Epstein Secrets

d; no such offer had 4 -be made. 38. EDWARDS' office also notified Defendant that he intended to take the depositions of and was subpoenaing: (i) Donald Trump (real-estate magnate and business mogul); (ii) Alan Dershowiti (noted Harvard Law professor, constitutional attorney and one of EPSTEIN'S criminal

depositions of and was subpoenaing: (i) Donald Trump (real-estate magnate and business mogul); (ii) A

ake the depositions of and was subpoenaing: (i) Donald Trump (real-estate magnate and business mogul);

consent of Defendant Scott W. Rothstein's counsel, Mark Nurik, Esq., a true and correct copy of the above and foregoing was served via email on Mr. Nurik, at [email protected]. This 3rd day of November, 2009. 'Si Fla LA M. Baia.i 9 COFFEY B URLINGTON OFFICE IN THE. GROVE, PENTHOUSE 2699 SOU I H

CERTIFICATE OF SERVICE I certify that on this 3rd day of November, 2009, with the agreement and consent of Defendant Scott W. Rothstein's counsel, Mark Nurik, Esq., a true and correct copy of the above and foregoing was served via email on Mr. Nurik, at [email protected]. This 3rd day of November, 2009.

n, Edwards Case No.: 502009CA040800XXXXMBAG Second Amended Complaint (2) Noticing and subpoenaing for deposition the following people: (3) (a) Donald Trump (a real estate investor and television personality); (b) Alan Dershowitz (a renowned Harvard Law Professor and one of Epstein's criminal defense

eposition the following people: (3) (a) Donald Trump (a real estate investor and television personali

g for deposition the following people: (3) (a) Donald Trump (a real estate investor and television per

assets to avoid paying any judgments that may be obtained by RRA clients against Epstein; g) On August 13, 2009 an email was sent from Rothstein to Mark Nurik ("Nurik"), an attorney at RRA, regarding legal research on causes of action against Epstein. On - 6 - FOWLER WHITE BURNETT P.A. • 901 PHILLIPS POI

ORIDA 33401 • (561) 802-9044 EFTA00584200 Epstein v Rothstein, Edwards Case No.: 502009CA040800XXXXMBAG Second Amended Complaint that same day, Nurik sent an email to Rothstein regarding discussions about Epstein. Also on August 13, 2009, Adler sent an email to Rothstein regarding legal research o

ORIDA 33401 • (561) 802-9044 EFTA00584222 Epstein v Rothstein, Edwards Case No.: 502009CA040800XXXXMBAG Second Amended Complaint (3) (a) (b) Donald Trump (a real estate investor and television personality); Alan Dershowitz (a renowned Harvard Law Professor and one of Epstein's criminal defense lawye

Second Amended Complaint (3) (a) (b) Donald Trump (a real estate investor and television personali

XXXMBAG Second Amended Complaint (3) (a) (b) Donald Trump (a real estate investor and television per

assets to avoid paying any judgments that may be obtained by RRA clients against Epstein; g) On August 13, 2009 an email was sent from Rothstein to Mark Nurik ("Nurik"), an attorney at RRA, regarding legal research on causes of action against Epstein. On that same day, Nurik sent an email to Rothstein reg

as sent from Rothstein to Mark Nurik ("Nurik"), an attorney at RRA, regarding legal research on causes of action against Epstein. On that same day, Nurik sent an email to Rothstein regarding discussions about Epstein. Also on August 13, 2009, Adler sent an email to Rothstein regarding legal research o

no such offer had ever been made. 38. EDWARDS' office also notified Defendant that he intended to take the depositions of and was subpoenaing: (i) Donald Trump (real-estate magnate and business mogul); (ii) Alan Dershowitz (noted Harvard Law professor, constitutional attorney and one of EPSTEIN'S criminal

depositions of and was subpoenaing: (i) Donald Trump (real-estate magnate and business mogul); (ii) A

ake the depositions of and was subpoenaing: (i) Donald Trump (real-estate magnate and business mogul);

and consent of Defendant Scott W. Rothstein's counsel, Mark Nurik E a true and correct copy of the above and foregoing was served via email on Mr. Nurik, at This 3rd day of November, 2009. s; S 9 COFFEY B URLINGTON OI+ICk IN THE DROVE. PENTHOUSE 2699 SOUTH SAYSHORE DRIVE MIAMI, FLORIDA 33 133

nate the depos of the following:) David Copperfield (potential witness) Bill Clinton Former president Alan Dershowitz One of Epstein's lawyers Donald Trump Leslie Wexner (ENTITIES FROM EDWARDS DEPO) Blue Line Research Clockwork Capital Advisors Razorback Funding Benozon Onyx Capital Onyx Options

