Epstein Secrets

ott Goldstein Address unknown at this time 58. Alfredo Rodriguez Address unknown at this time 59. Earleen Cote

stein Address unknown at this time 58. Alfredo Rodriguez Address unknown at this time 59. Earleen Cote

m 4855 Technology Way, Suite 630 Boca Raton, FL 33431-3351 26. Christina Fitch 5 EFTA00691740 Address unknown at this time 27. Gary Fanner Fanner, Jaffe, Weissing, Edwards Fistos & Lerhman 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 28. Denis Kleinfeld 1001 Brickell Bay D

ctive Order pursuant to Fed.R.Civ.P. 26(c). In support, Epstein states: Procedural Background 1. This court entered an order (DE 555) stating that Alfredo Rodriguez ("Rodriguez")(DE 469), must produce, to the extent in his possession, "...any and all journal, notes, diaries, and writings relating to Jeffrey Eps

her third parties or attach any portion of same to any pleadings pending the outcome of the Rule 4 Appeal. att infra A roument 3. As set forth in Rodriguez's deposition, he was an employee of Epstein. Rodriguez Deposition, Exhibit "A" at p. 12-13. Moreover, as an individual employee, Rodriguez claims

Atterbury Goldberger & Weiss, M. 250 Australian Avenue South Suite 1400 FL 33401-5012 Counsel for Defendant Jefj•ey Epstein Brad Edwards, Esq. Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Ave. Suite #2 Fort LanderdAle FT. 11301 Phone Fax: Cmailto:bedwardserra-law.com

2006, you knew or had substantial reason to believe at the time that they were wider the age of 18. 6. A document maintained by your employee, Mr. Alfredo Rodriguez, contains the names of dozens of minor girls with whom you had sexual relations and sexual interaction in West Palm Beach, New York, New Mexico, Ca

document maintained by your employee, Mr. Alfredo Rodriguez, contains the names of dozens of minor girls wit

Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659-8300 F4: (561)-835-8691 Attbrneys for Jeffrey Epstein Gaiy M. Fanner, Esq. Fanner, Jaffe, Weissing, Edwards, Fistos & Lebrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fat: (954)-524-28

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

Privilege Log — Dated 2-23-2011 Fanner. Jaffe. Weissing. Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION 9BJECTI2ti not reasonably calculated to lead to the discovery of a

home. As no one was home, a business card was left for him to return my call. We then traveled to 11349 SW 86th Lane in Miami in hopes to interview Alfredo Rodriguez, a former house man of Epstein. We did not locate them at home. I left a business card for him to return my call. We“then traveled todalaand met

EACH POLICE DEPARTMENT 'ime: 15:01:37 Page: 51 Incident Report Program: CMS301L 'ase No • 1-05-000368 (Continued) the previous houseman left. Rodriguez stated that it was his responsibility to keep the identity of the masseuses private. Mr. Epstein had a massage in the morning and one in the aftern

1 and 2 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-

t "may reasonably assure the appear- ance of [the defendant] at trial will not [necessarily] assure the safety of the com- munity." United States v. Rodriguez, 950 F.2d 85, 89 (2d Cir. 1991). [8] The Bail Reform Act sets forth the following four• factors to be considered in the release/remand analysis:

] to New Mexico" and was "inappropriate" with her. Id. She was reluctant to go into details about her experience with Mr. Epstein. Id. at 73. Ms. Fanner opposes Mr. Epstein's pretrial release because she believes other Epstein victims would "continu[e] to be victimized" and that Mr. Epstein's wealt