Epstein Secrets

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).

Fowler WhiteATBmuNEr,p S meLtAt,)p MEMORANDUM TO: File FROM: Susan H. Aprill DATE: April 18, 2011 RE: Outline of deposition of Russell Adler, former RRA partner FILE NO.: 80743 DRAFT 4 18 11 8:21 PM Epstein v. Rothstein & Edwards Outline for Russell Adler Deposition, 4-20-11 @ 9:30 a

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

4,124, 301-03. 30. Admit that Scott Rothstein was involved in the decision to file the Complaint (DE #1) in Case 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

52. All People on Jeffrey Epstein's Inmate Visitor Log while he was in jail. WITNESS TESTIMONY EXPECTED TO BE PRESENTED BY MEANS OF DEPOSITION 153' Mark Epstein 30 VANDAM STREET NEW YORK, NY 10013 154. c o Akin S. Ross, Gs q. 155. 156. Alfredo Rodriguez 11349 SW 86TH LN, Miami, FL C/O Federal Public De

25 W FLAGLER STREET, STE 800 MIAMI, FL 33131 83. David Co field (David Seth Kokin) LAS VEGAS, NV 89135 84. 85 Michael Fisten Weston, FL 86 Russell Adler Delray Beach, FL 87. Marie Alessi BOYTON BEACH, FL 33472 88. Janusz Banasiak 358 EL BRILLO WAY PALM BEACH FL, 33480 89. Beata Banasiak 358

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

ant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 03088 04/11/2009 Epstein Litigation Russell Adler Litigation Strategy Work Product;attorney client 28 EFTA00602862 Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos &

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

ege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01940 09/10/2009 Russell Adler Bradley J. Edwards Witness Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery

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

ant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 03088 04/11/2009 Epstein Litigation Russell Adler Litigation Strategy Work Productattorney client 28 EFTA00310075 Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & L

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

ege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01940 09/10/2009 Russell Adler Bradley J. Edwards Witness Info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery

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

ony, many RRA attorneys conferred and were involved with the prosecution of the Epstein Actions, including as described below: a) On May 3, 2009, Russell Adler ("Adler"), a name partner in RRA, who took part with Edwards in the prosecution of the Epstein Actions, sent an email to the staff and attorneys in

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

ony, many RRA attorneys conferred and were involved with the prosecution of the Epstein Actions, including as described below: a) On May 3, 2009, Russell Adler ("Adler"), a name partner in RRA, who took part with Edwards in the prosecution of the Epstein Actions, sent an email to the staff and attorneys in