Epstein Secrets

gned counsel and pursuant to Rule 1.380 of the Florida Rules of Civil Procedure, hereby moves this Court to enter an order compelling the Defendant Bradley Edwards, yet again, to provide responses to Plaintiff's Request for Production. Plaintiff likewise requests that this Court order sanctions against Defenda

» that > some >> of the items to which you are objecting, for example, are electronic >> communications to/from government entities which, as Mr. Edwards is >> likely aware from his days as a government attorney, are legally a >> matter of > public >> record, will not, in fact, be privileged under

ward Blvd., Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. Fernier, Jaffe, Weissing, Edwards, Fistos & Lehr

ing but not limited to, Scott Rothstein, Russell Adler, Williaria Berger, Michael Fisten, Ken Jenne, David Boden, Deborah Villegas, Andrew Barnett, Patrick Roberts, Richard Fandry, Christina Kittennan, Gary Farmer and Bradley Edwards, on the one hand, and any of the following regarding Jeffrey Epstein: 2 EFT

, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell A

frey Epstein; e. Payments made by RRA to or on behalf of any Plaintiff. 2. All e-mails, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell Adler and/or any attorney or representative of RRA and any Investor or third party (person or entity

nd any Investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 3. All e-mails, data, correspondence, memos, or similar documents between Scott W. Rothstein, and/or any attorney or rep

IDA JEFFREY EPSTEIN Complex Litigation, Ha. R. Civ. Pro.1201 Plaintiff, v. Case No. 50 2009CA040800,OOO(MB AG SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. gPSTEIN'S REQUEST TO PRODUCE TO EDWARDS Defendant, JEFFREY EPSTEIN ('Epstein'), pursuant to Fl

,OOO(MB AG SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. gPSTEIN'S REQUEST TO PRODUCE TO EDWARDS Defendant, JEFFREY EPSTEIN ('Epstein'), pursuant to Fla. R. Civ. P. 1.350, requests that Defendant, BRADLEY J. EDWARDS (*Edwards"), produce or make

d any investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (Including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 4. All emalls, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, and/or a

, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell A

frey Epstein; e. Payments made by RRA to or on behalf of any Plaintiff. 2. All e-mails, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell Adler and/or any attorney or representative of RRA and any Investor or third party (person or entity

nd any Investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 3. All e-mails, data, correspondence, memos, or similar documents between Scott W. Rothstein, and/or any attorney or rep

JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro.1201 Plaintiff, v. Case No. 50 2009 CA 040800XXXXMB AG SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants. SUBPOENA DUCES TECUM FOR DEPOSITION THE STATE OF FLORIDA: TO: YOU ARE COMMANDED to appear before a person authorized

ch might otherwise be construed to be outside its scope. 5. "Epstein" refers to Jeffrey Epstein, the Plaintiff in the captioned lawsuit. 6. 7. "Edwards" means Bradley J. Edwards, a defendant in the captioned lawsuit. 8. "Rothstein" means Scott W. Rothstein, a defendant in the captioned lawsuit. 3

ents or other representatives of or persons purporting to be affiliated with RRA, including without limitation, Mike Fisten, Ken Jenne, Wayne Black, Patrick Roberts, Patrick Diaz, Rick Fandry, Cara Holmes, William Berger, Russell Adler and Mark Nurik, or any other representatives of or persons purporting to be

Lippman Andrew Barnett Robert Buschel FROM LEON BRAUSER 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 Dary

s 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 names and addresses of females who may have come to Mr. Epstein's house along with phone numbers. Billionaire Worked for F

in Appellate attorney from Utah Investigator, former Broward Sheriff Investigator Media rep (?) Media rep (?) -1- EFTA00600049 Michael Sanka Patrick Roberts Nesbitt Kirkendahl Jason Richards Dexter Lee Maria Villafana Mark Epstein Judge Stone Deborah Villegas Bart' Bekkadan A.J. Discala Alfredo

RIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro.120 I Plaintiff, Case No. 50 2009CA040800XXXXMB AG v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. AMENDED AND SUPPLEMENTAL MOTION OF PLAINTIFF TO OVERRULE OBJECTIONS AND COMPEL DEFENDANT EDWAR

on Friday, April 1, at 9:00 a.m., the following: EPSTEIN'S AMENDED AND SUPPLEMENTAL MOTION OF PLAINTIFF TO OVERRULE OBJECTIONS AND COMPEL DEFENDANT EDWARDS TO ANSWER QUESTIONS AND APPEAR FOR FURTHER DEPOSITION The following procedures must be noted on all specially set hearing notices in Division AG:

tographs . ...? MR. SCAROLA: Same objection [work-product, attorney-client privilege] and instruction. Id. at 199, lines 25, 1-12. Q. [regarding Patrick Roberts] Did he ever perform investigation work on any of the Epstein files? MR. SCAROLA: Same objection [work-product, attorney-client privilege] and ins

, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. NOTICE OF HEARING (Specially Set- 15 min.) PLEASE TAKE NOTICE that the undersigned has set down for hearing before the

BURNETT PA. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA00606606 Epstein v Rothstein, Edwards CASE NO. 502009CA040800XXXXMBAG Notice of Hearing PLEASE GOVERN YOURSELVES ACCORDINGLY. In accordance with the Americans With Disabilities Act of

d any investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 4. All emalls, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, and/or a

the following: a. Any Plaintiff and Bradley J. Edwards or any entity with which he has been associated;

hich he has been associated; b. Any Plaintiff and the law firm of RRA. 3. All e-mails, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell Adler and/or any attorney or representative of RRA and any Investor or third party (person or entity

nd any Investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, Patrick Roberts or Rick (Rich) Fandrey). 4. All e-mails, data, correspondence, memos, or similar documents between Scott W. Rothstein, and/or any attorney or rep

COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and •., individually, Defendants. Complex Litigation, Fla. R. Civ. Pro.1201 Case No. 50 2009CA040800XXXXMB AG NOTICE OF TAKING D

ight otherwise be construed to be outside its scope. 5. "Epstein" means the Plaintiff. 6. "Holmes" "You" or "Yours" refers to Cara Holmes. 7. "Edwards" means Defendant Bradley J. Edwards. "Rothstein" means Defendant Scott Rothstein. "RRA" or the "Firm" means Rothstein Rosenfeldt Adler, •. 5 EFTA0

2008 to the present: a. Rothstein; b. Edwards; c. Russell Adler; d. William Berger; e. Mike Fisten; f. Ken Jenne; g. Wayne Black; h. Patrick Roberts; i. Patrick Diaz 2. All written communications between you and any of the following employees, independent contractors, attorneys, partners, sha