Epstein Secrets

e 7 A. I don't understand the question. Q. For whom do you work at the current time? Are you an employee? A. I am a partner in the law firm of Farmer, 5 Jaffe, Weissing, Edwards, Fistos & Lehrman. 6 Q. Is that a professional association? 7 A. Yes. 8 Q. And you said you're a partner. Do y

I> A. Correct. 13 Q. Does the firm have any paralegals that 14 came over from the RRA firm, RRA? 15 A. Yes. 16 Q. Who are they? 11 A. Maria and Beth. 18 Q. Does Maria have a last name? 19 A. Yes. 20 Q. What is it, please? 21. A. I believe it's pronounced Kelljian. 22 Q. Can

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 50 2009CA040800XXXXMB AG Complex Litigation, Fla.R.Civ.Pro. 1201 JEFFREY EPSTEIN, Plaintiff, -vs- VOLUME I OF II SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and III. individual

lsouth.net Counsel for Defendant Jeffrey Estein Farmer , Jaffe, Weissing, Edwards, Fistos & Lehrman, PL

s and the defenses in the litigation"). W. The information simply falls under the "highly protected category of opinion work-product." Id; see also Fla.R.Civ.Pro. 1.280. Also, Counsel for Jane Does 2-8 in the Federal companion cases apparently obtained a copy of the file retained by the Palm Beach State

to assign the mortgage. Wells Fargo Bank, N.A. v. Farmer 2008 NY Slip Op 51133U (N.Y. Sup. Ct. 2008); Deu

gment hearing, defendant objects to same since the note would need to be authenticated and no such document [sworn or certified copy as required by Fla.R.Civ.P. 1.510(e)] was filed in this case at least 20 days before the summary judgment hearing as required by Fla.R.Civ.P. 1.510(c). Plaintiff Has Never

10: MARC S. NURIK, ESQ. Law Offices of Marc S. Nurik One East Broward Boulevard Suite 700 Fort Lauderdale, FL 33301 Gary M. Farmer, Jr., Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 EFTA00728270 Epstein v. Rothstein. et

vidence that would be inadmissible at trial, so long as it is reasonably calculated to lead to the discovery of admissible evidence. Rule 1.280(b), Fla.R.Civ.P. (2008). Wherefore, Epstein requests that this court grant the relief requested herein, including, but not limited to, ordering that Edwards retu

10: MARC S. NURIK, ESQ. Law Offices of Marc S. Nurik One East Broward Boulevard Suite 700 Fort Lauderdale, FL 33301 Gary M. Farmer, Jr., Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 EFTA00728263 Epstein v. Rothstein. et

vidence that would be inadmissible at trial, so long as it is reasonably calculated to lead to the discovery of admissible evidence. Rule 1.280(b), Fla.R.Civ.P. (2008). Wherefore, Epstein requests that this court grant the relief requested herein, including, but not limited to, ordering that Edwards retu