Epstein Secrets

407 A: I'm not going to answer based on privilege. Id. at page 142; line 25. The subject matter of the deposition turned to the subpoena served on Ghislaine Maxwell: Q: Do you, is she neither would you agree that neither Jane Doe nor L.M. have testified to any, that they had any connection whatsoever with Ghisl

nd what, what was, what is the purpose; that is, with regard to your three clients and only your three clients is they — what connection if any, did Ghislaine Maxwell have to those individuals? Id. at page 155; line 19-23. MR. SCAROLA: Objection, work-product. Instruct you to not answer. Id. at 155; line

at was, what is the purpose; that is, with regard to your three clients and only your three clients is they — what connection if any, did Ghislaine Maxwell have to those individuals? Id. at page 155; line 19-23. MR. SCAROLA: Objection, work-product. Instruct you to not answer. Id. at 155; line 24-25.

uld not respond on the basis of privilege. Id. at page 288; line 15-21. A: Privilege. Id. at page 288; line 22. Counsel for Epstein then discusses Ken Jenne: Q: Did Mr. Jenne, did you ever direct Mr. Jenne to do any investigation on the Epstein cases? Transcript of Deposition dated March 23, 2010, at pa

stions as well: Q. What connection, if any, did Ghislaine Maxwell have to [your three clients]? MR. SCAROL

uct privilege. Id. at 126-127. Edwards wrongfully claimed the work product privilege for these questions as well: Q. What connection, if any, did Ghislaine Maxwell have to [your three clients]? MR. SCAROLA: Objection, work product. Instruct you not to answer. Id. at 155.6 Q. Who did [Mike Fisten] go to Califo

by this time already put considerable allegations concerning the answer to this question into the records. Obviously, his clients' interaction with Maxwell was not intended to be kept in confidence. 7 EFTA00606632 Q. Who other than Mr. Fisten from an investigator, from an internal investigator at

ion of Jeffrey Epstein? MR. SCAROLA: Same objection [work-product, attorney-client privilege]. Id., at 201. Q. [D]id you ever authorize or direct Ken Jenne to perform any investigation on the Epstein files? MR. SCAROLA: Same objection [work-product, attorney-client privilege] and instruction. 12. Co

-23. A: I'm not going to answer based on privilege. Id. at page 142; line 25. The subject matter of the deposition turned to the subpoena served on Ghislaine Maxwell: 6 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301• EFTA00585399 Q: Do you, is she neither would you agree that neither Jane D

nd what, what was, what is the purpose; that is, with regard to your three clients and only your three clients is they — what connection if any, did Ghislaine Maxwell have to those individuals? Id. at page 155; line 19-23. MR. SCAROLA: Objection, work-product. Instruct you to not answer. Id. at 155; line

at was, what is the purpose; that is, with regard to your three clients and only your three clients is they — what connection if any, did Ghislaine Maxwell have to those individuals? Id. at page 155; line 19-23. MR. SCAROLA: Objection, work-product. Instruct you to not answer. Id. at 155; line 24-25.

uld not respond on the basis of privilege. Id. at page 288; line 15-21. A: Privilege. Id. at page 288; line 22. Counsel for Epstein then discusses Ken Jenne: Q: Did Mr. Jenne, did you ever direct Mr. Jenne to do any investigation on the Epstein cases? Transcript of Deposition dated March 23, 2010, at pa

otd Notice of Taking Deposition Ghislane Noelle Maxwell 08/07/2009 85 Notd Notice of Taking Deposition

08/07/2009 84 Notd Notice of Taking Deposition Ghislane Noelle Maxwell 08/07/2009 85 Notd Notice of Ta

Production Non Party See List 12/16/2010 158 Notd Notice of Taking Deposition Scott Rothstein 12/16/2010 159 Notd Notice of Taking Deposition Ken Jenne 12/16/2010 160 Notd Notice of Taking Deposition Gary Farmer 12/16/2010 161 Notd Notice of Taking Deposition Debra Villegas 12/16/2010 162 Notd

O Maria Kelljian Beth Williamson Michael Fisten Dean Howell Paul Cassell Ken Jenne Bill Berger Richard Fandry Jane Muskrat Michelle Daryan Chislaine Maxwell Paralegal Paralegal Investigator Referred E.W. case against Epstein Appellate attorney from Utah Investigator, former Broward Sheriff Investig

Fandry Jane Muskrat Michelle Daryan Chislaine Maxwell Paralegal Paralegal Investigator Referred E.W

arry Yogel Alan Weinstein, investment broker FROM BRADLEY EDWARDS DEPO Maria Kelljian Beth Williamson Michael Fisten Dean Howell Paul Cassell Ken Jenne Bill Berger Richard Fandry Jane Muskrat Michelle Daryan Chislaine Maxwell Paralegal Paralegal Investigator Referred E.W. case against Epstei

6107 08/11/2009 Adam Horowitz Jacquie Johnson Maxwells deposition Joint-privilege 16123-16124 08/11/20

t and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05292 07/22/2009 Attorneys at RRA Ken Jenne RE: Epstein Meeting W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; pro

and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 26716-26717 09/04/2009 Mike Fisten Ken Jenne NR as a victim W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by

6107 08/11/2009 Adam Horowitz Jacquie Johnson Maxwells deposition Joint-privilege 16123-16124 08/11/20

t and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05292 07/22/2009 Attorneys at RRA Ken Jenne RE: Epstein Meeting W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; pro

and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 26716.26717 09/04/2009 Mike Fisten Ken Jenne NR as a victim W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by

ut I am just going through the questions that refused to be answered at this time. Next it discusses the deposition of the subpoena served on Ms. Maxwell. And Mr. Edwards is asked, "Do you -- is she neither -- would you agree that neither Jane Doe nor LM" -- who are, again, Mr. Edwards' two clients

scusses the deposition of the subpoena served on Ms. Maxwell. And Mr. Edwards is asked, "Do you -- is she ne

tic) -- purpose of the conversation with this officer. No answer, yet he's listed on the witness list at this time. Then the conversation turns to Ken Jenne, former Sheriff who worked at RRA during the time in question. THE COURT: What page are you on? MS. HADDAD COLEMAN: I'm at the top of page 15. S

es Estrada Bradley Edwards Improper Serving of Maxwell Joint WI() Priv. 05105-05107 04/20/2009 Bradle

riot reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 1835818359 07/24/2009 Bradley Edwards Ken Jenne Investigation into Epstein's planes W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admis

ed to lead to the discovery of the admissible evidence; protected by privacy rights 06540-06541 09/21/2009 Bradley Edwards Mike Fisten Info on Maxwell Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protect

irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01787.01788 09/04/2009 Ken Jenne Bradley J. Edwards 1. Accountants 2. Motion for IME Work product; attorney/client privilege; irrelevant and not reasonably calculated to lea