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otified Defendant that he intended to take the depositions of and was subpoenaing: (i) Donald Trump (real-estate magnate and business mogul); (ii) Les Wexner (founder of the Limited Clothing Line, Victoria Secret etc...) and his wife Abigal Wexner; (iii) Alan Dershowitz (noted constitutional attorney and
eal-estate magnate and business mogul); (ii) Les Wexner (founder of the Limited Clothing Line, Victoria S
ts on behalf of clients in Palm Beach County, Florida. (RRA is currently a debtor in bankruptcy. RRA is not named as a Defendant). 17. Defendant, E.W. ("E.W."), is an individual residing in County, Florida. At all times relevant hereto, E.W. was represented by RRA, ROTHSTEIN and the Litigation
bs, including Cheetah (7°) which RRA represented and ROTHSTEIN may have owned an interest; EFTA00725339 j) Epstein v. RRA, et al. Page 22 and E.W. also worked at Platinum Showgirls in Boynton Beach, which was the subject of a recent police raid where dancers were selling prescription painkill
president Clinton, David Copperfield, and Leslie Wexner as an inducement to get Mr. Epstein to settle hi
th Mr. Rothstein or anyone on his behalf the value of taking the depositions of Trump, Dershowitz, former president Clinton, David Copperfield, and Leslie Wexner as an inducement to get Mr. Epstein to settle his lawsuits? Transcript of Deposition dated March 23, 2010, page 284; line 18-23. MR. SCAROLA: Beyo
AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o
reet, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00799405 lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., has Mr. Howell participated in the case; that is, has he done work on the case? Id. at page 90; lines 20-23. A: Yes. Id. at page 90; line 24. Q:
th. 18 A Fifth. 18 Q Have you ever been made to engage in sex 19 Q Do you know if Jeffrey Epstein still 19 with 12-year olds? 20 talks with Leslie Wexner? 20 MR. YAREMA: Object to the form. 21 MR. YAREMA: Object to the form. 21 A Fifth. 22 A Fifth. 22 Q Is it true that Jeffrey Epstein makes
s for the purposes of hint 10 Q Do you know Les Wexner? 10 sexually abusing them? 11 A Fifth. 11 M
23 females? 24 MR. YAREMA: Object to the form. 25 A Fifth. 11 1 A I take the Fifth. 2 Q I represent a lady named, a young female 3 named E.W.; you know who that is, right? 4 Ma. YAREMA: Object to the form. S A The Fifth. 6 Q Jeffrey Epstein made you have sex with 7 E.W., didn't he?
ow Ghislaine Maxwell? 18 A Fifth. 18 A Fifth. 19 Q in addition to your sexual interactions 19 Q Is that somebody who helped Jeffrey 20 with E.W., isn't it true that you have used 20 Epstein to devise the scheme to allow him access 21 strap-on dildos and vibrators on other underage 21 to
y enjoys his social life." Jeffrey Epstein: International Moneyman of Mystery; He's pals with a passel of Nobel Prize—winning scientists, CEOs like Leslie Wexner of the Limited, socialite Ghislaine Maxwell, even Donald Trump. But it wasn't until he flew Bill Clinton, Kevin Spacey, and Chris Tucker to Africa o
Nobel Prize—winning scientists, CEOs like Leslie Wexner of the Limited, socialite Ghislaine Maxwell, even
an provide explanation. See Epstein Deposition, February 17, 2010, at 11-12, 30-31 (Deposition Attachment # 7). 9. Epstein also sexually assaulted E.W., beginning when she was 14 years old and did so on numerous occasions. See E.W. Depo., Attachment #4 at 215-216. 10. Another of the minor girls Ep
did not notify E.W. and L.M. that a plea agreement had already been reached that would block federal prosecution of Epstein. Nor did the FBI notify E.W. and L.M. of any of the parts of the plea agreement. Nor did the FBI or other federal authorities confer with E.W. and L.M. about the plea. See id.
th Mr. Rothstein or anyone on his behalf the value of taking the depositions of Trump, Dershowitz, former president Clinton, David Copperfield, and Leslie Wexner as an inducement to get Mr. Epstein to settle his lawsuits? Transcript of Deposition dated March 23, 2010, page 284; line 18-23. MR. SCAROLA: Beyo
president Clinton, David Copperfield, and Leslie Wexner as an inducement to get Mr. Epstein to settle hi
AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o
Attorney-Client and work-product privileges. Id. at page 89; lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., 3 It is significant to note that other jurisdictions have sanctioned counsel for just this behavior during deposition. See e.g. Van Pilsum v. Iow
iscovery of the admissible evidence; protected by privacy rights 11105-11110 09/09/2009 Jacquie Johnson Bradley Edwards Disseminate letter from Wexner attorney Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence
ed to lead to the discovery of the admissible evidence; protected by privacy rights 11568 10/07/2009 Paul Cassell Bradley Edwards Meeting with Leslie Wexner Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protect
ed to lead to the discovery of the admissible evidence; protected by privacy rights 07025-07027 10/29/2009 Bradley Edwards Paul Cassell ■. and E.W. v. Epstein — Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evide
on the specifics of her counsel to you about these individuals. BY MR. SIMPSON: Q. Is one of the other -- one of the powerful business executives, Les Wexner? MS. McCAWLEY: Again, same instruction. BY MR. SIMPSON: Q. Okay. Now, you mentioned yesterday -- well, a moment ago, you testified that these -- i
r -- one of the powerful business executives, Les Wexner? MS. McCAWLEY: Again, same instruction. BY MR.
. yesterday. That was the Jane Doe case in Federal Court in front of Judge Marra. There were two state claims. I'll -- I'll identify the clients as E.W. and L.M. Q. And then the fourth one? A. The fourth one, I believe -- the initial M. ESQUIRE DEPOSITION SOLUTIONS (954) 331-4400 261 and I believe
$1 billion or greater. It has been estimated he has roughly 15 clients, but their identities are the Subject of only speculation. All except for one: Leslie Wexner, founder of The Limited retail chain and a former Palm Beacher who is said to have been a mentor to Epstein. Wexner sold Epstein one of his most lavi
ation. All except for one: Leslie Wexner, founder of The Limited retail chain and a former Palm Beacher who is said to have been a mentor to Epstein. Wexner sold Epstein one of his most lavish residences: a massive townhouse that dominates a block on Manhattan’s Upper East Side. It is reported to have, am
h to do so today. "It.is against public policy for these documents to be have been sealed and hidden from public scrutiny. As a member of the public, E.W. has a right to have these documents unsealed," wrote former CircuitJudge Bill Berger, now in private practice-and representing one ofthe women. The P
Entities connected to both Les Wexner and E.W.

Jeffrey Epstein
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Bill Clinton
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
U.S. Virgin Islands
LOCATION
George W. Bush
PERSONDarren Indyke
PERSONLeon Black
PERSONJane Doe
PERSON
Bear Stearns
ORGANIZATION
New York
LOCATION
Marc Rich
PERSONMaria Farmer
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
Mort Zuckerman
PERSONScott Rothstein
PERSON