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as an Exhibit by Plaintiff's counsel at Detective Recarey's deposition as well as certain message pads Pla
t marked as an Exhibit by Plaintiff's counsel at Detective Recarey's deposition as well as certain message pads Pla
is already in hand? Sic also Exhibits "D-1" and "D-2" and "E," a copy of the 89-page incident report marked as an Exhibit by Plaintiff's counsel at Detective Recarey's deposition as well as certain message pads Plaintiff claims was pulled from the residence at 358 Brillo Way. EFTA00317225 Case 9:08-cv-80119-KAM
ld this court order production of same after an in camera inspection) must be redacted to secure the names of unsuspecting third-parties. Moreover, Michael Fisten (formerly an employee of RRA and now an employee/independent contractor of Mr. Edwards' firm) acted, upon information and belief, as a broker or mid
rt marked as an Exhibit by Plaintiffs counsel at Detective Recarey's deposition as well as certain message pads Pla
y in hand? See also Exhibits "D-1" and "D-2" and "E," a copy of the 89-page incident report marked as an Exhibit by Plaintiffs counsel at Detective Recarey's deposition as well as certain message pads Plaintiff claims was pulled from the residence at 358 Brillo Way. Case 9:08-cv-80119-KAM Document
ld this court order production of same after an in camera inspection) must be redacted to secure the names of unsuspecting third-parties. Moreover, Michael Fisten (formerly an employee of RRA and now an employee/independent contractor of Mr. Edwards' firm) acted, upon information and belief, as a broker or mid
rence 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 (Deposed by Edwards) Claims he had list of na
USER DEPO Michael Szafranski Jim McCay Larry Yogel Alan Weinstein, investment broker FROM BRADLEY EDWARDS DEPO Maria Kelljian Beth Williamson Michael Fisten Dean Howell Paul Cassell Ken Jenne Bill Berger Richard Fandry Jane Muskrat Michelle Daryan Chislaine Maxwell Paralegal Paralegal Investiga
Elizabeth Friedland Michael Legomaro Ken Jenne Mike Fisten Saudi Prince Bill Clinton Naomi Campbell Ted Waite Composed of Roberts, Fandrey, Fisten and Jenne APRILL MEMO DATED FEBRUARY 10, 2011 Convinced several investors to invest in Rothstein Hampton Capital in New York - invested in Razorba
riety of Edwards' actions. 10. Detective Joseph Recarey Palm Beach Police Department 345 South County R
being prosecuted by Edwards at the time, including on the issue of punitive damages. Will confirm the propriety of Edwards' actions. 10. Detective Joseph Recarey Palm Beach Police Department 345 South County Road Palm Beach, FL 33480 2-3 Expected to testify about the malicious prosecution elements of absen
erg, Esq. PODHURST ORSECK, PA 25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 83. David Co field (David Seth Kokin) LAS VEGAS, NV 89135 84. 85 Michael Fisten Weston, FL 86 Russell Adler Delray Beach, FL 87. Marie Alessi BOYTON BEACH, FL 33472 88. Janusz Banasiak 358 EL BRILLO WAY PALM BEACH FL,
10 tilde Phan( 9 11 ind 10 12 TARA A. MORGAN. ESQUIRE. TARA A. P124141GAN. PA 11 13 224 Datum SEM 12 DEPOSITION OF SAW 900 DETECTIVE JOSEPH RECAREY 14 West ids 33401 13 Plan. 14 15 Tuesday, April 27, 2010 1003 - 5:23 p.m. Is 16 17 Oo bd./gelthe De /W. Setiney Epsiesn: MEI IAN PIKE.
ory on any tape recording of this statement on 12 Q. This is page 20 of E:dtibit I, which is 12 January 9th with Ms. M., were you? 13 Detective Reearey's — 13 A. A tape recording? 14 MR. PIKE: If you would, could you please turn 14 Q. Yes. 15 to that page because there's some writing on this
stigation? 11 A. Not that I'm aware of. 12 Q. Did he ever tell you that he had any 13 communications with Mr. Jenne, or Mr. Fandrey or 14 Mr. Fisten? 15 A. Not that fin aware of. 16 Q. And have you ever seen any note, report, 17 document, memorandum, e-mail or log entry in the Palm 18 Beac
Haddad. P.A. • 315 SE 7th Street, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00799415 Counsel for Epstein then examines Edwards regarding Officer Recarey: Q: What was the purpose of your conversation? Transcript of Deposition dated March 23, 2010, page 288; line 13-14. MR. SCAROLA: To the extent tha
sition dated March 23, 2010 at page169; line 19-21. A: If you want an exclusive list, I don't know. Id. at page 169; line 22. Q: Did you direct Mr. Fisten to do investigations in California? Id. at page 170; line 8-9. A: I directed Mr. Fisten to interview people and ultimately it was learned that they
(Duces Tecum) 04/23/10 Spectrum Reporting, LLC 333 E. Stewart Avenue Columbus, OH Noticed by Mermelstein Cross by • All Cases Detective Recarey (Duces Tecum) 04/27/10 Prose Court Rep 250 S. Australian Ave, Suite 1500, WPB Notice by Jess * Agreed Upon / Scheduled Have service ** EF
10 Veritext Corp. Noticed by Custodian — New York 10:30 a.m. 1250 Broadway, Suite 2400 Mermelstein Strategy Group NY, NY 10001 Epstein v. Michael Fisten 4/19/10 101 Business Noticed by Jess RRA 10:00 a.m. Center, 101 NE Third Ave., #1500 Ft. Lauderdale, FL Epstein v. Richard Fandry 4/19/10
(Duces Tecum) 04/23/10 Spectrum Reporting, LLC 333 E. Stewart Avenue Columbus, OH Noticed by Mermelstein Cross by • All Cases Detective Recarey (Duces Tecum) 04/27/10 Prose Court Rep 250 S. Australian Ave, Suite 1500, WPB Notice by Jess * Agreed Upon / Scheduled Have service ** EF
10 Veritext Corp. Noticed by Custodian — New York 10:30 a.m. 1250 Broadway, Suite 2400 Mermelstein Strategy Group NY, NY 10001 Epstein v. Michael Fisten 4/19/10 101 Business Noticed by Jess RRA 10:00 a.m. Center, 101 NE Third Ave., #1500 Ft. Lauderdale, FL Epstein v. Richard Fandry 4/19/10
s is protected by a privilege. I instruct him not to answer. Id. at page 287; line 3-6. Counsel for Epstein then examines Edwards regarding Officer Recarey: Q: What was the purpose of your conversation? Transcript of Deposition dated 14 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301
sition dated March 23, 2010 at page169; line 19-21. A: If you want an exclusive list, I don't know. Id. at page 169; line 22. Q: Did you direct Mr. Fisten to do investigations in California? Id. at page 170; line 8-9. A: I directed Mr. Fisten to interview people and ultimately it was learned that they
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