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.

st Palm Beach, FL 33409 Jack GWcx T i -,Es • Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South, Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. 1 East Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Br .acHe .LEc .b ls, Es . Fanner Jaffe Weissing Edwards Fistos Lehrman 425 N And

ung girls were also blocked because Epstein's co-conspirators (i.e., also took the Fifth on every question posed. Other important witnesses (i.e., Ghislaine Maxwell, Jean Luc Brunel) evaded depositions. 12. Because of the difficulty of obtaining discovery from Epstein and his co-conspirators, Edwards was force

osed. Other important witnesses (i.e., Ghislaine Maxwell, Jean Luc Brunel) evaded depositions. 12. Becau

question posed. Other important witnesses (i.e., Ghislaine Maxwell, Jean Luc Brunel) evaded depositions. 12

dia Levy IOM (Via U.S. Mail) William George Salim, Jr. Moskowitz Mandell & Salim (VIA CM/ECF and EMAIL) USI Attn: Anthony Gruppo (VIA EMAIL) Marc Nurik, Esq. (VIA EMAIL) BAST AMRON LLP (VIA CM/ECF and EMAIL) The Florida Bar Adria E. Quintela, Esq. Alan Anthony Pascal, Esq. Lake Shore Plaza II

shared with any non-lawyer) which communication references directly or indirectly Bradley Edwards, this pending litigation or litigation involving Ghislaine Maxwell. ANSWER: No responsive documents exist. WE HEREBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed below,

ing litigation or litigation involving Ghislaine Maxwell. ANSWER: No responsive documents exist. WE HER

this pending litigation or litigation involving Ghislaine Maxwell. ANSWER: No responsive documents exist.

ola, Esq. Searcy Denney Scarola et al. West Palm Beach, FL 33409 Jack Goldberger, Esq. Atterbur Goldber er & Weiss PA West Palm Beach, FL 33401 Marc Nurik, Esq. Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. Farmer Jaffe Weissin Edwards Fistos Lehrman Fort Lauderdale, Florida 33301 bred Haddad.

ims of his sexual molestations. 145. Phone journal taken from Epstein's home and produced to the FBI by Alfredo Rodriguez. 146. Photo depicting Ghislaine Maxwell, and Prince Andrew. 147. Al flight logs for any Epstein owned or controlled aircraft. This is so overbroad that Epstein cannot possibly make a det

edo Rodriguez. 146. Photo depicting Ghislaine Maxwell, and Prince Andrew. 147. Al flight logs for any

BI by Alfredo Rodriguez. 146. Photo depicting Ghislaine Maxwell, and Prince Andrew. 147. Al flight logs

West Palm Beach, FL 33409 Jack Goldbe er, Es . Atte ury, o erger, c Weiss, PA 250 Australian Ave. South, Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. 1 East Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Bradle . Edwards E . armer a e eissing wards Fistos Lehrman 425 N Andrews Ave

-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.

st Palm Beach, FL 33409 Jack GWcx T i -,Es • Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South, Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. 1 East Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Br .acHe .LEc .b ls, Es . Fanner Jaffe Weissing Edwards Fistos Lehrman 425 N And

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

ivilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05372 04/20/2009 Marc Nurik Bradley Edwards Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissi

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 11175-11183 04/27/2009 Marc Nurik Bradley Edwards Epstein Case info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery

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

ivilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05372 04/20/2009 Marc Nurik Bradley Edwards litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissi

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 11175-11183 04/27/2009 Marc Nurik Bradley Edwards Epstein Case info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery