Epstein Secrets

5-05266 07/22/2009 Adam Horowitz Spencer Kuvin Alfredo Rodriguez depo Joint W/P Priv. 24 EXHIBIT I EFTA R1 00

07/22/2009 Adam Horowitz Spencer Kuvin Alfredo Rodriguez depo Joint W/P Priv. 24 EXHIBIT I EFTA R1 00

os & Lehrman SATES DATE 12 FROM DESCRIPTION 91116010N discovery of admissible evidence; protected by privacy rights 25815-25822 06/01/2009 William Berger Bradley Edwards Depo information W/P; Attorney Client Privilege; Irrelevant and riot reasonably calculated to lead to the discovery of admissibl

At recent depositions of two witnesses, Alfredo Rodriguez and Juan Alessi, five different plaintiffs' attor

the undersigned that they coordinate their efforts in joint conference calls at least two times per month. At recent depositions of two witnesses, Alfredo Rodriguez and Juan Alessi, five different plaintiffs' attorneys questioned the witnesses for approximately six to eight hours, often repeating the same or sim

partner, Mr. Luther, had a court reporter and a videographe• present. Additionally, Mr. Hill on behalf of C.M..A., Adam Langino on behalf of B.B., William Berger on behalf of three Plaintiffs were present for the deposition. 3 EFTA01625667 Case 9:08-cv-80119-KAM Document 305 Entered on FLSD Docket 09/17/

nse and pay a $15,000 fine. (IS THAT THE SAME JOE RODRIGUEZ WHO IS REPRESENTED BY ROTHSTEIN, ROSENFELDT AND

J [email protected]] From: gmax Sent: Wed 12/9/2009 4:39:29 PM Subject: FW: <no subject> Title: FW: <no subject> As former Circuit Judge William Berger resigned Friday from the law firm at the heart of an alleged massive investment scandal, he depicted Rothstein Rosenfeldt Adler's lead partner as a