Epstein Secrets

to lead to the discovery of admissible evidence. See Edwards Affidavit, Exhibit "N" at 117. 75. Epstein also takes issue with Edwards identifying Bill Richardson as a possible witness. Richardson was properly identified as a possible witness because Epstein's personal pilot testified to Richardson joining Ep

evidence. See Edwards Affidavit, Exhibit "N" at 117. 75. Epstein also takes issue with Edwards identifying Bill Richardson as a possible witness. Richardson was properly identified as a possible witness because Epstein's personal pilot testified to Richardson joining Epstein at Epstein's New Mexico Ranch

q. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Gary M. Farmer, Jr. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 38 EFTA00726036

8 EFTA00605132 Case 1:15-cv-07433-RWS Document 228 Filed 06/20/16 Page 22 of 29 for example, witnesses and but added Senators George Mitchell, Bill Richardson and Les Wexner. Then between March 11 and June 1, a few weeks before the discovery cut-off, Plaintiff added 20 more witnesses, including As to sev

s and but added Senators George Mitchell, Bill Richardson and Les Wexner. Then between March 11 and June 1

0 [email protected] Ft. Lauderdale, FL 33301 [email protected] [email protected] Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, 425 North Andrews Ave., Ste. 2 Ft. Lauderdale, FL 33301 [email protected] J. Stanley Pottinger 49 Twin Lakes Rd. South Salem, NY 10590 S

to lead to the discovery of admissible evidence. See Edwards Affidavit, Exhibit "N" at ¶17. 75. Epstein also takes issue with Edwards identifying Bill Richardson as a possible witness. Richardson was properly identified as a possible witness because Epstein's personal pilot testified to Richardson joining Ep

evidence. See Edwards Affidavit, Exhibit "N" at ¶17. 75. Epstein also takes issue with Edwards identifying Bill Richardson as a possible witness. Richardson was properly identified as a possible witness because Epstein's personal pilot testified to Richardson joining Epstein at Epstein's New Mexico Ranch

q. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Gary M. Farmer, Jr. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 38 EFTA00081219

evidence. See Edwards Affidavit, Exhibit "N" at 117. 75. Epstein also takes issue with Edwards identifying Bill Richardson as a possible witness. Richardson was properly identified as a possible witness because Epstein's personal pilot testified to Richardson joining Epstein at Epstein's New Mexico Ranch

to lead to the discovery of admissible evidence. See Edwards Affidavit, Exhibit "N" at 117. 75. Epstein also takes issue with Edwards identifying Bill Richardson as a possible witness. Richardson was properly identified as a possible witness because Epstein's personal pilot testified to Richardson joining Ep

the motion that would help gamer your support. Thanks in advance for considering this request. Very truly yours, FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. Bradley J. Edwards BJE::mwk Enclosure Farmer, Jaffe, Weissing, Edwards, Fistos ft Lehrman, P.L. EFTA00188812 Case 9:08-cv-80736-KAM .doc

sis to deny the pending pro hac vice motion. See Richardson-Merrell, Inc. v. Koller, 472 U.S. 424, 441 (1985)

reet Salt Lake City, Utah 84112 (801) 858-5202 [email protected] Bradley J. Edwards (Seeking Pro Hac Vice) FARMER, JAFFE,WEISSING, EDWARDS, FISTOS & LEHRMAN, ■. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 (954) 524-2820 Email: brad @pathtojustice.com 9 EFTA00600144 Case 1:15-cv-074

ure. Consequently, their motion should be denied. III. THE REQUESTED DEPOSITIONS, WHICH INCLUDE DEPOSITIONS OF FBI SPECIAL AGENTS KUYRICENDALL AND RICHARDS, SHOULD NOT BE PERMITTED Petitioners seek to depose four federal prosecutors (including two former United Sates Attorneys) and FBI Special Agents

08-80736-CIV-MARRA/JOHNSON United States District Court, Southern District of Florida Bradley J. Edwards, Esq., Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, ■. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 (954) 524-2820 10 EFTA00618031 Case 9:08-cv-80736-KAM Document 359 Entere

y of evidence, guidelines calculations." The Government is asserting attorney-client privilege regarding this e-mail. I understand the reference to "Richards' and "Kuyrkendall" to be references to FBI agents — not attorneys in the U.S. Attorney's Office. Accordingly, the attorney-client privilege would n

uce any such burden. DATED: October 3. 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Florida Bar No.: 542075

IMPSON, ESQ. [email protected] BY: NICOLE A. RICHARDSON, ESQ. [email protected] INDEX Examinatio

REYES Utah Attorney General By: JONI J. JONES JOEL A. FERRE Assistant Utah Attorneys General Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 E-mail: brad@pathtojusti