Epstein Secrets

w; g. Jean-Luc Brunel; h. Tommy Motolla; i. Bill Richardson; j. Donald Trump. 18. Any and all documents r

. Jean-Luc Brunel; h. Tommy Motolla; i. Bill Richardson; j. Donald Trump. 18. Any and all documents r

tative of RRA and 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 an

. Jean-Luc Brunel; j. Tommy Motolla; k. Bill Richardson; I. Donald Trump. 7 EFTA00725174 Case 0:09-

on; d. Alan Dershowitz; e. David Copperfield; f. Kevin Spacey; g. Chris Tucker; h. Prince Andrew i. Jean-Luc Brunel; j. Tommy Motolla; k. Bill Richardson; I. Donald Trump. 7 EFTA00725174 Case 0:09-cv-61780-WJZ Document 25 Entered on FLSD Docket 12/17(2009 Page 1 of 9 UNITED STATES DISTRICT COURT

ative of RRA and 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 emails, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Ro

w; g. Jean-Luc Brunel; h. Tommy Motolla; i. Bill Richardson; j. Donald Trump. 18. Any and all documents r

. Jean-Luc Brunel; h. Tommy Motolla; i. Bill Richardson; j. Donald Trump. 18. Any and all documents r

tative of RRA and 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 an

w; g. Jean-Luc Brunel; h. Tommy Motolla; i. Bill Richardson; j. Donald Trump. 19. Any and all documents r

. Jean-Luc Brunel; h. Tommy Motolla; i. Bill Richardson; j. Donald Trump. 19. Any and all documents r

tative of RRA and 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 an

t matters, E.W. and L.M., and listed additional high profile witnesses that would allegedly be called at trial, including, but not limited to: (i) Bill Richardson (Governor of New Mexico, formerly U.S. Representative and Ambassador to the United Nations); and (ii) Any and all persons having knowledge of EPSTE

t trial, including, but not limited to: (i) Bill Richardson (Governor of New Mexico, formerly U.S. Represent

Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Villegas, Andrew Barnett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about the number of cases/

t matters, E.W. and L.M., and listed additional high profile witnesses that would allegedly be called at trial, including, but not limited to: (1) Bill Richardson (Governor of New Mexico, formerly U.S. Representative and Ambassador to the United Nations); and (ii) Any and all persons having knowledge of EPSTE

t trial, including, but not limited to: (1) Bill Richardson (Governor of New Mexico, formerly U.S. Represent

Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Villegas, Andrew Bamett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about the number of cases/

ate court matters, and.., and listed additional high profile witnesses that would allegedly be called at trial, including, but not limited to: (i) Bill Richardson (Governor of New Mexico, formerly U.S. Representative and Ambassador to the United Nations); and (ii) Any and all persons having knowledge of EPSTE

t trial, including, but not limited to: (i) Bill Richardson (Governor of New Mexico, formerly U.S. Represent

Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Villegas, Andrew Barnett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about the number of cases/

t matters, E.W. and L.M., and listed additional high profile witnesses that would allegedly be called at trial, including, but not limited to: (i) Bill Richardson (Governor of New Mexico, formerly U.S. Representative and Ambassador to the United Nations); and (ii) Any and all persons having knowledge of EPSTE

t trial, including, but not limited to: (i) Bill Richardson (Governor of New Mexico, formerly U.S. Represent

l Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David an, ebbie Villegas, Andrew Barnett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about the number of cases/

urt matters, E.W. and ■., and listed additional high profile witnesses that would allegedly be called at trial, including, but not limited to: (i) Bill Richardson (Governor of New Mexico, formerly U.S. Representative and Ambassador to the United Nations); and (ii) Any and all persons having knowledge of EPST

trial, including, but not limited to: (i) Bill Richardson (Governor of New Mexico, formerly U.S. Represen

Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Vilieges, Andrew Barnett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about the number of cases/

t trial, including, but not limited to: (i) Bill Richardson (Governor of New Mexico, formerly U.S. Represent

t matters, E.W. and L.M., and listed additional high profile witnesses that would allegedly be called at trial, including, but not limited to: (i) Bill Richardson (Governor of New Mexico, formerly U.S. Representative and Ambassador to the United Nations); and (ii) Any and all persons having knowledge of EPSTE

Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Villegas, Andrew Bamett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about the number of cases/