Epstein Secrets

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

AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o

reet, Fort Lauderdale, FL 3330I• 954.467.1223 EFTA00799405 lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., has Mr. Howell participated in the case; that is, has he done work on the case? Id. at page 90; lines 20-23. A: Yes. Id. at page 90; line 24. Q:

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

AROLA: I am going to object. That calls for attorney-client privilege. Id. at page 98; line 24-25. Q: All right. At the time you began representing E.W. or at any time prior to the filing of the lawsuit against the United States Government in July of '08, did you learn whether she was listed as a, o

Attorney-Client and work-product privileges. Id. at page 89; lines 20-21. Q: During that time that you have been involved in this case on behalf of E.W., 3 It is significant to note that other jurisdictions have sanctioned counsel for just this behavior during deposition. See e.g. Van Pilsum v. Iow

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

Paul Cassell? If yes, since when and how did you meet? 14.10 A Mr. Howell? same as for Cassell. 14.11 3 files: State court was ■. (Jane Doe # 2), E.W. (Jane Doe #1) and . 14.12 Who staffed the Epstein files? 14.12.1 BE testified that you Judge Stone, Bill Berger and Rob Buschell worked on cases?

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

S to strike. 14 THE MITNESS: Ho. Is BY MR. SCAROLA: IS Q If Jeffrey Epstein alleges in this 19 complaint against Bradley Edwards that III., E.W. or 24 Jane Doe voluntarily consented to their sexual 21 molestation, could Jeffrey Epstein have possibly made 22 that claim on the basis of any

nd Frederick Small Road. Steven Dunn, 53, of Stone Mountain, Ga., and Jesus Antonio Resen- diz-Ba

th to do so today. "It is against public policy for these documents to have been sealed and hidden from public scrutiny. As a member of the public, E.W. has the right to have these documents unsealed," wrote former Circuit Judge Bill Berger, now in private practice and representing one of the women.

ention is reviewed only for abuse of discretion. Stone' First Union Corp.. 371 F.3d 1305, 1309 (11th Cir

z] who you know to have stayed at Jeffery Epstein's house on many occasions, correct? And also somebody who you know to have been at the house when E.W. was in Jeffrey Epstein's bedroom getting sexually abused, correct? 26 Of course, in a proceeding such as this one, the victims are entitled to an i

o discovery, for the "purpose of discovery is to find out additional facts about a well-pleaded claim, not to find out whether such a claim exists." Stoner v. Walsh, 772 F. Supp. In Bonner v. City of Pritchard, 661 F.2d 1206, 1207 & 1209 (11i° Cir. 1981) (en bane), the Eleventh Circuit adopted as bindi

follows: The names of all of the victims are unknown to the plaintiff at this time. However, they include Jane Doe herself as well as the victim in E.W. v. Jeffrey Epstein and L.M. v. Jeffrey Epstein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Offic

o discovery, for the "purpose of discovery is to find out additional facts about a well-pleaded claim, not to find out whether such a claim exists." Stoner v. Walsh, 772 F. Supp. In Bonner v. City of Pritchard, 661 F.2d 1206, 1207 & 1209 (11i° Cir. 1981) (en bane), the Eleventh Circuit adopted as bindi

follows: The names of all of the victims are unknown to the plaintiff at this time. However, they include Jane Doe herself as well as the victim in E.W. v. Jeffrey Epstein and L.M. v. Jeffrey Epstein. A list of more than 30 such minor females has previously been provided by the U.S. Attorney's Offic

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

state court civil action on behalf of L.M. 31. On or about October 17, 2009, Edwards, who had filed a state complaint against Epstein on behalf of E.W., emailed his assistant to file a federal complaint against Epstein on behalf of E.W like the one he had filed in federal court on behalf of L.M.. 3