, 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

ee 51 Southwest First Avenue Suite 1204 Miami, Florida 33130 (VIA CM/ECF and EMAIL) EFTA00595520 John G. Bianco, Esq. John M. Mulli, Esquire Tripp Scott 110 Southeast Sixth Street Fifteenth Floor Fort Lauderdale. Fl. 33301 (VIA CM/ECF and EMAIL) Michael D. Seese, Esq. Hinshaw & Culbertson, LLP