JEFFREY EPSTEIN,
Plaintiff,
vs.
SCOTT ROTHSTEIN individually, and J, individually.
Defendants.
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
CASE NO. 502009CA040800XXXXMBAG
JUDGE: HAFELE
# JEFFREY EPSTEIN'S MOTION TO COMPEL DISCO RY RESPONSES FROM
Plaintiff/Counter-Defendant Jeffrey Epstein ("Epst and through his undersigned counsel and pursuant to Rule 1.380 of the Florida Rit' ( s Civil Procedure, hereby moves this Court to enter an order compelling the D e 11 t/ ounter-Plaintiff J. a "), yet again, to provide respon e P1 \*ntiff's Request for Production. In support thereof, Plaintiff states:
# A-ACtiINTRODUCTION
Since March 9, 2012, Epstein has been seeking, and has obtained numerous Orders from this Court requiring, documents from that directly relate to both prosecution of, and Epst e of, this case. True and correct copies of the Motions and Orders are attached composite "Exhibit A." These items arc listed on an improper privilege log filed by wards in this matter, pursuant to which he seeks to preclude any information whatsoever regarding the prosecution of the cases against Epstein by RRA during the Ponzi Scheme. A true and correct copy of the privilege log sections at issue are attached hereto as "Exhibit B."
Notwithstanding three Court Orders mandating him to do so, has failed to provide responsive documents or otherwise file any proper privilege log with respect to the items requested that are directly related to the prosecution and defense of this matter. See Orders from this Court dated April 10, 2012, May 7, 2012, and August 17, 2012, attached hereto as part of composite "Exhibit A." Undeniably, in his Malicious Prosecution Count in his Fourth Amended Counterclaim,M specifically alleges that while prosecuting the cases against Epstein at RRA, he had "not engaged in any unethical, illegal, or improper conduct nor hash taken any action inconsistent with the duty he has to vigorously represent the interests of his clients. EPSTEIN has no reasonable basis to believe othenvise and has never had any reasonable basis to believe otherwisc." See Fourth Amended Counterclaim, 1 24. As such, and as demonstrated more fully below, an Order compelling Edwards to comply with this Court's orders is warranted..
## MEMORANDUM OF LAW
Florida law permits litigants ample latitude in discovery. Rule 1.280 of the Florida Rules of Civil Procedure memorializes this broad scope, and provides that
Parties may obtain discovery regarding any matter, not privileged, that is relevant to the subject matter of the pending action, whether it relates to the claim or defense of the party seeking discovery or the claim or defense of any other, party, including the existence, description, nature, custody, condition, and location of any books, documents, or other tangible things and the identity and location of persons having knowledge of any discoverable matter. It is not ground for objection that the information sought will be inadmissible at the trial if the information sought appears reasonably calculated to lead to the discovery of admissible evidence.
FLA. R.Civ. P 1.280(1) (emphasis added). As such, as long as the discovery requested is relevant to the cause of action as to any claim or defense, and is not othcnvise subject to a privilege, it is discoverable. Here, has a single remaining claim against Epstein for Malicious
Prosecution, and has therefore not only made the actions of both him and his law partners at RRA the subject of this litigation, but also necessary to prove either his assertions in his cause of action or Epstein's defense thereto. This Court has repeatedly agreed, yet notwithstanding three Orders compelling him to do sal not only failed to provide the items requested, but also failed to provide a privilege log as mandated. It is well-settled law that if a party alleges that information requested from it is protected by privilege, then a privilege log must be prepared and attached to the response, or the privilege is waived.. See TIG Insurance Corp. of America v. 799 So. 2d 339 (Fla. 4th DCA 2001) (stating that failure to provide a reason for privilege and prepare a privilege log constitutes waiver of the privilege) (emphasis added). Accordingly,M should be compelled to turn over all of the items requested by Epstein.
Finally, a court has the inherent power to implement and enforce effective judicial proceedings pursuant to pretrial rules. As, such, when a party fails to comply with a pretrial order, a court has broad discretion in determining sanctions. First Republic Corp. of America v. Hayes, 431 So. 2d 624 (Fla. 3d DCA 1983). Rule 1.380(3) of the Florida Rules of Civil Procedure provides that "\[for purposes of this subdivision an evasive or incomplete answer shall be treated as a failure to answer." FLA. R.Civ. P. 1.380(3). This Rule likewise governs failure to comply with a prior court order and mandates that such failure "may be considered a contempt of the court." FLA. R.Civ. P. 1.380(b). \_
Plaintiff certifies that he "in good faith, has conferred or attempted to confer with the person or party failing to make the discovery in an effort to secure the information or material without court action." FLA. R.C1v. P. 1.380.
# CONCLUSION
Accordingly, for all of the reasons delineated above and in reliance upon the applicable
law cited herein, Jeffrey Epstein respectfully requests that this Court, yet again, Order Defendant
EMI to respond in full to Plaintiff's Request to Produce, and such other and further relief as this Court deems proper.
WE HEREBY CERTIFY that a true and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list, this September 25, 2017.
> /s/ Tonja Haddad Colemaq Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 71h Street Suite 301 Fort. Lauderdale, Florida 33301 954.467.1223 954.337.3716 (facsimile) nja@TonjaHaddad.com ling®Tonjahaddad.com Attorneys for Epstein
# SERVICE LIST
CASE NO. 502009CA040800)OOOCMBAG
Jack Scarola, Esq. jsx@searcylaw.com; mep@searcylaw.com Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409
Jack Goldberger, Esq. jgoldberger®agwpa.com; smahoney®agwpa.com Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South, Suite 1400 West Palm Beach, FL 33401
Marc Nurik, Esq. 1 East Broward Blvd., Suite 700 Fort Lauderdale, FL 33301
J. Esq. Jaffe Weissing Fistos Lchrm lairathtojustice.co 425 N Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301
Fred Haddad, Esq. Dee@FredHaddadLaw.com 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301
Tonja HaddadMman, Tonja@tonjahaddad.com; effiing@tonjahaddad.com Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301
W. Chester, Jr. Wcblaw@aglairawi wcbasst@aol.com W. Chester Jr., P.A. 250 S. Australian Avenue, Suite 1400 West Palm Beach, FL 33401
cos
## IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION AG CASE NO. 502009CA04 Judge David F.
JEFFREY EPSTEIN,
Plaintiff/Counter-Defendant,
v.
SSOIITIagai siaijividually, and J. individually,
Defendants/Counter-Plaintiffs.
/
## PLAINTIFF JEFFREY EPSTEIN'S MOTION TO COMPEL AND AMEND PROTECI'In ORDER
Plaintiff, Jeffrey Epstein ("Epstein"), by and thrmigh his undersigned counsel, moves this Court to compel the production of documents front Defendant, a J. S (a") and to amend and ER a protective order relating to a subpoena to the Bankruptcy Trustee. The grounds for this are as follows:
- 1. On April 12 010 pstein sent a Request to Produce tos requesting the following documents
- 3. All em, correspondence, memos, or similar docut tween Bradley J. , Scott W. Rothstein, William Berger, and Adler ( and/or any attorney or representative of,RRA and any investor or.third party (person or entity) regarding Jeffrey Epstein l ts Jeffrey Epstein (including Mike Fistcn, Kenneth Jenne, or Rick (Rich) Fandrey). . On May 11, 2010, served his response to this request by stating:
- 3. Objection as to communications to or from investigators as that is protected by the work-product and/or attorney-client privilege.
Exhibit A
3. Although Mildid not object to producing all documents requested, he did not produce any documents responsive to this request. Nor did 1MI who asserted privilege, prepare a privilege log related to this request. It is important to note that this request went to documents within and control as opposed to documents that were produced from the Bankruptcy Trustee.
1. 1'he documents requested in 83 were also requested by means of irsubpoena to the Bankruptcy Trustee dated April 17, 2010. After several motions and'orders to'Compel, finally prepared a privilege log relating to communications to and from the investigators among others. However, did not produce any c-mails or documents between the lawyers at RRA and (a) the U.S. Attorneys Office, (b) the State Attorney's Office, (c) the Federal Bureau of Investigation — to which he had not objected and for which he did not claim a privilege on his privilege log.
1. did not produce any documents by and between RRA lawyers or representatives and third parties such as a a reporter, and any other news employees or reporters. Edwards has not identified any communication with reporters on his privilege log.
1. On January 3, 2011, Epstein sent a second subpoena requesting the following documents 'from the Bankruptcy Trustee:
1. --- Any and all email communications by/between any attomcy and/or employee of the former Rothstein law fum, including but not limited to, Scott Rothstein, Adler William Berger, Michael Piston Ken Jenne, David Baden, De or Andrew Barnett L Richard Fan dry, Christina Kitterman, Gary and IM on e one hand, and any of the following regarding Jef rey Epstein:
- a) U.S. Attorney's office;
- b) State of Florida Attorney's Office
- c) Federal Bureau of Investigations;
- d) City of Palm Beach Police Department;
- e) Any investigator working for the State of Florida;
- I) Any attorney, law firm and any agent of any attorney or law finn who icpresented any individual with a claim against Jeffrey Epstein.
7. On April 1, 2011, Epstein sent aRequest to Produce sseeking documents that support a contention that Epstein has waived endmcnt right by speaking to reporters.
1. On May 5, 2011, responded with •ns and claims of privilege. did not prepare aprivilege log even though th ercd him to do so.
1. On July 14, 2011, this Court ent it er granting a Motion for Protective. Order without prejudice minting to the reco c \\ t poena to the Bankruptcy Trustee based loa on scope and relevancy. A copy of th er flecked to this Motion as Exhibit 1.
1. On November •0 • filed his Renewed Motion for Summary Judgment and a lengthy tern of Undisputed Facts in which he purported to identify "summary judgment evidence on which he relied. Such "midi:puled facts" reforunco and/or quote the Palm each olt Incident Report (see 13), correspondence from the U.S. Attorney's Office to see tds, 19, 25), correspondence between the U.S. Attorney's Office and Epst 1 (see 116, 20, 27) to support a' argument that he acted in good faith and taps n "violated his agreement with the U.S. Attorney's Office..." (128). also quotes correspondence from the U.S. Attorney's Office to Epstein's counsel (see 16) specifically in support of his contention that there was a"joint attempt to minimize Epstein's civil exposure."
(Li). also cites from aproposed plea agreement (see '320) in support of his contention that Epstein engaged in witness tampering.
11. has also referred to statements allegedly made by Epstein to areporter in it80.81 of his Undisputed Statement of Facts. contends Epstein's alleged statements to reporters waives his Filth Amendment rights.
01. As a result of relying on communications with-the government and reporters as part of his Renewed Motion for Summary Judgment and to support his contention that Epstein has waived his Fifth Amendment rights by speaking with reporters, discovery is highly appropriate on these issues and should be permitted:
01. Epstein wishes to amend and narrow his request to the Trustee to obtain the following records:
> All c-mails, data, correspondence, and similar documents dated A ril 1, 2008 through August 1, 2010 by and between J. Scott W. Rothstein, Marc Nurik, Cara Mike Fisten an any one of the following regarding or mentioning Jet rey Epstein in any way: (a) the U.S. Attorney's Office, (b) the State Attorney's Office, (c) the Federal Bureau of Investigation, ( Conchita MS and (c) any other news employees or reporters.
14. The dqrcribed documents are not privileged, so no in camera review is necessary. Epstein's request has been narrowed so that compliance and production are not overly broad or burdens' Th request is relevant and necessary in order for Epstein to defend la Rene Ion for Summary Judgment, including ME' contention that Epstein has war his Fifth Amendment rights by discussions and communications with media, news employees or reporters.
01. Based on the above, Epstein requests the following relief:
a. An Order directing [REDACTED] to produce the above-described records that are in his possession and control;
b. An Order directing the Bankruptcy Trustee to produce the records described above and amending the prior protective order so as to allow the Bankruptcy Trustee to produce the records described above; and
c. That the Order contain a specific deadline for compliance. Epstein requests compliance within twenty (20) days of the date of the Order so as to allow time for any additional discovery in advance of Rothstein's deposition and in advance of the hearing on [REDACTED] Renewed Motion for Summary Judgment.
16. The undersigned counsel certifies that he has and will continue to attempt to resolve this matter with counsel for Edwards without the need of a hearing.
WHEREFORE, Plaintiff, JEFFREY EPSTEIN, requests the Court grant its Motion to Compel and Amend Protective Order for the reasons set forth above.
Respectfully submitted,
Joseph L. Ackerman, Jr.\
Florida Bar No. 235954
[REDACTED] BURNETT, P.A.
901 [REDACTED] Point West
777 South Flagler Drive
West Palm Beach, Florida 33401
Telephone: (561) 802-9044
Facsimile: (561) 802-9976
and
[REDACTED] E. Knight
Florida Bar. No. 607363
Epstein v. Rothstein and Case No. 502009CA040800=CMB/Div. AG Epstein's Motion to Compel and Amend Protective Order
BURNEIT, P.A.
Espirito Santo Plaza, 14th Floor 1395 Briekell Avenue Miami, Florida 33131 Telephone: (305) 789-9200 Facsimile: (305) 789-9201 Attorneys for PI ai ntiffJeffrey Epstein
# CERTIFICATE OF SERVICE
IHEREBY CERTIFY that atrue and correct copy of the foregoing was sent via U.S. Mail on this 91h day of March, 2012 to: Jack Scatrola, Esq., Searcy:Denney Scarab Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Attcrbuty, Goldberger & Weiss, PA., 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401-5012; and Marc S. q., Law Offices of Marc S. Nurik, One East Browanl Blvd., Suite 700, Fort Laude 01.
IL:Ackerman, Jr.
IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT\
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION AG\
CASE NO. 502009CA040800XXXXMB\
Judge David F. [REDACTED]
JEFFREY EPSTEIN,
Plaintiff/Counter-Defendant,
v.
SCOTT ROTHSTEIN, individually, and\
[REDACTED] J. [REDACTED] individually,
Defendants/Counter-Plaintiffs.
ORDER ON PLAINTIFF JEFFREY EPSTEIN'S\
MOTION TO COMPEL AND AMEND PROTECTIVE ORDER
THIS MATTER came before the Court on Plaintiff Jeffrey Epstein's Motion to Compel and Amend Protective Order in the above-styled case. This Court having reviewed the Motion, having heard argument of counsel, and being otherwise fully advised in the premises, it is hereby
ORDERED AND ADJUDGED as follows: The Motion seeks to Compel a Request to Produce and to modify this Court's prior Protective Order in regard to specific requests of the Defendant [REDACTED]. In addition, the Motion seeks authority to direct a subpoena to the Bankruptcy Trustee of the former law firm of the Defendants [REDACTED] and ROTHSTEIN. The Court finds that the Amended Request for Production and request for subpoena, does request documents which the Court finds are either relevant and/or reasonably calculated to lead to admissible evidence. Therefore, within twenty (20) days of the date of this Order, the Defendant [REDACTED] shall produce any non-privileged documents as identified in Paragraph 13 of [REDACTED] Motion to Compel and Amend Protective Order. In addition, the Plaintiff El [REDACTED] is given authority to issue a subpoena to the Bankruptcy Trustee requesting the identical documents that are non-privileged.
Nothing in this Order shall constitute any waiver or ruling upon any privilege that may apply to said documents and the Defendant [REDACTED] and/or others may file an objection to any such documentation on any privilege grounds and shall file a privilege log specifically identifying such documents.
Epstein v. Rothstein and [REDACTED]\
Case No. 502009CA040800XXXXXMB/Division AG\
Order on Epstein's Motion to Compel and Amend Protective Order\
Page 2 of 2
DONE AND ORDERED in [REDACTED] at West Palm Beach Palm Beach County, Florida\
this \_\_\_\_\_ day of April, 2012.
**SIGNED AND DATED**\
APR 10 2012\
JUDGE DAVID F. CROW
HONORABLE DAVID F. [REDACTED]\
CIRCUIT JUDGE
Copies furnished to:
[REDACTED] L. Ackerman, Jr., Esq.\
[REDACTED] Burnett, P.A.\
901 [REDACTED] Point West\
777 South Flagler Drive\
West Palm Beach, FL 33401
Lilly Ann [REDACTED], Esq.\
The L.S Law Firm\
Four Seasons Tower, 15th Floor\
1441 Brickell Avenue\
Miami, FL 33131
Jack Scarola, Esq.\
Scarcy 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, South, Suite 1400\
West Palm Beach, FL 33401-5012
Marc S. Nurik, Esq.\
Law Offices of Marc S. Nurik\
One E. Bro [REDACTED] Blvd., Suite 700\
Fort Lauderdale, FL 33301
[REDACTED] J. [REDACTED], Esq.\
[REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman, P.L.\
425 North Andrews Avenue, Suite 2\
Fort Lauderdale, FL 33301
JEFFREY EPSTEIN,
Plaintiff,
VS.
scorr ROTHSTEIN individually, and J. individually.
Defendants.
I
IN THE CIRCUIT COURT OF THE FIFTEENTII JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY. FLORIDA
CASE NO. 502009CA040800W Ait MBAG
AS
O.
# PLAINTIFF'S MOTION TO COMPEL DISCOVER iIONSES AND FOR SANCTIONS
Plaintiff-Jeffrey Epstein, by and through his undersigned counsel and pursuant to Rule 1.380 of the Florida Rules ofCivil Procedure, hereby moves this Court to enter an order compelling the Defendant Bradley Edwards, yet again, to provide responses to Plaintiffs Request for Production. -Plaintiff likewise requests that this Court order sanctions against Defendant Edward's tor his direct and flagrant disregard of this Court's previous Order dated April 10.201?. In support thereof, Plaintiff states:
#### INTRODUCTION
On March 9, 2012, Plaintiff Epstein served upon Defendant a Motion to Compel and to Amend and Lift a Protective Order. A true and correct copy of Plaintiff's Motion is attached hereto as "Exhibit A." On April 10, 2012, this Court entered an Order on Plaintiff's Motion to Compel, stating that "within twenty (20) days of the date of this Order, the Defendant shall produce any non-privileged documents as identified in Paragraph 13 of [sic] Motion to Compel and Amend Protective Order." See Order entered April 10, 2012, a true and correct copy of
which is attached hereto as "Exhibit B." The Order further avowed that Inlothing in this Order shall constitute any waiver or ruling upon any privilege that may apply to said documents and the Defendant and/or others may file an objection to any such documentation on any privilege grounds and shall file aprivilege log specifically identjring such documents." See Exhibit B (emphasis added). Accordingly, •all responses were due on or before April 30, 2012.
On May 9, 2012, Plaintiff received Defendant untimely response to the afore-referenced Request to Produce. A perfunctory re 'ew f the items provided by linestablishes that his response is incomplete d c • nt. NM response contains nothing more than partial electronic mt lions between himself and three or four of the countless reporters a had communications during the relevant time period. Further, Dc ponse irrefutably corroborates that he wholly disregarded this Court OAccordingly, Defendant has failed to comply with this Court's Order to roducc the items responsive to Plaintiff's Request to Produce, as well as any, opportunity afforded to him therein to provide any privilege log with respect t afore-refcrenced request. As such, and as demonstrated more fully below, P quested order is warranted.
### MEMORANDUM OF LAW
This Court has the authority to rule on this Motion without Oral Argument. See First Clip Developments of Florida. Err. it hallmark of Hollywood Condominium Assin. 545 So. 2d 502 (Fla. 4th DCA 1989). Defendant was Ordered by this Court to provide
[a]ll e-mails, data, correspondence. and similar documents dated April 1, 2008 W. through August I, 2010 by and between J. Scott Rothstein, Marc, Nurik, Cam Mike sisten and any on of he following regarding or mentioning Je my Epstein in any way: (a) the U.S. Attorney's Office, (b) the State Attersis Office, (c) the Federal Buau re of Investigation, (d) and (c) any other news employees or reporters.
See Exhibit A. This Court also permitted Defendant to assert •cnvt grounds and "file a privilege log specifically identifying such docume s. .xhibit 13. not only failed to provide the items requested, but a o fai to provide a privilege log as mandated. It is well-settled law that if arty alleges that information requested from it is protected by privilege, then a p al e og must be prepared and c SISe attached to the response, or the privilege is iv Sce TIC? Insurance Corp. of America is all. 799 So. 2d 339 (Fla. 001) (stating that failure to provide areason for privilege and prepare log constitutes waiver of the privilege) (emphasis added).
Here, fai to eit respond to the Request to Produce or assert any privilege as Court o ercil. court has the inherent power to implement and enforce b ooty effective judicial procttedings pursuant to pretrial rules. As such, when aparty fails to comply wi < apretrial order, a court has broad discretion in determining sanctions. First Coq). of America v. Hayes, 431 So. 2d 624 (Fla. 3d DCA 1983). Rule 1.38 of the Florida Rules if Civil Procedure provides that "fflor purposes of this subdivision an evasive or incomplete answer shall be treated as a failure to answer." RA. R.Civ. P. 1.380(3). This Rule likewise governs failure to comply with a prior court order and mandates that such failure "may be considered acontempt of the court"
FLA. R.CIV. P. 1.380(b). Accordingly, Defendant [REDACTED] inapposite and patent disregard for this Court's Order mandates sanctions.
Finally, Plaintiff certifies that he "in good faith, has conferred or attempted to confer with the person or party failing to make the discovery in an effort to secure the information or material without court action." FLA. R.CIV. P. 1.380. A true and correct copy of the correspondence sent to Defendant [REDACTED] regarding this Motion is attached hereto as "Exhibit C." Pursuant to Rule 1.380 of the *Florida Rules of Civil Procedure*, Epstein is entitled to reasonable attorney's fees necessitated by Defendant's flagrant disregard of both this Court's Order and the afore-referenced Rules of Civil Procedure.
### CONCLUSION
Accordingly, for all of the reasons delineated above and in reliance upon the applicable law cited herein, Plaintiff Jeffrey Epstein respectfully requests that this Court, yet again, Order Defendant [REDACTED] to respond in full to Plaintiff's Request to Produce, a [REDACTED] attorney's fees as sanctions, and such other and further relief as this Court deems proper.
Tonja Haddad Coleman, Esq.\
Fla. Bar No.: 0176737\
LAW OFFICES OF TONJA HADDAD, PA\
524 South Andrews Avenue\
Suite 200N\
Fort Lauderdale, Florida 33301\
954.467.1223\
954.337.3716 (facsimile)\
Tonja@tonjahaddadpa.com
WE I IEREBY CERTIFY that a true and correct copy of the foregoing was served upon all parties listed on the attached service list, via facsimile and US Mail, this May 15.2012.
> Tonja Haddad Coleman, Esq. Fla. Bar No.: 0176737
# ' SERVICE LIST.
CASE NO. 502009CA040800XXXXMBAG
Jack Scarala, Esq. Searcy Denney Scarola et ul. 2139 Palm Beach Lakes Blvd. WCSt Palm Beach, FL 33409
Jack Goldberger, Esq. Atterbuty. Goldberger, & Weiss, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL 33401
Marc Nurik, Esq. 1 East Broward Blvd. SUite 700 Foil Lauderdale, FL 33301
J.\_, C Jaffe Wcissing Fisto 425 N Andrews Avenue Suite 2 Fort Lauderdale, Florida 333
Lilly Ann.., Esq. LS Law Firm Four Seasons Tower 15th Floor 1441 Bricke Miami. F
IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT\
IN AND FOR PALM BEACH COUNTY, FLORIDA
CIVIL DIVISION AG\
CASE NO. 502009CA040800XXXXMB\
Judge David F. [REDACTED]
JEFFREY [REDACTED]
Plaintiff/Counter-Defendant,
v.
SCOTT ROTHSTEIN, individually, and\
[REDACTED] J. [REDACTED], individually,
Defendants/Counter-Plaintiffs.
**ORDER ON PLAINTIFF JEFFREY EPSTEIN'S\
MOTION TO COMPEL PRODUCTION OF DOCUMENTS FROM\
DEFENDANT BRADLEY EDWARDS AND FOR SANCTIONS**
THIS MATTER came before the Court on Plaintiff Jeffrey Epstein's Motion to Compel Production of Documents from Defendant [REDACTED] and for Sanctions in the above-styled case. This Court having reviewed the Motion, having heard argument of counsel, and being otherwise fully advised in the premises, it is hereby
ORDERED AND ADJUDGED as follows: The Defendant\
Bradley Edwards shall within 30\
days of the date of this order file\
a more complete privilege log. The Court\
finds The privilege log is insufficient on its\
face and does not comply with the requirements\
of F.B.I.P. 1.280(b)(5) and TIG Ins. Corp. v.\
Johnson, 799 Suzd 339 (Fla. 4th Dec 2001). In
Epstein v. Rothstein and [REDACTED]\
Case No. 502009CA040800XXXXXMB/Division AG\
Order on Epstein's Motion to Compel and for Sanctions\
Page 2 of 2
\~~all other respects the Motion is denied at this\
DONE AND ORDERED in [REDACTED] at West Palm Beach, Palm Beach County, Florida~~\
this 7th day of April, 2012.
*may*
Copies furnished to:
Joseph L. Ackerman, Jr., Esq.\
Fowler White Burnett, P.A.\
901 Phillips Point West\
777 South Flagler Drive\
West Palm Beach, FL 33401
Lilly Ann [REDACTED], 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, South, Suite 1400\
West Palm Beach, FL 33401-5012
Marc S. Nurik, Esq.\
Law Offices of Marc S. Nurik\
One E. Broward Blvd., Suite 700\
Fort Lauderdale, FL 33301
[REDACTED] J. [REDACTED], Esq.\
Farmer, Jaffe, Weissing, [REDACTED], Fistos & Lehrman, P.L.\
425 North Andrews Avenue, Suite 2\
Fort Lauderdale, FL 33301
IN THE CIRCUIT COURT OF THE\
FIFTEENTH JUDICIAL CIRCUIT, IN AND\
FOR PALM BEACH COUNTY, FLORIDA
CASE NO.: 502009CA040800XXXXMBAG
JEFFREY EPSTEIN,
Plaintiff(s),
vs.
SCOTT ROTHSTEIN, individually,\
[REDACTED] J. [REDACTED], individually, and\
L.M., individually,
Defendant(s).
2012 AUG 17 PM 3:41\
FILED\
CIRCUIT CIVIL S.F.L.\
PALM BEACH COUNTY, FL\
SCOTT ROTHSTEIN, JR.
ORDER ON OUTSTANDING DISCOVERY MOTIONS
THIS CAUSE having come to be considered on August 3, 2012, on outstanding discovery motions, and the Court having reviewed the file and being fully advised in the premises, it is hereby,
ORDERED and ADJUDGED that EDWARDS' Motion for Clarification is GRANTED, and this Court's Order of [REDACTED] by 7, 2012 is vacated without prejudice. [REDACTED] shall file a written response specifically addressing the production sought in Paragraph 13 of [REDACTED] Motion to Compel and Amend Protective Order of March 9, 2012 as Ordered in this Court's April 10, 2012 Order. The response shall identify non-privileged responsive documents previously produced, shall be accompanied by all non-privileged responsive documents not previously produced, if any, and shall identify, in a proper privilege log as referenced in this Court's May 7, 2012 Order, responsive documents withheld from production on the basis of any assertion of privilege. This response shall be filed within 10 days from the date of this Order.
adv. Epstein Case No.: 502009CA040800XXXXMBAG Order on Outstanding Discovery Motions
DONE AND ORDERED at West Palm Beach, Palm Beach County, Florida, this n 71\` day of ,20I2.
> DA CIRCUIT JUD
Copies have been furnished to all counsel on the attached couta D.
