Epstein Secrets

-80591,09-80656,09-80802,09-81092 ------------------'/ MOTION FOR PROTECTIVE ORDER AS TO THE DEPOSITION OF NADIA MARCINKOV A Third-Party Witness, NADIA MARCINKOV A, by and through her undersigned attorney, Jack A. Goldberger, and pursuant to Fed. R. Civ. P. 26(c), moves for a Protective Order to rescheduled he

, via email and telephone on February 24 and February 25, 2010 detailing the circumstances surrounding the need to reschedule the deposition of Ms. Marcinkova, providing additional available dates wherein both the undersigned and Ms. Marcinkova will be available. Case 9:08-cv-80119-KAM Document 475

0, to another date to be agreed upon by all interested parties. Isl Jack A. Goldberger Jack A. Goldberger, Esq. Attorney for Third-Party Witness, Nadia Marc ink ova Certificate of Service I HEREBY CERTIFY that the foregoing document is being served this day on all counsel of record identified on th

& Coleman, LLP 303 Banyan Blvd. Suite 400 561-842-2820 561-844-6929 West Palm Beach, FL 33401 Counsel for Defendant, Jeffrey Epstein Farmer , Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Phone: 954-524-2820 Fax: 954-524-2822 brad@pa

0119-KAM Document 510 Entered on FLSD Docket 03/29/2010 Page 4 of 8 RICO Case Statement" to argue that the FBI's files related Sarah Kellen and Nadia Marcinkova should be produced because of their "involvement in the scheme." See DE #486 at 2. 14. As Jane Doe's RICO claim was dismissed with prejudice, any

at the FBI's files related Sarah Kellen and Nadia Marcinkova should be produced because of their "involvement

gue that the FBI's files related Sarah Kellen and Nadia Marcinkova should be produced because of their "

Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 [email protected] Counsel for Defendant Jeffrey Epstein Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Ave. Suite #2 Fort Lauderdale, FL 33301 Phone: 954-524-2820 Fax: 954-524-2822 Brad@pat

pstein's co-conspirators are Sarah Kellen, Nadia Marcinkova, and Adrianna Mucinska. Extensive investigation d

frey Epstein's co-conspirators are Sarah Kellen, Nadia Marcinkova, and Adrianna Mucinska. Extensive inve

did not break his schedule for Alan Dershowitz, meaning he continued to sexually abuse minors despite Alan Dershowitz being a guest in the house? Nadia Marcinkova Depo. at 56:22-25; 57:1-25, 58: 1-10, Jane Doe'. Epstein, No. 9:08-cv- 80893-1CAM (April 13, 2010) (excerpts attached as Exhibit 22). And Adrianna Mucinsk

Farmer, Jaffe, Weissing, Edwards, Fistos £t Lehrman, P.L. 'Ovid Pam ftoisl pet WWW.PATITTOJUSTKE.COM 425 North Andrews Avenue • Suite 2 Fort Lauderdale, Flori

s to entice or induce them into going to his mansion for sexual abuse. Epstein also made E.W. perform oral sex on him and was to perform sex acts on Nadia Marcinkova (Epstein's live- in sex slave) in Epstein's presence. See Plaintiff Jane Doe's Notice Regarding Evidence of Similar Acts of Sexual Assault, filed in

was removing herself from the massage table. [A.H.] asked for a sheet of paper and drew the massage table in the master bathroom and where Epstein, Marcinkova and she were. Epstein turned [A.H.] on to her stomach on the massage bed and inserted his penis into her vagina. [A.H.] stated Epstein began to pum

rm oral sex on him and was to perform sex acts on Nadia Marcinkova (Epstein's live- in sex slave) in Epst

FL 33401 Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Gary M. Farmer, Jr. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 38 EFTA00081219

/24/2009 Bradley Edwards Spencer Kuvin Seeking Computers Joint W/P Priv. 05350 08/10/2009 Kikka Claudio Bradley Edwards Current address for Marcinkova Joint W/P Priv. 05353.05354 09/09/2009 Katherine Ezell Bradley Edwards Distribution of Costs Joint W/P Priv. 05367 09/10/2009 Jacquie Johnso

Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 08076.08089 08/04/2009 Bradley Edwards Spencer Kuvin Transcri

V: Yeah, yeah, there was. There was pictures of Nadia Bjoumik , pictures Sarah Keller, pictures Emmy,

, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 EFTA01657683 West Palm Beach, FL 33401 Attorneys for Jeffrey Epstein Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 FPax ho:nli Attorneys for Jeffrey Epstein Jos

about to return to Teterboro, NJ. After the conversation with , Mr. M in became concerned that the FBI would try to serve his traveling companion, Marcinkova, with a similar grand jury subpoena. In fact, the agents were 9 EFTA00188874 Case 9:08-cv-807211/8la.13413gsS 2 BOACVeril giAla im)ocisstg21/pgn

d on FLSD U. 01/21/2015 Page 2 of 9 P ORAS Tam C leis Action Pe winal Injury Wconglul Otell Comer cal Lotqatton WWW.PATHTOJUSTICE COM Farmer, Jaffe, Weissing, Edwards, Fistos Et Lehrman, P.L. August 20, 2014 Wifredo A. Ferrer United States Attorney Southern District of Florida RE: Jane Doe

/L ase No • 1-05-000368 (Continued) . gaMMPrefused to perform that act. Epstein offered her an ad itional $200.00 for her to perform oral sex on Marcinkova for five minutes. .agreed to perform the oral sex for the additional $200.00. OMMIe explained that Epstein would masturbate while he watched them

United States, Case No. 08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 Fax: (954) 524-2822 E

ls to entice or induce them into paing to his mansion for sexual abuse. Epstein also made E.W. perform oral sex on him and was to periiom sex acts on Nadia Marcinkova (Epstein's live-in sex slave) in Epstein’s presence. See Plaintiff Jane Doe’s Notice Regarding Evidence of Similar Acts of Sexual Assault, filed in J

was removing herself from the massage table. [A.H.] asked for a sheet of paper and drew the massage table in the master bathroom and where Epstein, Marcinkova and she were. Epstein turned [A.H.] on to her stomach on the massage bed and inserted his penis into her vagina. [A.H.] stated Epstein began to pum

information in discovery. For example, I was given reason to believe that Sarah Kellen, Larry Visoski, Larry Harrison, David Rogers, Louella Rabuyo, Nadia Marcinkova, Ghislaine Maxwell, Mark Epstein, and Janusz Banasiak all had lawyers paid for by Epstein. Because Epstein and the co-conspirators in his c