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

ed 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 EFTA00208198 Case

10 at 8:15 AM 04/07/2010 43 Notd Notice of Taking Deposition Video of Michael Fisten & Richard Fandry 04/13/2010 44 Reqp Request to Produce To Edwards 04/13/2010 45 Mot Motion Pursuant to F.S. 57.105 04/15/2010 46 Noh Notice of Hearing 4-19-10 at 8:45 AM 04/15/2010 47 Mfpo Motion For Prote

rd Order On Dft Bradley J Edwards Motion to Compel or Alternatively to Strike Pltf Claim For Damages Dcrow 11/04/2010 139 Ord Order On Defendant Bradley J. Edwards' Motion to Compel Complete Response to Reouest to Produce Dcrow 11/08/2010 140 Not Notice Of Propounding First Set of Expert Witness Interrogs And

Complaint 08/19/2009 97 Notd Notice of Taking Deposition Of EW C/O Brad Edwards Esq. 08/19/2009 98 Notd Notice of Taking Deposition Of LM C/O Brad Edwards Esq. 08/20/2009 99 Npnp Notice of Production Non Party None 08/20/2009 100 Nnac Notice -Name/Address Change None 08/24/2009 101 Ord Order On Mot

terrogatories 04/07/2010 42 Noh Notice of Hearing 5-11-10 at 8:15 AM 04/07/2010 43 Notd Notice of Taking Deposition Video of Michael Fisten & Richard Fandry 04/13/2010 44 Reqp Request to Produce To Edwards 04/13/2010 45 Mot Motion Pursuant to F.S. 57.105 04/15/2010 46 Noh Notice of Hearing 4-19

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, 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 Daryan Chislaine Maxwell Paralegal Paralegal Investigator Referred E.W. case against Epstein Appellate attorney from Ut

1 SE 2nd Ave. Doe) Suite #207 Gainesville, FL 32601 Doe 4/13/10 US Legal Support Noticed by a (By Video) 9:30 a.m. 444 W. Railroad Ave. Edwards, Cross by 103 (JAG) Suite 300 WPB Epstein v. Scott Rothstein 4/15/10 Prose Court Rep Noticed by us Rothstein 10:00 a.m. 250 S. Australian

stein v. Michael Fisten 4/19/10 101 Business Noticed by Jess RRA 10:00 a.m. Center, 101 NE Third Ave., #1500 Ft. Lauderdale, FL Epstein v. Richard Fandry 4/19/10 101 Business Noticed by Jess RRA 2:00 p.m. Center, 101 NE Third Ave., #1500 Ft. Lauderdale, FL Does 2-8 Richard Kahn 4/20/10 Veri

SE 2nd Ave. Doe) Suite #207 Gainesville, FL 32601 Doe 4/13/10 US Legal Support Noticed by le (By Video) 9:30 a.m. 444 W. Railroad Ave. Edwards, Cross by 103 (JAG) Suite 300 WPB Epstein v. Scott Rothstein 4/15/10 Prose Court Rep Noticed by us Rothstein 10:00 a.m. 250 S. Australian

stein v. Michael Fisten 4/19/10 101 Business Noticed by Jess RRA 10:00 a.m. Center, 101 NE Third Ave., #1500 Ft. Lauderdale, FL Epstein v. Richard Fandry 4/19/10 101 Business Noticed by Jess RRA 2:00 p.m. Center, 101 NE Third Ave., #1500 Ft. Lauderdale, FL Does 2-8 Richard Kahn 4/20/10 Veri

the 16 same. 17 BY MR. SCAROLA: 18 Q. So, even if, do you even if you talked 19 about it with Mrs. Villafana, even if your client 20 Mr. Edwards spoke with Mrs. Villafana about a 21 scheduling issue, it's your position that that is 22 what, work-product? 23 MR. SCAROLA: That's correct. W

regard to, as an investigator, 1' Fandry? r, A. That's a male? ii Q. Pardon? 18 A. That's a first name or a last name? 19 Q. Last name, Richard Fandry. 20 A. I know an investigator named Rick that did 21 work, was contracted out by RRA to do investigative 22 work. I don't know his last name b