Alan Dershowitz One of Epstein's lawyers Donald Trump Leslie Wexner (ENTITIES FROM EDWARDS DEPO) Blu

ident Alan Dershowitz One of Epstein's lawyers Donald Trump Leslie Wexner (ENTITIES FROM EDWARDS DEPO

evin Ira Sochet Mark Melvin Jack Samoney Lawrence King Steve Jackel Michael Legamaro Kevin Draber David Boden Andrew Barnett Alan Sakowitz Mark Nurik Mark Fistos Tommy Mottola Officer Recarey Interviewed by Michael Fisten Investigator FBI Agent FBI Agent US Attorney Rothstein's right arm

no such offer had ever been made. 38. EDWARDS' office also notified Defendant that he intended to take the depositions of and was subpoenaing: (i) Donald Trump (real-estate magnate and business mogul); (ii) Alan Dershowitz (noted Harvard Law professor, constitutional attorney and one of EPSTEIN'S criminal

depositions of and was subpoenaing: (i) Donald Trump (real-estate magnate and business mogul); (ii) A

ake the depositions of and was subpoenaing: (i) Donald Trump (real-estate magnate and business mogul);

d consent of Defendant Scott W. Rothstein's counsel, Mark Nurik Es , a true and correct copy of the above and foregoing was served via email on Mr. Nurik, at This 3rd day of November, 2009. M.P ICSAM 9 COFFEY B 1./RLINGTON OFFICE IN THE GROVE, PENTHOUSE 2699 SOUTH BAYSHORE DRIVE MIAMI, FLORIDA

's Order entered March 8, 2018, by the Honorable Donald Hafele, denying Epstein's Motion to Remove Case

Complaint. (App. 4). Rothstein retained counsel, Mark Nurik, who moved to set aside the default, but an order was never entered on that motion. Mr. Nurik has not withdrawn from this case and has been on the service list since 2010. On April 12, 2011, Epstein filed an Amended Complaint against Rothste

21, 2010, a Clerk's Default was entered against Rothstein as to all claims in the December 7, 2009 Complaint. (App. 4). Rothstein retained counsel, Mark Nurik, who moved to set aside the default, but an order was never entered on that motion. Mr. Nurik has not withdrawn from this case and has been on the

h 13, 2018,' and the circuit court (the Honorable Donald Hafele) has just made two rulings which warrant

Complaint. (App. 4). Rothstein retained counsel, Mark Nurik, who moved to set aside the default, but an order was never entered on that motion. Mr. Nurik has not withdrawn from this case and has been on the service list since 2010. On April 12, 2011, Epstein filed an Amended Complaint against Rothste

21, 2010, a Clerk's Default was entered against Rothstein as to all claims in the December 7, 2009 Complaint. (App. 4). Rothstein retained counsel, Mark Nurik, who moved to set aside the default, but an order was never entered on that motion. Mr. Nurik has not withdrawn from this case and has been on the

's Order entered March 8, 2018' by the Honorable Donald Hafele, granting Respondent Bradley J. Edwards'

d from this case on August 9, 2010. (App. 5). 5 EFTA00793697 all claims in the December 7, 2009 Complaint. (App. 4). Rothstein retained counsel, Mark Nurik, who moved to set aside the default, but an order was never entered on that motion. Mr. Nurik has not withdrawn from this case and has been on the

Complaint. (App. 4). Rothstein retained counsel, Mark Nurik, who moved to set aside the default, but an order was never entered on that motion. Mr. Nurik has not withdrawn from this case and has been on the service list since 2010. On April 12, 2011, Epstein filed an Amended Complaint against Rothste

f a list supplied as it related to the NPA 75. Leslie Wexner Three Limited Parkway Columbus, Ohio 43206. Subject to assertions of privilege 76. Donald Trtunp c/o Alan Garten, Esq. 725 Fifth Avenue EFTA00798051 DESCRIPTION OF WITNESSES New York, NY 10022. Subject to the assertions of privilege 77. L

o 43206. Subject to assertions of privilege 76. Donald Trtunp c/o Alan Garten, Esq. 725 Fifth Avenue

S. Ross, Gs q. 155. 156. Alfredo Rodriguez 11349 SW 86TH LN, Miami, FL C/O Federal Public Defender or Bureau of Prisons 157. Scott Rothstein do Mark Nurik One East Broward Boulevard, Suite 700 Fort Lauderdale, Florida 33301 EFTA00798057 2. Each contested factual issue expected to be addressed by th