EFTA00129670¶
Bradley J. Edwards¶
Direct Dial: 954-315-7266¶
bedwards.arra-law.com¶
August 4, 2009¶
Via Fedex And First Class Mail¶
Alfredo Rodriguez¶
11349 SW 86th Lane¶
Miami, FL 33173¶
Re: Jane Doe v. Epstein, Our File No. 09-22784¶
Dear Mr. Rodriguez,¶
During the first part of your deposition you indicated that you would be able to locate some documents and information to bring to the continuation of your deposition scheduled for this Friday, August 7, 2009. Some of those things were:¶
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Your journals, logs, notes or personal memos that reflect the names and phone numbers of the girls (“masseuses”) that visited the house;
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The cards from the investigators that visited you on various occasions;
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Names/numbers of the cab companies or drivers used to take the girls to and from the house;
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Name and address of Epstein’s company that paid you your salary;
address and/or phone number;¶
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Name of the girl that took care of the pool;
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List of all clubs where Epstein was a member;
| Reply To: Las Olas City Centre • 401 East Las Olas Boulevard • Suite 1650 • Fort Lauderdale, Florida 33301 Telephone: (954) 522-3456 • Fax: (954)527-8663 |
| BOCA RATON • FORT LAUDERDALE • MIAMI • NEW YORK CITY • TALLAHASSEE • WASHINGTON D.C. • WEST PALM BEACH |
EFTA00129671¶
November 9, 2009 Page 2 of 3¶
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Full name, address and phone number for Bella and Eva in New York;
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Any copies of message pads or schedules;
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The confidentiality agreement;
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Copy of the house manual;
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Copies of documents reflecting banks where Epstein had accounts; and
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Names of any of Epstein’s businesses.
Please bring whatever other related information that you have. I appreciate your cooperation in this regard.¶
Very Truly Yours,¶
ROTHSTEIN ROSENFELDT ADLER¶
Bradley J. Edwards, Esq.¶
FOR THE FIRM¶
BJE/jj¶