Epstein Secrets

ton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (I) David

sor, constitutional attomey and one of EPSTEIN'S criminal defense attorneys); (iii)Bill Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (I) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTE

FTA00190040 Epstein'. RRA, et at Page 16 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Berger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were asked of EPSTEIN which had no bearing o

or, constitutional attorney and one of EPSTEIN'S criminal defense attorneys); (iii)Bill Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (v) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTE

ton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (v) David

A00596503 Epstein v. RRA, et al. Page 16 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Berger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were asked of EPSTEIN which had no bearing o

or, constitutional attorney and one of EPSTEIN'S criminal defense attorneys); (iii)Bill Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (v) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTE

ton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (v) David

A00729418 Epstein v. RRA, et al. Page 16 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Berger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were asked of EPSTEIN which had no bearing o

confident that once we do, I will be able to answer your questions with more specificity. Id. at 83; lines 11-22. Q. Have you ever socialized with Tommy Mottola? A. This is the type of questions where people who have nothing to do with this case whatsoever have been brought into the case by Mr. Edwards in a

ess by Mr. Edwards, his partners, Scott Rothstein, who sits in jail, in an attempt to imperil my friendships. But, yes, I have socialized with Mr. Mottola. Id. at 91; lines 11-19. Q. Have you had a social relationship with David Copperfield? A. As a reaction to, once again, the abusive discovery proc

Mr. Berger, Mr. Adler, Mr. Edwards and other people associated with the firm like Mr. Fisten, Diane Villegas, if that's how you pronounce her name, Russell Adler, and many of the other partners of his firm currently under investigation by either the Florida or the U.S. Attorney or FBI or all of the above, si

ton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (v) David

constitutional attorney . and one of EPSTEIN'S criminal defense attorneys); (iii)Bill Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (v) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTE

A00286297 Epstein v. RRA, et al. Page 16 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Berger and Russell Adler (another named partner In RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were asked of EPSTEIN which had no bearing o

ton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and J) David

professor, constitutional attorney . and one of EPSTEIN'S criminal defense attorneys); Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and J) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTEI

TA00193786 Epstein'. RRA, et al. Page 16 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Berger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were asked of EPSTEIN which had no bearing o

onstitutional attorney . • and one of EPSTEIN'S criminal defense attorneys); (iii)Bill Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and 1) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTEI

ton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and 1) David

FTA00223282 Epstein 1RRA, et al. Page S6 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Borger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were asked of EPSTEIN which had no bearing o

WITNESSES 104. Jose .h Pagnano WEST PALM BEACH, FL 33401 105. Ste han Kossl CAMBRIDGE MA 02138-1802 106. Cecile Deon • ST THOMAS VI 00802 107. Tommy Mottola PALM BEACH FL 33480-3012 108. Mike Sanka 449 S BEVERLY DR STE 101 BEVERLY HILLS, CA 90212 109. S/A Witness #105 110. William "Bill" Rile CORA

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

rd Law professor, constitutional attorney and one of EPSTEIN'S criminal defense attorneys); ill Clinton (Former President of the United States); T mmy Mottola (former President of Sony Record); and (v) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTE

A00795602 Epstein v. RRA, et al. Page 16 investors or to prejudice Epstein's right to a fair trial in Palm Beach County. c) EDWARDS, Berger and Russell Adler (another named partner in RRA) all attended EPSTEIN's deposition. At that time, outrageous questions were asked of EPSTEIN which had no bearing o

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

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 &