Epstein Secrets

ate Attorney's Office 1350 NW12th Avenue Miami, FL 33136-2102 7. Kikka Claudio (do we know who she was at RRA) Address unknown at this time 8. Paul Cassell Borton Petrini, LLP 1320 Columbia Street, Suite 210 San Diego, California 92101-3436 9. Margaret Berk 5925 Kaiser Lane Pensacola, FL 32507-831

s at RRA) Address unknown at this time 8. Paul Cassell Borton Petrini, LLP 1320 Columbia Street, Suite

ist named in Complaint- we want 2 EFTA00691737 16. Notices to produce medical records to Charles J. Galecki, M.D., Bruce W. Markowitz, M.D. and Steven R. Alexander, Ph.D. (as stated in Complaint- we want this one too? ). The Defendants reserve the right to produce any newly discovered evidence upon proper not

vestigation, sent an email to Edwards stating that "our best bet is to go after those close to Epstein"; f) In July, 2009, Edwards and co-counsel, Paul Cassell, exchanged emails about their lack of proof on a previously-filed motion, which claimed that Epstein was moving his assets to avoid paying any judg

f) In July, 2009, Edwards and co-counsel, Paul Cassell, exchanged emails about their lack of proof on a

44 EFTA00584206 Epstein v Rothstein, Edwards Case No.: 502009CA040800XXXXMBAG Second Amended Complaint (b) Bruce W. Markowitz, M.D.; and (c) Steven R. Alexander, Ph.D. (7) Directing and filing Notices to the following banks of Epstein, Colonial Bank and Palm Beach National Bank, to produce all financial rec

f Investigation, sent an email to Edwards stating that "our best bet is to go after those close to Epstein"; In July, 2009, Edwards and co-counsel, Paul Cassell, exchanged emails about their lack of proof on a previously-filed motion, which claimed that Epstein was moving his assets to avoid paying any judg

in"; In July, 2009, Edwards and co-counsel, Paul Cassell, exchanged emails about their lack of proof on a

n, when Epstein's mental and emotional state was not an issue in the case: (a) Charles J. Galecki, M.D.; (b) Bruce W. Markowitz, M.D.; and (c) Steven R. Alexander, Ph.D.; - 12 - FOWLER WHITE BURNETT P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLF.R DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA

712 6. Ami Eden Miami-Dade State Attorney's Office 1350 NW12th Avenue Miami, FL 33136-2102 7. Kikka Claudio Address unknown at this time 8. Paul Cassell Borten Petrini, LLP 1320 Columbia Street, Suite 210 San Diego, California 92101-3436 9. Mar Taret Berk 10. Mercedes Estrada Address unknown a

a Claudio Address unknown at this time 8. Paul Cassell Borten Petrini, LLP 1320 Columbia Street, Suite

nd Mark Epstein. 15. Subpoena to Leonard Baird. 16. Notices to produce medical records to Charles J. Galecki, M.D., Bruce W. Markowitz, M.D. and Steven R. Alexander, Ph.D. 2 EFTA00587267 17. Any and all exhibits/documents/pleadings referenced in Epstein's Motion for Summary Judgment as to Edwards's Counterc