Epstein Secrets

CLUSION Based on the foregoing, Edwards' Renewed Motion for Summary Judgment should be denied. Dated: February 16, 2012. Respectfully submitted, Joseph L. Ackerman, Jr. Florida Bar No. FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Easier Drive West Palm B Telephone: Facsimile: and Christo

ricken. Finally, inadmissible and improper triple hearsay forms the basis of the "facts" set forth in ¶ 80, in which Edwards cites the affidavit of Michael Fisten (Ex. QQ), an investigator who recounted what George Rush, a New York Daily News reporter, told Fisten what Epstein had said in an interview with Ru

n which Edwards cites the affidavit of Michael Fisten (Ex. QQ), an investigator who recounted what George Rush, a New York Daily News reporter, told Fisten what Epstein had said in an interview with Rush. EDWARDS' "FACTS" PERTAINING TO OTHER PURPORTED ACTS OR WRONGS ARE NOT PROBATIVE AND ARE HIGH

rola, Esquire, Searcy Denney Scarola et al., 2139 Palm Beach Lakes Boulevard, P.O. Drawer 3626, West Palm Beach, FL 33409. Respectfully submitted, Joseph L. Ackerman, Jr. Fla. Bar No. 235954 FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone:

t 14. RRA employed a number of investigators used in the prosecution of the Epstein Actions. Those investigators included, but were not limited to Michael Fisten ("Fisten") and Ken Jenne, ("Jenne"), employees of RRA. Fisten and Jenne were the primary investigators assigned to Edwards and to whom they reporte

yed a number of investigators used in the prosecution of the Epstein Actions. Those investigators included, but were not limited to Michael Fisten ("Fisten") and Ken Jenne, ("Jenne"), employees of RRA. Fisten and Jenne were the primary investigators assigned to Edwards and to whom they reported to cond

rida this day of April, 2012. wED p,, 04 vo s ApR u Ar JUDGs ° 20I2 to HONORABLE DAVID F. CR( )w %it CIRCUIT JUDGE Copies furnished to: Joseph L. Ackerman, Jr., Esq. Fowler White Burnett, P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, FL 33401 Lilly Ann Sanchez, Esq. The L•S

ween any attorney and/or employee of the former Rothstein law firm, including but not limited to, Scott Rothstein, Russell Adler, Williaria Berger, Michael Fisten, Ken Jenne, David Boden, Deborah Villegas, Andrew Barnett, Patrick Roberts, Richard Fandry, Christina Kittennan, Gary Farmer and Bradley Edwards, o

00 Ft. Lauderdale, FL 33301 Martin Weinberg, Esq. Martin G. Weinberg, P.A. 20 Park Plaza, Suite 1000 Suffolk, MA 02116 Respectfully submitted, Joseph L. Ackerman, Jr. Fla. Bar No. 235954 FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: (

going to another lawyer and going to the Florida Bar. 11. RRA 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 Edward

1 • (561) 802-9044 EFTA00584226 Epstein v Rothstein, Edwards Case No.: 502009CA040800XXXXMBAG Second Amended Complaint Respectfully submitted, Joseph L. Ackerman, Jr. Fla. Bar No. 235954 FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: (

going to another lawyer and going to the Florida Bar. II. RRA 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 Edward

ther harassing actions against Jane Doe also followed. See Motion for Contempt filed by Edwards in Jane Doe v. Epstein detailing the event, including Fisten Affidavit attached to Motion, Composite Exhibit “RR.” Epstein Settlement of Civil Claims Against Him for Sexual Abuse of Children 84. The civil cas

139 Palm Beach Lakes Blvd West Palm Beach, FL 33409 By: 42 HOUSE_OVERSIGHT_010607 --- PAGE BREAK --- SERVICE LIST Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, FL 33401 Jack Alan Goldberger, Esq. Atterbury Goldb

ther harassing actions against Jane Doe also followed. See Motion for Contempt filed by Edwards in Jane Doe v. Epstein detailing the event, including Fisten Affidavit attached to Motion, Composite Exhibit “RR.” Epstein Settlement of Civil Claims Against Him for Sexual Abuse of Children 84. The civil case

139 Palm Beach Lakes Blvd West Palm Beach, FL 33409 By: 42 HOUSE_OVERSIGHT_013360 --- PAGE BREAK --- SERVICE LIST Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, FL 33401 Jack Alan Goldberger, Esq. Atterbury Goldb