Epstein Secrets

z; c. David Copperfield; d. Kevin Spacey; e. Chris Tucker; f. Prince Andrew; g. Jean-Luc Brunel; h. Tommy Motolla; i. Bill Richardson; j. Donald Trump. 18. Any and all documents referring or relating to Jeffrey Epstein utilized for the specific purpose of soliciting Investors into the Rothstein P

Tommy Motolla; i. Bill Richardson; j. Donald Trump. 18. Any and all documents referring or relatin

l; h. Tommy Motolla; i. Bill Richardson; j. Donald Trump. 18. Any and all documents referring or r

tative of RRA and any Investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 3. All e-mails, data, correspondence, memos, or similar documents between Scott W. Rothstein, and/or an

e. David Copperfield; f. Kevin Spacey; g. Chris Tucker; h. Prince Andrew i. Jean-Luc Brunel; j. Tommy Motolla; k. Bill Richardson; I. Donald Trump. 7 EFTA00725174 Case 0:09-cv-61780-WJZ Document 25 Entered on FLSD Docket 12/17(2009 Page 1 of 9 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT

Tommy Motolla; k. Bill Richardson; I. Donald Trump. 7 EFTA00725174 Case 0:09-cv-61780-WJZ Docume

l; j. Tommy Motolla; k. Bill Richardson; I. Donald Trump. 7 EFTA00725174 Case 0:09-cv-61780-WJZ

ative of RRA and any investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 4. All emails, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Ro

z; c. David Copperfield; d. Kevin Spacey; e. Chris Tucker; f. Prince Andrew; g. Jean-Luc Brunel; h. Tommy Motolla; i. Bill Richardson; j. Donald Trump. 18. Any and all documents referring or relating to Jeffrey Epstein utilized for the specific purpose of soliciting Investors into the Rothstein P

Tommy Motolla; i. Bill Richardson; j. Donald Trump. 18. Any and all documents referring or relatin

l; h. Tommy Motolla; i. Bill Richardson; j. Donald Trump. 18. Any and all documents referring or r

tative of RRA and any Investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 3. All e-mails, data, correspondence, memos, or similar documents between Scott W. Rothstein, and/or an

z; c. David Copperfield; d. Kevin Spacey; e. Chris Tucker; f. Prince Andrew; g. Jean-Luc Brunel; h. Tommy Motolla; i. Bill Richardson; j. Donald Trump. 19. Any and all documents referring or relating to Jeffrey Epstein utilized for the specific purpose of soliciting Investors into the Rothstein P

Tommy Motolla; i. Bill Richardson; j. Donald Trump. 19. Any and all documents referring or relatin

l; h. Tommy Motolla; i. Bill Richardson; j. Donald Trump. 19. Any and all documents referring or r

tative of RRA and any Investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 4. All e-mails, data, correspondence, memos, or similar documents between Scott W. Rothstein, and/or an

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 attomey and one of EPSTEIN'S criminal d

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);

Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Villegas, Andrew Barnett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about the number of cases/

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);

Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Villegas, Andrew Bamett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about the number of cases/

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);

Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Villegas, Andrew Barnett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about the number of cases/

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);

l Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David an, ebbie Villegas, Andrew Barnett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about the number of cases/

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 crimin

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);

Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Vilieges, Andrew Barnett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about the number of cases/

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

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 crimin

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

Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Villegas, Andrew Bamett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about the number of cases/