Epstein Secrets

ched as Exhibit A). 2. Mr. Cowles was hired by Jack Goldberger, Esq., co-counsel for Mr. Epstein, on I July 16, 2008 and has been employed by Mr. Goldberger since that time. Mr. Cowl.es was hired as Mr. Goldberger's law office assistant to be directly involved only with Mr. Epstein's case while he was s

enter a protective '" order prohibiting the deposition of Story Cowles and grant any additional relief the Comi deems just and proper. 6 By: /s/ Jack Alan Goldberger Florida Bar No. 262013 Case 9:08-cv-80119-KAM Document 536 Entered on FLSD Docket 04/29/2010 Page 7 of 8 Certificate of Service I HEREBY C

5 Case 9:08-cv-80119-KAM Document 536 Entered on FLSD Docket 04/29/2010 Page 6 of 8 16. While Epstein sought to depose Mr. Fisten and Mr. Fandrey regarding their knowledge of Scott Rothstein's Ponzi scheme, the Court nevertheless entered a protective order prohibiting their depositions until

11. All conversations recorded from any telephones which purported to be from Jeffrey Epstein's attorneys including Roy Black, Alan Dershowitz or Jack Goldberger, that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives or any other electronic format and any written transcriptions).

neys including Roy Black, Alan Dershowitz or Jack Goldberger, that are contained in any media (audio tapes, C

esentative of RRA regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Henne, Patrick Roberts or Rick (Rich) Fandrey). 4. All agreements or documents of any nature which were provided to or received from an Investor or potential Investor relating to any case (rea

Court enter a protective order prohibiting the deposition of Story Cowles and grant any additional relief the Court deems just and proper. By: Is/ Jack Alan Goldberger Florida Bar No. 262013 6 EFTA00728109 Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with t

ttached as Exhibit A). 2. Mr. Cowles was hired by Jack Goldberger, Esq., co-counsel for Mr. Epstein, on July 16, 2008 and has been employed by Mr. Goldberger since that time. Mr. Cowles was hired as Mr. Goldberger's law office assistant to be directly involved only with Mr. Epstein's case while he was se

. As the Court may recall, RRA represented Jane Doe prior to its implosion. 5 EFTA00728108 16. While Epstein sought to depose Mr. Fisten and Mr. Fandrey regarding their knowledge of Scott Rothstein's Ponzi scheme, the Court nevertheless entered a protective order prohibiting their depositions until

II. All conversations recorded from any telephones which purported to be from Jeffrey Epstein's attorneys including Roy Black, Alan Dershowitz or Jack Goldberger, that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives or any other electronic format and any written transcriptions).

neys including Roy Black, Alan Dershowitz or Jack Goldberger, that are contained in any media (audio tapes, C

esentative of RRA regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Henne, Patrick Roberts or Rick (Rich) Fandrey). 4. All agreements or documents of any nature which were provided to or received from an Investor or potential Investor relating to any case (rea

m day of March, 2012 to: Jack Scarola, Esq., Searcy Denney Searc4a Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atter:bury, Goldberger & Weiss, PS, 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401-502; and Marc S. Nutik, Esq., Law Office

h Lakes Blvd. West Palm Beach, FL 33409 Jack A. Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. 250 A

on or entity) regarding Jeffrey Epstein of Which inentkins Jeffrey Epstein (including • Mike Fisten, Rermeth Jenne, Patrick Robe:KS or Ritil (Rich) Fandrey). 2. On May 11, 2010, Edwards served his response to this request by stating: 3. Objection as to communications to or from investigators as that

day of April, 2011 to : Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401-5012 2 EFTA00600002 Epstein v. Roth

Lakes Blvd. West Palm Beach, FL 33409 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Au

erger d) Bradley Edwards e) Michael Fisten f) Kenneth Jenne g) David Baden h) Deborah Villegas i) Andrew Barnett j) Patrick k) Richard (Rick) Fandrey I) Christina Kitterman 2. Any and all contracts and/or agreements, including all drafts and final versions, which were provided to you by any of t

neys including Roy Black, Alan Dershowitz or Jack Goldberger, that are contained in any media (audio tapes, C

12. All conversations recorded from any telephones which purported to be from Jeffrey Epstein's attorneys including Roy Black, Alan Dershowitz or Jack Goldberger, that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives or any other electronic format and any written transcriptions).

esentative of RRA regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Henne, Patrick Roberts or Rick (Rich) Fandrey). 5. All agreements or documents of any nature which were provided to or received from an Investor or potential Investor, as well as, their agents

n 11 Beach? 12 A. Yes. 13 Q. And ends up in this community of offices that 14 includes Mr. Epstein's office? 15 A. If his office was in Mr. Goldberger's Office, 16 the quickest route would have been on Okeechobee. 17 Q. But one of the route — you have to get off 18 the beach, right? 19 A. Co

and leaving in a 4 touch — former Chief Reiter was in touch with various 4 vehicle registered to an investigator named Richard 5 reporters? 5 Fandrey? 6 A. I don't believe so. 6 MS. ARBOUR: Form. 7 Q. Did he talk to you about having been 7 THE WITNESS: No, sir. 8 interviewed by Mr. Connol