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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 lawyers); (c) David Copperfield (illusionist); (d) Individuals who had k
investor and television personality); (b) Alan Dershowitz (a renowned Harvard Law Professor and one of Eps
tate investor and television personality); (b) Alan Dershowitz (a renowned Harvard Law Professor and
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
wards 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 lawyers); (c) David Copperfield (illusionist); (d) Individuals who had k
tate investor and television personality); Alan Dershowitz (a renowned Harvard Law Professor and one of Eps
al estate investor and television personality); Alan Dershowitz (a renowned Harvard Law Professor and
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
otified 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 defense attorneys); (iii)Bill Clinton (Former President of the
al-estate magnate and business mogul); (ii) Alan Dershowitz (noted Harvard Law professor, constitutional atto
Civil Actions. 19. Miami attorney and developer, Alan Sakowitz, was quoted in a November 2009 article
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
stice charges (Edwards attempted to coordinate 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 Fundi
al witness) Bill Clinton Former president Alan Dershowitz One of Epstein's lawyers Donald Trump Leslie W
DEPO Michael Szafranski Jim McCay Larry Yogel Alan Weinstein, investment broker FROM BRADLEY EDWARD
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
3301 125. 126. Zack Bryan Wellin' on, Florida 127. 128. Larry Morrison WELLINGTON, FL 33449 129. Story Cowles WEST PALM BEACH, FL 33401 130. Alan Dershowitz CAMBRIDGE, MA 02138 or EFTA00798055 DESCRIPTION OF WITNESSES NEW YORK, NY 10017. Subject to assertions of privilege 131. Michael Dawson Palm
tory Cowles WEST PALM BEACH, FL 33401 130. Alan Dershowitz CAMBRIDGE, MA 02138 or EFTA00798055 DESCRIPT
assertions of privilege 76. Donald Trtunp c/o Alan Garten, Esq. 725 Fifth Avenue EFTA00798051 DE
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
otified 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 defense attorneys); (iii)Bill Clinton (Former President of the
al-estate magnate and business mogul); (ii) Alan Dershowitz (noted Harvard Law professor, constitutional atto
Civil Actions. 19. Miami attorney and developer, Alan Sakowitz, was quoted in a November 2009 article
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
otified 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 defense attorneys); ill Clinton (Former President of the United
Civil Actions. 19. Miami attorney and developer, Alan Sakowitz, was quoted in a November 2009 article
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.
GER, ESQUIRE ATTERBURY, GOLDBERGER & WEISS, P.A. 10 11 12 and West Palm Beach, Florida 33401-5012 Phone: 13 On behalf of the Plaintiff: 14 ALAN M. DERSHOWITZ, ESQUIRE HARVARD LAW SCHOOL 15 Cambridge, Massachusetts 02138 16 Phone: 17 On behalf of the Defendant: 18 JACK SCAROLA, ESQUIRE SEARCY, DEN
AGENCY, INC. EFTA00599665 Page 5 Plaintiff, Jeffrey Epstein. MR. GOLDBERG: Jack Goldberger on behalf of the Plaintiff, Jeffrey Epstein. 4 MR. DERSHOWITZ: Alan Dershowitz on behalf 5 of the Plaintiff, Jeffrey Epstein, of counsel. 6 MR. SCAROLA: The record should reflect that Mr. Epstein is also pe
t Palm Beach, Florida 334O1 Phone: 7 and JACK ALAN GOLDBERGER, ESQUIRE ATTERBURY, GOLDBERGER & WEIS
9680 Page 20 1 behalf; that is, who purports to represent 2 Mr. Rothstein since you left the firm that day? 3 A. No. 4 Q. Do you know Mr. Nurik? 5 A. Yes. 6 Q. Do you recog -- are you aware that he 7 represents Mr. Rothstein? A. Yes. 9 Q. Okay. Have you spoken with him since that
King Tonja Coleman tw W. Chester Brewer Jack Alan Goldberger LONN WEISSBLUM, Clerk Fourth Distric
am B. King Tonja Coleman tw W. Chester Brewer Jack Alan Goldberger LONN WEISSBLUM, Clerk Fourth District Court of Appeal Philip M. Burlington Mark Nurik Clerk Palm Beach EFTA00592356 Fourth District Court of Appeal 1525 Palm Beach Lakes Blvd. West Palm Beach, Florida 33401 (561) 242-2000 ACKNO
each Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atter:bury, Goldberger & Weiss
data, correspondence, and similar documents dated April 1, 2008 through August 1, 2010 by and between Bradley J. Edwards. Scott W. Rothstein, Marc, Nurik, Cara Holmes, Mike Fisten and any on of he following regarding or mentioning Jeffrey Epstein in any way: (a) the U.S. Attorney's Office, (b) the St
Entities connected to both Alan Dershowitz and Mark Nurik

Jeffrey Epstein
PERSONLeon Black
PERSON
Bradley Edwards
PERSON
Marc Rich
PERSONJack Goldberger
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
George W. Bush
PERSON
United States
LOCATION
Paul Cassell
PERSONJane Doe
PERSON
Kenneth Marra
PERSON
Donald Trump
PERSON
Bill Clinton
PERSONMartin Weinberg
PERSONRobert D. Critton
PERSONMaria Farmer
PERSON
Joe Biden
PERSON
Barry Diller
PERSON
Scarlett Johansson
PERSON