Epstein Secrets

hat jurors may hear at trial: • Juan Alessi • Maria Alessi • • Janusz Banasiak • • Daniel Besse

A00040231 Page 2 • • Tracy Chappell • • Dr. Park Dietz • Eva Anderson Dubin • Glen Dubin • • Bennett Gershman • Lesley Groff • Dr. Ryan Hall • • • • Jordana Feldman • • Stephen Flatley • • Robert Hanson • • • Paul Kane • Robert Kelso • • • Gerald LaPorte • • Dr. Eli

hose on the attached service Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L

in preparation for this litigation by any party to this cause 131. Curriculum vitaes of any and all listed experts 132. Curriculum vitae of Dr. Ryan Hall 133. Any articles or publications of Dr. Ryan Hall 134. Any articles or publications of Dr. Richard Hall 135. Any articles or publications of D

BY CERTIFY that e copy of the foregoing was sent by U.S. Mail to the following addressees on this lf day of March , 2010: Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 954-524-2820 954-524-2822 - fax brad@p

sponse to Request for Admissions No. 11 was anything other than an admission, please explain why you did not admit that the history you gave to Dr. Ryan Hall at your Compulsory Medical Examination on February 5, 2010 ("CME") was completely true and accurate and describe any false or inaccurate statements

irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; 132 EFTA00602966 Privilege LoR — Dated 2-23-2011 Farmer. Jaffe. Weissing. Edwards. Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION protected by privacy rights 06118-06146 09/15/2009 Set

asonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05927 09/18/2009 Bradley Edwards Amy Swan Ryan Hall Psychiatrist Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evide

Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead 135 EFTA00310182 Privilege Log — Dated 2-23-2011 Farmer. Jaffe, Weissing, Edwards. Fistos & Lehrman BATES DATE 12 FROM DESCRIPTION OBJECTION to the discovery of the admissible evidence; protected b

asonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05927 09/18/2009 Bradley Edwards Amy Swan Ryan Hall Psychiatrist Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evide