Epstein Secrets

ned herein including, but not limited to, the discovery abuses and bad faith litigation tactics that Epstein has been the subject of at the hands of Scott Rothstein and his-co-conspirators, any tax returns must be redacted to preserve confidently and to prevent further abuses. See supra. Further, Epstein's com

us civil litigation abuses that resulted in profoundly serious injury to Jeffrey Epstein, including substantial attorneys' fees and costs. In short, Rothstein and his co-conspirators forged Federal court orders and opinions and, among other things, staged a series of depositions that were unrelated to any

equesting party can show need and the inability to obtain the substantial equivalent by other means without undue hardship. Vesta Fire Ins. Corp. v. Figueroa, 821 So.2d 1233, 1234 (Fla. 5th DCA 2002)(the showing of need and undue hardship necessary to overcome the work product immunity must include speci

reasonably calculated to lead to the discovery of admissible evidence. b. None. 6. All fee sharing agreements between Bradley J. Edwards, RRA, or Scott W. Rothstein and/or any other attorney or investor relating to any aspect of any Plaintiff's case. ANSWER: Objection, relevance, not reasonably calculated to l

ent to his cause of action. Moreover, discovery relating to Edwards's financial incentives to join RRA and to engage in conduct in cooperation with Rothstein in support of RRA's illicit activities is most certainly relevant to Edward's allegations in this case and Epstein's defense of the same. Accordingl

ing party can show both the need for the information and the inability to obtain the substantial equivalent by other means. Vesta Fire Ins. Corp. v. Figueroa, 821 So. 2d 1233, 1234 (Fla. 5th DCA 2002); Ashemimiy v. Ba Nafa, 847 So. 2d 603 (Fla. 5th DCA 2003). Accordingly, this production should be compel

reasonably calculated to lead to the discovery of admissible evidence. b. None. 6. All fee sharing agreements between Bradley J. Edwards, RRA, or Scott W. Rothstein and/or any other attorney or investor relating to any aspect of any Plaintiff's case. ANSWER: Objection, relevance, not reasonably calculated to l

ent to his cause of action. Moreover, discovery relating to Edwards's financial incentives to join RRA and to engage in conduct in cooperation with Rothstein in support of RRA's illicit activities is most certainly relevant to Edward's allegations in this case and Epstein's defense of the same. Accordingl

ing party can show both the need for the information and the inability to obtain the substantial equivalent by other means. Vesta Fire Ins. Corp. v. Figueroa, 821 So. 2d 1233, 1234 (Fla. 5th DCA 2002); Ashemimiy v. Ba Nafa, 847 So. 2d 603 (Fla. 5th DCA 2003). Accordingly, this production should be compel

reasonably calculated to lead to the discovery of admissible evidence. b. None. 6. All fee sharing agreements between Bradley J. Edwards, RRA, or Scott W. Rothstein and/or any other attorney or investor relating to any aspect of any Plaintiff's case. ANSWER: Objection, relevance, not reasonably calculated to l

nt to his causes of action. Moreover, discovery relating to Edwards's financial incentives to join RRA and to engage in conduct in cooperation with Rothstein in support of RRA's illicit activities is most certainly relevant to Edward's allegations in this case and Epstein's defense of the same. Accordingl

ng party can show both the need for the information and the inability to obtain the substantial equivalent by other means. Vesta Fire Ins. Corp. v. Figueroa, 821 So. 2d 1233, 1234 (Fla. 5th DCA 2002); Ashemimiy v. Ba Nafa, 847 So. 2d 603 (Fla. 5th DCA 2003). Accordingly, this production should be compel

TEIN & liOROWIT2, P.A. BY: ADAI4HORownt ESQ. 4 6 7 8 9 10 11 12 13 14 15 16 12 18 19 20 21 22 23 24 25 la y , .,„ 6, and 7. ROTHSTEIN ROSENfELOT ADLER BY: BRAD J. EDWARDS, ESQ., and PODHURST ORSECK SQ. Attorney for lane Doe 101 and 102. Palm Bead, Gardens, Florida 33410 Attorn

en 19 you came and found the old car in the driveway? 20 A. Exactly, yes, with the police, yes. 21 Q. How did you remember that it was Tony 22 Figueroa? 23 A. It's the only person, male that I 24 remember. 25 Q. But you don't know his name? 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

Florida 33410 21 Attorney for 22 23 24 25 ROTHSTEIN ROSPMFELDT ADLER BY: BRAD J. EDWARDS, ESQ., and

came and found the old car in the driveway? 19 20 A. Exactly, yes, with the police, yes. 20 21 Q. How did you remember that it was Tony 21 22 Figueroa? 22 23 A. It's the only person, male that I 23 24 remember. 24 25 Q. But you don't know his name? 25 Page 445 alrie, I guess. was to help

7.02.01 letter frame:old Went 3501.156033 2007.12.11 Letter from lay Lefkorniz 3501.156034 2009.12.)7 Palm Beach County complaint (Epstein sr. Scott Rothstei ,=M and LAI) ...M. 3501.157 Date Desolation 3501.157 001 2008.04.23 National canprehenshve moon for 3501.157 002 2008.04.30 Lserenforcemcn

ch regarding Tony Figueroa 3501476014 2007.01.06 Research regarding Tony Figueroa 3501476015 2007.01.06 National comprehensive mpan resin:m.7am Figueroa 3501.076016 2007.01.10 Fns memorandum regarding intavieerof Tony Figueroa 3501.076017 2007.01.10 Tony Figueroa Miamian notes 1501.0760113 200

teresting additional details that can be 11 used in the letter to the mail and in the following press 12 complaints. In addition, this article on Rothstein you may 13 find helpful. 14 "What is the number one lie that Ms. Maxwell points 15 to? Number 1. Bill Clinton identified in lawsuit against his

which only 3 further substantiates Ms. testimony that at one point 4 she attempted to get away from defendant's abuse, along with -- 5 and Mr. Figueroa testified to the same. 6 So again, I would also reiterate that her reputation 7 as a child for being a truant or a runaway is not what is at 8

s and interesting additional details that can be used in the letter to the mail and in the following press complaints. In addition, this article on Rothstein you may find helpful. "What is the number one lie that Ms. Maxwell points to? Number 1. Bill Clinton identified in lawsuit against his former fri

th, 2002, which only further substantiates Ms. testimony that at one point she attempted to get away from defendant's abuse, along with -- and Mr. Figueroa testified to the same. So again, I would also reiterate that her reputation as a child for being a truant or a runaway is not what is at issue in

s and interesting additional details that can be used in the letter to the mail and in the following press complaints. In addition, this article on Rothstein you may find helpful. "What is the number one lie that Ms. Maxwell points to? Number 1. Bill Clinton identified in lawsuit against his former fri

which only further substantiates Ms. Giuffre's testimony that at one point she attempted to get away from defendant's abuse, along with -- and Mr. Figueroa testified to the same. So again, I would also reiterate that her reputation as a child for being a truant or a runaway is not what is at issue in t