Epstein Secrets

ou about the people you named. 13 A. What do you mean by *personal relationship," 13 Have you had a social relationship with Tommy 14 sir? 14 Mottola? 15 Q. Have you socialized with him? 15 A. The names in my Complaint are strictly as a 16 A. Yes, sir. 16 reaction to the abusive discovery p

and 14th Amendment Rights. 7 Copperfield? 8 BY MR. SCAROLA: 8 A. As a reaction to, once again, the abusive 9 Q. Have you ever socialized with Tommy Mottola`. 9 discovery process of bringing in names of people that 10 A. This is the type of questions where people who 10 have absolutely nothing to do

mplaint, I'm asking you about the people you named. 13 A. What do you mean by *personal relationship," 13 Have you had a social relationship with Tommy 14 sir? 14 Mottola? 15 Q. Have you socialized with him? 15 A. The names in my Complaint are strictly as a 16 A. Yes, sir. 16 reaction to th

6 17 18 19 20 21 22 23 24 25 EXHIBITS 1 Message pad 2 Documents INDEX OF EXAMINATION WITNESS DIRECT CROSS ALFREDO RODRIGUEZ (By Mr. Mermelstein) 12 (By Mr. Edwards) 157 (By Mr. Langino) 260 INDEX OF EXHIBITS PAGE 72 115 Page 6 Page 8 1 Doe right here on the copy you gave me. I'm

Richard Willits, representing MR. BERGER: William J. Berger, representing M., M. and Jane Doc number two. MR. MERMELSTEIN: Stuart Mennetstein of Mermelstein and Horowitz. representing Jane Does numbers two through eight. MR. LANGINO: Adam Langino, on behalf of 1 2 3 4 5 6 7 8 9 10 11 12 13

and Edwards Affidavit, Exhibit "N" at ¶14. 73. Epstein's complaint alleges that Edwards provided notice that he wished to take the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law firm of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exh

t Epstein, other civil attorneys were filing similar lawsuits against Epstein. For example, on or about April 14, 2008 another law firm, Herman and Mermelstein, filed the first civil action against Epstein on behalf of one of its seven clients who were molested by Epstein. The complaints that attorney Herma

and Edwards Affidavit, Exhibit "N" at ¶14. 73. Epstein's complaint alleges that Edwards provided notice that he wished to take the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law finn of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exh

t Epstein, other civil attorneys were filing similar lawsuits against Epstein. For example, on or about April 14, 2008 another law firm, Herman and Mermelstein, filed the first civil action against Epstein on behalf of one of its seven clients who were molested by Epstein. The complaints that attorney Herma

Edwards Robert C. Josefsberg Hearing to Un-seal Joint-privilege 06702-06705 09/16/2009 Bradley J. Edwards Kikka M. Claudio Igor Zinoview & Tommy Matola depos Joint-privilege 06706-06708 10/14/2009 Bradley J. Edwards Kikka M. Claudio Igor Zinoview depo Joint-privilege 06715-06719 10/09/2009

9 EFTA00602853 Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Mermelstein 01319 08/11/2009 Adam Horowitz Jacquie Johnson Epstein Depo Joint-privilege 01316 08/27/2009 Spencer Kuvin Bradley J. Edwards Epstein Depo

Edwards Robert C. Josefsberg Hearing to Un-seal Joint-privilege 06702-06705 09/16/2009 Bradley J. Edwards Kikka M. Claudio Igor Zinoview & Tommy Matola depos Joint-privilege 06706-06708 10/14/2009 Bradley J. Edwards Kikka M. Claudio Igor Zinoview depo Joint-privilege 06715-06719 10/09/2009

9 EFTA00310066 Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Mermelstein 01319 08/11/2009 Adam Horowitz Jacquie Johnson Epstein Depo Joint-privilege 01316 08/27/2009 Spencer Kuvin Bradley J. Edwards Epstein Depo

and Edwards Affidavit, Exhibit "N" at /14. 73. Epstein's complaint alleges that Edwards provided notice that he wished to take the deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law firm of Searcy Denny Scarola Barnhart and Shipley. See Edwards Affidavit, Exh

t Epstein, other civil attorneys were filing similar lawsuits against Epstein. For example, on or about April 14, 2008 another law firm, Herman and Mermelstein, filed the first civil action against Epstein on behalf of one of its seven clients who were molested by Epstein. The complaints that attorney Herma