Epstein Secrets

DRAFT April 7, 2010 Sent by Fax and U.S. Mail Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Re: Epstein v. Rothstein, et al. Dear Mr. Scarola: I am in receipt of your March 17,

which was sent. We also have requested days for the completion of Mr. Edwards' deposition, taking the deposition of A.J. DiScala, Michael Legamaro, Michael Fisten and Richard Fandrey. While we obtained April 19, 2010 for Fisten and Fandrey, the dates that you have given for the others are months away, i.e. Ju

ards' deposition, taking the deposition of A.J. DiScala, Michael Legamaro, Michael Fisten and Richard Fandrey. While we obtained April 19, 2010 for Fisten and Fandrey, the dates that you have given for the others are months away, i.e. June of 2010. I find it hard to believe that you are the only perso

nd correct copy of the foregoing was sent via e-mail and U.S. Mail on this 16th day of February, 2012 to: Jack Scarola, Esq., Searcy Denney Scarola Barnhart & Shipley, E., 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, 250 Australian Ave. South,

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

e 2 Fort Lauderdale, FL 33301 EFTA00728270 Epstein v. Rothstein. et at Page 7 Fax Attorneys for Defendant Scott Rothstein Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A 2139 Palm Beach Lakes Blvd. Mttor neyr Beach, FL 33409 s for Defendant Bradley Edwards Fax ttorneys or efendant, L.M. Jack Alan Goldberge

t "A" at pp. 169-171, 185-186. Edwards counsel made clear that Edwards would not answer "any questions" related to the alleged investigation done by Fisten and other investigators. Therefore, it was clear that despite the fact that Mr. Edwards and Mr. Fisten discussed Epstein and the Jane Doe matters w

stein v. Epstein, 519 So.2d 1042 (Fla. 3d DCA 1988). The financial information sought here is clearly relevant. (b) Topic Specific Objections As to Michael Fisten Should Be Overruled and Edwards Should be Compelled To Return For Deposition to Testify to Same and to His Newly Filed Affidavit 6. Michael Fiste

8263 Epstein v. Rothstein. et at Page 7 Fax Attorneys for Defendant Scott Rothstein M- Fax Attorneys for Defendant, L.M. Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 F ttorneys for Defendant Bradley Edwards Jack Alan Goldberger, Esq. Atterbury Goldb

t "A" at pp. 169-171, 185-186. Edwards counsel made clear that Edwards would not answer "any questions" related to the alleged investigation done by Fisten and other investigators. Therefore, it was clear that despite the fact that Mr. Edwards and Mr. Fisten discussed Epstein and the Jane Doe matters w

stein v. Epstein, 519 So.2d 1042 (Fla. 3d DCA 1988). The financial information sought here is clearly relevant. (b) Topic Specific Objections As to Michael Fisten Should Be Overruled and Edwards Should be Compelled To Return For Deposition to Testify to Same and to His Newly Filed Affidavit 6. Michael Fiste

secure mode of communication and may be accessed by unauthorized persons. This communication originates from the law firm of Searcy Denney Scarola Barnhart & Shipley, P.A. and is protected under the Electronic Communication Privacy Act, 18 U.S.C. S2510-2521. The information contained in this E-mail message is pri

each, FL 33401 Lilly Ann Sanchez, Esq. The L•S Law Firm Four Seasons Tower, 15th Floor 1441 Brickell Avenue Miami, FL 33131 Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack A. Goldberger, Esq. Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue,

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

dberger & Weiss, P.A. 250 Australian Avenue South Suite 1400 West Palm Beach. FL 33401 Phone: Fax: Attorneys for Jeffrey Epstein Jack Scarola Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: Fax: Attorneys or e endant, Bradley Edwards Marc Nurik Law Offices

red private investigators to perform investigative work in anticipation and furtherance of litigation. 8. Several private investigators, including Michael Fisten and Richard Fandry, were hired by RRA to perform investigative work on the L.M. case, in anticipation and furtherance of litigation. 9. As has be

I HEREBY CERTIFY that a true and correct copy of the foregoing was mailed, faxed and emailed this 1 3 day of April, 2011 to : Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue S

t opportunities in any claim or litigation against Jeffrey Epstein: a) Scott Rothstein b) Russell Adler c) William Berger d) Bradley Edwards e) Michael Fisten f) Kenneth Jenne g) David Baden h) Deborah Villegas i) Andrew Barnett j) Patrick k) Richard (Rick) Fandrey I) Christina Kitterman 2. Any and

pel Defendant Edwards to Answer Questions and Appear for Further Deposition was served by mail vA this Cl day of February, 2011 on: Jack Scarola Searcy Denney Scarola Barnhart & Shipley Attorneys for Bradley J. Edwards 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Marc S. Nurik, Law Offices of Marc S. Nurik Attorney

Who did [Mike Fisten] go to California to interview? MR. SCAROLA: That is work product and I instruct you not to answer. Id. at 170. Q. Did Mr. Fisten interview a person by the name of Michael Sanka? MR. SCAROLA: That is work product and I instruct you not to answer. Q. Did Mr. Fisten interview a

attached list, this 'ay of 2017. OLA No.: 169440 E-Mail(s): [email protected]• and @searcylaw.com Primary E-Mail: [email protected] Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: 561-383-9451 Attorneys for Bradley J. Edwards

erg, Esq. PODHURST ORSECK, PA 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,

g has been duly furnished via G Email, G Facsimile, G U.S. Mail, G Hand Delivery, G Federal Express this day of August, 2011: Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A 2139 Palm Beach Lakes Blvd. P.O. Drawer 3626 West Palm Beach, FL 33409 Jack Alan Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 A

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