Epstein Secrets

ge 2 of 2 Beth Williamson From: Tama Beth Kudman Sent: Monday. January 25,MINI To: Beth Williamson Subject: Re: Regarding: Epstein - Depo of Jean Luc Brunel I have just been informed that my client will be out of the country until the end of March. Please ask Mr Edwards to call me to discuss this. Than

bject: Re: Regarding: Epstein - Depo of Jean Luc Brunel I have just been informed that my client will be

Subject: Re: Regarding: Epstein - Depo of Jean Luc Brunel I have just been informed that my client will be

um of Law [DE 138) EXHIBIT B EFTA_R1_01464813 EFTA02406993 Case 9:08-cv-80119-KAM Document 547-2 Entered on FLSD Docket 05/17/2010 Page 2 of 2 Beth Williamson From: Tama Beth Kudman Sent: Monday. January 25,MINI To: Beth Williamson Subject: Re: Regarding: Epstein - Depo of Jean Luc Brunel I have ju

On March 10, 2010 Plaintiff filed her Motion for an Order to Show Cause and for an Order to Compel [DE 483] requesting entry of an Order directed to Jean Luc Brunel and his counsel ordering them to show cause why they should not be held in contempt, for sanctions, and for an Order compelling Jean Luc Brunel to

position. Plaintiff's counsel recently obtained Epstein's probation file that contains documents that further corroborate Plaintiff's position that Brunel has not remained out EFTA01660111 Case 9:08-cv-80119-KAM Document 547 Entered on FLSD Docket 05/17/2010 Page 2 of 4 CASE NO: 08-CV-80119-MARRA/JO

Show Cause and to Compel the Deposition of Jean Luc Brunel [DE 483]. On March 10, 2010 Plaintiff filed her

corporated Memorandum of Law fDE 138) EXHIBIT B EFTA01660119 Case 9:08-cv-80119-KAM Document 547-2 Entered on FLSD Docket 05/17/2010 Page 2 of 2 Beth Williamson From: Tama Beth Kudman [FIIIII I] Sent: Monday, January 25, To: Beth Williamson Subject: Re: Regarding: Epstein - Depo of Jean Luc Brunel I

rine W. Ezell Bradley J. Edwards Deposition of Bill Riley Joint-privilege 03943-03945 09/18/2009 Adam Horowitz Jacquie Johnson Deposition of Jean Luc Bruhnel Joint-privilege 02911-02912 09/15/2009 Bradley J. Edwards Jack P. Hill Igor Zinoview depo Joint-privilege 02939 07/14/2009 Bradley J. Ed

n Katherine Ezell RE:Deposition of Jean Luc Bruhnel Joint W/P Priv. 15501.15555 09/18/2009 Jacquie

levant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 25738 08/03/2009 William Berger Beth Williamson Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evid

n Katherine Ezell RE:Deposition of Jean Luc Bruhnel Joint W/P Priv. 15501.15555 09/18/2009 Jacquie

levant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 25738 08/03/2009 William Berger Beth Williamson Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evid

calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03672-03673 06/26/2009 Wayne Black Bradley Edwards Brunel information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible eviden

irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02548-02553 08/03/2009 Beth Williamson Bradley Edwards Federal Subpoena Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery o

calculated to lead to the discovery of the admissible evidence; protected by privacy rights 03672-03673 06/26/2009 Wayne Black Bradley Edwards Brunel information Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible eviden

irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02548-02553 08/03/2009 Beth Williamson Bradley Edwards Federal Subpoena Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery o