belief, ROTHSTEIN and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff an

naming additional Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Villegas, Andrew Bamett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about th

en indicated that they were doing an official police investigation relating to Jeffrey Epstein. 4. But for the affirmative representation that Mr. Fisten was working for either the FBI or certainly for the Miami-Dade Police Department Homicide Division, we never would have opened our door and let the

to my wife's and my home and rang the doorbell. I went to the door and asked who they were. One of the white males, who later identified himself as Michael Fisten, EFTA_R1_00010667 EFTA01733929 may have said that he was an FBI agent, but certainly said that he was from the Homicide Division of the Miami-Da

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

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

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

USER DEPO Michael Szafranski Jim McCay Larry Yogel Alan Weinstein, investment broker FROM BRADLEY EDWARDS DEPO Maria Kelljian Beth Williamson Michael Fisten Dean Howell Paul Cassell Ken Jenne Bill Berger Richard Fandry Jane Muskrat Michelle Daryan Chislaine Maxwell Paralegal Paralegal Investiga

Elizabeth Friedland Michael Legomaro Ken Jenne Mike Fisten Saudi Prince Bill Clinton Naomi Campbell Ted Waite Composed of Roberts, Fandrey, Fisten and Jenne APRILL MEMO DATED FEBRUARY 10, 2011 Convinced several investors to invest in Rothstein Hampton Capital in New York - invested in Razorba

to my wife's and my home and rang the doorbell. I went to the door and asked who they were. One of the white males, who later identified himself as Michael Fisten, EFTA_R1_00010664 EFTA01733926 may have said that he was an FBI agent, but certainly said that he was from the Homicide Division of the Miami-Da

en indicated that they were doing an official police investigation relating to Jeffrey Epstein. 4. But for the affirmative representation that Mr. Fisten was working for either the FBI or certainly for the Miami-Dade Police Department Homicide Division, we never would have opened our door and let the

OOOCMBAG, Judge Crow entered an order on April 19, 2010 (attached as Exhibit H), in which he granted a protective order regarding the depositions of Michael Fisten and Rick Fandrey, investigators previously employed by Rothstein, Rosenfeldt & Adler ("RRA"). As the Court may recall, RRA represented Jane Doe pri

Adler ("RRA"). As the Court may recall, RRA represented Jane Doe prior to its implosion. 5 EFTA00728108 16. While Epstein sought to depose Mr. Fisten and Mr. Fandrey regarding their knowledge of Scott Rothstein's Ponzi scheme, the Court nevertheless entered a protective order prohibiting their de

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

naming additional Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Vilieges, Andrew Barnett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about th

belief, ROTHSTEIN and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff an

XMBAG, Judge Crow entered an order on April 19, 2010 (attached as I Exhibit H), in which he granted a protective order regarding the depositions of Michael Fisten and Rick Fandrey, investigators previously employed by Rothstein, Rosenfeldt & Adler ("RRA"). As the Court may recall, RRA represented Jane Doe pri

its implosion. 5 Case 9:08-cv-80119-KAM Document 536 Entered on FLSD Docket 04/29/2010 Page 6 of 8 16. While Epstein sought to depose Mr. Fisten and Mr. Fandrey regarding their knowledge of Scott Rothstein's Ponzi scheme, the Court nevertheless entered a protective order prohibiting their de

ave to testify Tuesday. Neither did Fort Lauderdale private investigator Michael Fisten, also in the courtroom. Working on behalf of Epstein victims, Fisten discovered the existence of the tape and had a conversation with Rush about its contents. Representing Rush and the newspaper, Washington attorney La

Rush, of the New York Daily News, was present in the courtroom, but did not have to testify Tuesday. Neither did Fort Lauderdale private investigator Michael Fisten, also in the courtroom. Working on behalf of Epstein victims, Fisten discovered the existence of the tape and had a conversation with Rush about its

terview had been off-the-record and, moreover, would be of no help to his clients. Id. 8. Thereafter, on October 22, 2009, Rush also had a call with Michael Fisten, an investigator employed by Edwards on the sexual abuse cases, during which Rush paraphrased aspects of the Epstein interview. Moving Affidavit of

sexual abuse cases, during which Rush paraphrased aspects of the Epstein interview. Moving Affidavit of Michael Fisten, sworn to Sept. 14, 2010,1 8. Fisten also requested a copy of the Epstein interview, which request was likewise refused. Id. ¶ 10. The Daily News has not published any articles publicl

interview with Jeffrey Epstein but whom I did not identify in my prior affidavit. Hearing that refreshed my memory that in fact I did speak to Mr. Fisten about the interview. The attorney's representation that the interview with Mr. Epstein must have occurred prior to October 22, 2009, because my conv

unsel responded that they would do so only if movants would stipulate to the accuracy of all facts alleged in the subpoenas of Brad- ley Edwards and Michael Fisten submitted in support of Doe's opposition to movants' motion to quash or for a protective order. I declined. I declare under penalty of perjury that

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

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

: told George : o 16. oe Mr. Rush indicated that he taped the. conversation between him and: Mr. Epstein, _ 5, Se Mr. “Rush also spoke at length to Michael Fisten, an investigator with: my'fi firm that. was - . assisting with the investigation of the case... Mr. Fisten reported to: me * shortly after the conver

Mr. “Rush also spoke at length to Michael Fisten, an investigator with: my'fi firm that. was - . assisting with the investigation of the case... Mr. Fisten reported to: me * shortly after the conversation with Mr. Rush that he: had such a conversation. . pclae tpi vale HOUSE_OVERSIGHT_013464 --- PAGE

any evidence to prove Epstein's lack of remorse for this abuse, a showing critical for securing substantial punitive damages. In the fall of 2009, Michael Fisten, an investigator working for Edwards, heard from an author that Daily News reporter George Rush had made a recording of Epstein discussing the sexu

ard from an author that Daily News reporter George Rush had made a recording of Epstein discussing the sexual abuse of minor girls. The author told Fisten that Rush had played the recording for her and two other persons. The author concluded: "You've got to get that tape." Fisten then called Rush. Rus

belief, ROTHSTEIN and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff an

naming additional Defendants was filed. 21. In addition, and upon information and belief, ROTHSTEIN, David Boden, Debbie Villegas, Andrew Barnett, Michael Fisten and Kenneth Jenne (all employees of RRA) through brokers or middlemen would stage regular meetings during which false statements were made about th

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

unsel responded that they would do so only if movants would stipulate to the accuracy of all facts alleged in the subpoenas of Brad- ley Edwards and Michael Fisten submitted in support of Doe's opposition to movants' motion to quash or for a protective order. I declined. 1 declare under penalty of perjury that

interview with Jeffrey Epstein but whom I did not identify in my prior affidavit. Hearing that refreshed my memory that in fact I did speak to Mr. Fisten about the interview. The attorney's representation that the interview with Mr. Epstein must have occurred prior to October 22, 2009, because my conv

one and the city would remove the no parking signs. I asked Capt. Hess if they knew the complainants' name or his address. They did not. I gave him Fisten's details, along with the other three miscreants information. Capt. Hess is now aware they are Pl's surveilling the address and Fisten is upset my h

pril 1, 2010 3:50:32 AM EDT To Cc Subject: 358 El Brillo Way Story, Spoke to Capt. Hess tonight. His department is still getting complaints from Michael Fisten (pretending to be a resident) in reference to our parking on the street using headlights. PBPD's solution is to have the client send a letter reque