Epstein Secrets

DATE TO FROM DESCRIPTION OBJECTION 15454-15475 09/15/2009 Adam Horowitz Jacquie Johnson Critton's notice of depo;Epstein notice of hearing,Mark Epstein notice of depo Joint W/P Priv. 01465 07/13/2009 Katherine Ezell Bradley Edwards Epstein Joint W/P Priv. 15485-15492 09/17/2009 Jacquie John

t and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05292 07/22/2009 Attorneys at RRA Ken Jenne RE: Epstein Meeting W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; pro

and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 26716.26717 09/04/2009 Mike Fisten Ken Jenne NR as a victim W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by

DATE TO FROM DESCRIPTION OBJECTION 15454-15475 09/15/2009 Adam Horowitz Jacquie Johnson Critton's notice of depo;Epstein notice of hearing,Mark Epstein notice of depo Joint W/P Priv. 01465 07/13/2009 Katherine Ezell Bradley Edwards Epstein Joint W/P Priv. 15485-15492 09/17/2009 Jacquie John

t and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 05292 07/22/2009 Attorneys at RRA Ken Jenne RE: Epstein Meeting W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; pro

and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 26716-26717 09/04/2009 Mike Fisten Ken Jenne NR as a victim W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by

cket from L.M. v. Jef•ey Epstein; 09-CV-81092- COHN. 14. Subpoena(s)/Notice(s) for Deposition of Donald Trump, Alan Dershowitz, David Copperfield, Mark Epstein. 15. Subpoena to Leonard Baird. this one too? ). (sex therapist named in Complaint- we want 2 EFTA00691737 16. Notices to produce medical re

WITNESSES I. Scott W. Rothstein do Marc Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 2. Ken Jenne do Broward Co. Sheriff Office 2601 W. Broward Blvd. Ft. Lauderdale, FL 33312-1308 3. William Scherer do Conrad & Scherer, LLP PB Box 14723 Ft

tein files? 14.12.1 BE testified that you Judge Stone, Bill Berger and Rob Buschell worked on cases? [BE tr. 229-232] 14.12.2, you, e.g., attended Mark Epstein's depo 14.12.3 you were to coordinate depos or be involved for all high profile people? 15. Did Adler and others ever talk about Epstein case(s).

s, bugs, other listening and watching)? 21.9.6 What is Blue Line R & D? 21.10 Knowledge of skills and involvement of: 21.10.1 Mike Fisten 21.10.2 Ken Jenne 21.10.3 Patrick 21.10.4 Rick Fandry 22. Criminal History - have you ever been convicted of a crime? If yes, when and for what? C:WserAill0JAVIM

a named Defendant herein), and two of which have been filed in state court in the 15th Judicial Circuit Court, Palm Beach County, State of Florida, (M. v. Epstein, Case No. 502008CA028051XXXXMB AB; M. v. Epstein, Case No. 502008CA028058XXXXMB AB), (hereinafter collectively referred to as the "Civil A

No. 09-CV-81092. 31. Admit that Russell Adler was involved in the decision to file the Complaint (DE #1) in Case No. 09-CV-81092. 32. Admit that Ken Jenne was involved in the decision to file the Complaint (DE #1) in Case No. 09-CV-81092. 33. Admit that Michael Fisten was involved in the decision to

or Media rep (?) Media rep (?) -1- EFTA00600049 Michael Sanka Patrick Roberts Nesbitt Kirkendahl Jason Richards Dexter Lee Maria Villafana Mark Epstein Judge Stone Deborah Villegas Bart' Bekkadan A.J. Discala Alfredo Rodriguez Michael Szafranski Dominic Ponatchio Moto Ban Mon Shimone Levy O

arry Yogel Alan Weinstein, investment broker FROM BRADLEY EDWARDS DEPO Maria Kelljian Beth Williamson Michael Fisten Dean Howell Paul Cassell Ken Jenne Bill Berger Richard Fandry Jane Muskrat Michelle Daryan Chislaine Maxwell Paralegal Paralegal Investigator Referred E.W. case against Epstei

494.02515 09/20/2009 Bradley Edwards Pat Diaz Mark Epstein Info Work product; attorney/client privilege;

irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01787-01788 09/04/2009 Ken Jenne Bradley J. Edwards 1. Accountants 2. Motion for IME Work product; attorney/client privilege; irrelevant and not reasonably calculated to lea

494-02515 09/20/2009 Bradley Edwards Pat Diaz Mark Epstein Info Work product; attorney/client privilege;

irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01787.01788 09/04/2009 Ken Jenne Bradley J. Edwards 1. Accountants 2. Motion for IME Work product; attorney/client privilege; irrelevant and not reasonably calculated to lea

who had knowledge of Epstein's charitable, political or other donations; Leslie Wexner, a. client of the Plaintiff; (e) Taking the deposition of Mark Epstein, brother of the Plaintiff, but not asking any questions about Edwards' clients; Edwards targeted the foregoing individuals because they were close

A employed a team of investigators on the Epstein Actions, including Michael Fisten ("Fisten") and former Broward County Sheriff and convicted felon Ken Jenne ("Jenne"). 12. Fisten and Jenne were the primary investigators assigned to Edwards, and routinely reported to Edwards and Rothstein regarding thei

avid Copperfield (illusionist); (d) Individuals who had knowledge of Epstein's charitable, political or other donations. Taking the deposition of Mark Epstein, brother of the Plaintiff, but not asking any questions about Edwards' clients; Edwards targeted the foregoing individuals because they were close

A employed a team of investigators on the Epstein Actions, including Michael Fisten ("Fisten") and former Broward County Sheriff and convicted felon Ken Jenne ("Jenne"). 12. Fisten and Jenne were the primary investigators assigned to Edwards, and routinely reported to Edwards and Rothstein regarding thei