Epstein Secrets

secy? explain 8.36 Any loans by RRA to BE? 9. Who worked with BE at RRA? 9.1 Go through lawyer names mentioned in priv log, including Buschel, Stone, Bill Berger, Adler (go through does). 9.2 10. Others who may have worked with BE on cases: 10.1 11. Cara Holmes 11.1 who hired her? 11.2 t

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

I sat 3 on the Fourth District -- that ha had been hired by the 4 firm, and he had either already started or he was going 3 to start. 6 Judge Stone baa a tremendous reputation. • I think he was Cho longest sitting judge on the S Fourth District. In cases whore I wa➢ -- as a circuit court 10

re In this IS roughly 70-lawyer firm? 19 30 31 A I think there were about 10. Q And who were the other shareholders? A Stuart Rosenfeldt, Russell Adler, Lea 22 Streltfeld, Steve Lippman. There were others -- Mare 23 think might have been -- - pretty sure Hunk was a 24 shareholder. I just do

rred where these various lawyers, Berger, Adler, Stone, Rob Buschel were present and Epstein was discus

the manner in which the cases were handled while Edwards was a partner at RRA: Q: The one meeting that you had in Mr., Mr. Rothstein's office with Russell Adler and some unknown person on the phone, were you given any direction at that time that certain discovery should be done or certain tactics should be

e Anthony P RRA CLIENT Attorneys at RRA Barry Stone Attorney RRA Bert Patton Legal Assistant to Ro

RA Robert C. Josefsbergs Counsel for other Epstein Victims Robin T. Kempner RRA Staff Ronald Wise Forensics (Epstein Case) RRA Personnel RRA Russell Adler Attorney RRA Scott Goldstein Attorney RRA Scott Rothstein Attorney RRA Seth Lehrman Attorney RRA Shawn Gilbert Prior Legal Assistant to Brad

Epstein Case RRA CLIENT Attorneys at RRA Barry Stone Attorney RRA Bert Patton Legal Assistant to Ro

RA Robert C. Josefsbergs Counsel for other Epstein Victims Robin T. Kempner RRA Staff Ronald Wise Forensics (Epstein Case) RRA Personnel RRA Russell Adler Attorney RRA Scott Goldstein Attorney RRA Scott Rothstein Attorney RRA Seth Lehrman Attorney RRA Shawn Gilbert Prior Legal Assistant to Brad

rred where these various lawyers, Berger, Adler, Stone, Rob Bushel were present and Epstein was discus

handled while Edwards was a partner at RRA, the meeting he had with Mr. Rothstein. We asked: "The meeting you had in Mr. Rothstein's office with Russell Adler and some unknown person on the phone, were you given any direction at that time that certain discovery should be done, certain tactics should be

e 04222.04223 09/04/2009 Bradley Edwards Barry Stone Letter from Bob Critton Joint W/P Privilege 21

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 &

e 04222.04223 09/04/2009 Bradley Edwards Barry Stone Letter from Bob Critton Joint W/P Privilege 21

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

email requested that Jenne, Adler, Berger, Barry Stone, Mike Wheeler, Cara Holmes, Rob Buschel, Fisten,

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

email requested that Jenne, Adler, Berger, Barry Stone, Mike Wheeler, Cara Holmes, Rob Buschel, Fisten,

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