[REDACTED] adv. Epstein\
Case No.: 502009CA040800XXXXMBAG\
Order on Outstanding Discovery Motions
COUNSEL LIST
Jack A. Goldberger, Esquire\
jgoldberger@agwpa.com;\
smahoney@agwpa.com\
Atterbury, Goldberger & Weiss, P.A.\
250 Australian Avenue South, Suite 1400\
West Palm Beach, FL 33401\
Phone: (561)-659-8300\
Fax: (561)-835-8691
[REDACTED] J. [REDACTED] Esquire\
brad@pathtojustice.com\
[REDACTED] Jaffe, Weissing, [REDACTED] Fistos &\
Lehrman, FL\
425 North Andrews Avenue, Suite 2\
Fort Lauderdale, FL 33301\
Phone: (954)-524-2820\
Fax: (954)-524-2822
Marc S. Nurik, Esquire\
marc@nuriklaw.com\
One E Broward Blvd., Suite 700\
Fort Lauderdale, FL 33301\
Phone: (954)-745-5849\
Fax: (954)-745-3556
Tonja Haddad Coleman, Esquire\
tonja@tonjahaddadpa.com\
524 S Andrews Avenue, Suite 200N\
Fort Lauderdale, FL 33301\
Phone: (954)-467-1223\
Fax: (954)-337-3716
Lilly Ann [REDACTED] Esquire\
lsanchez@thelsfirm.com\
The L-S Law Firm\
1441 Brickell Avenue, 15th Floor\
Miami, FL 33131\
Phone: (305)-503-5503\
Fax: (305)-503-6801
Jack Scarola, Esquire\
Searcy Denney Scarola Barnhart & Shipley\
2139 Palm Beach Lakes Boulevard\
West Palm Beach, FL 33409\
Phone: 561-686-6300\
Fax: 561-383-9451\
Attorneys for [REDACTED]
NOT A CERTIFICATE OF COPY
#### Privilege Lop, - Dated 2-23-2011
Jaffe. Welssin Fistos & Lehrman
| | DATE | TO | FROM | DESCRIPTION | OBJECTION |
| ----------- | ---------- | ---------------- | ------------------- | ----------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------- |
| | | | | | not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 19856 | 10/17/2009 | Mike Fisten | Mike Fisten | Investigation into Epsteln's planes | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 20888 | 09/12/2009 | Adler | Adler | Potential New witnesses | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 20946 | 05/11/2009 | Attorneys at RRA | Attorneys at RRA | Investigation into Epsteln's planes | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 05807-05810 | 07/23/2009 | Attorneys at RRA | Priscila Nascimento | Conference room reserved | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 05262-05263 | 07/22/2009 | Jacquie Johnson | Jacquie Johnson | Investigator information | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 25829 | 05/11/2009 | Bradley Edwards | William Berger | Motion to unseal criminal records | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 25830-25831 | 05/11/2009 | Attorneys at RRA | Attorneys at RRA | Investigation into Epsteln's planes | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 25811-25813 | 05/11/2009 | Attorneys at RRA | Attorneys at RRA | Investigation into Epsteln's planes | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence |
# Jaffe, Welssin Fistos & Lehrman
| | DATE | TO | FROM | DESCRIPTION | OBJECTION |
| ----------- | ---------- | ------------------ | ------------- | ------------------------------------------------------ | ----------------------------------------------------------------------------------------------------------------------------------------------------- |
| | | | | | privacy rights |
| 18174-18176 | 08/24/2009 | Ken Jenne | Mike Fisten | Epstein Probation | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 18172-18173 | 08/24/2009 | Mike Fisten | [REDACTED] | Epstein Probation | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 18170 | 08/24/2009 | [REDACTED] | Mike Fisten | Epstein Probation | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 03106 | 06/03/3009 | [REDACTED] | Shawn Gilbert | Epstein Case Info | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 02593-02594 | 05/13/2009 | [REDACTED] | Shawn Gilbert | Discussion with secretary regarding client information | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 08014 | Undated | Unknown Staff | [REDACTED] | Miscellaneous case info | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 27494 | 10/23/2009 | Attorneys at RRA | Mike Fistos | Legal Research RE: Causes of action against Epstein | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 18166-18167 | 08/04/2009 | Bradley [REDACTED] | Mike Fisten | Copperfield Depo | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
=, Jaffe, Weissing,S Fistos &Lehrman
| | DATE | TO | FROM | DESCRIPTION | OBJECTION |
| ----------- | ---------- | ---------------- | ------------------ | --------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------- |
| | | | | | discovery of admissible evidence; protected by privacy rights |
| 25815-25822 | 06/01/2009 | William Berger | [REDACTED] | Depo information | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 18358-18359 | 07/24/2009 | [REDACTED] | Ken Jenne | Investigation into Epstein's planes | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 05382 | 09/12/2009 | [REDACTED] | Mike Fisten | Potential new witnesses | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 08033-08070 | 10/23/2009 | Attorneys at RRA | Mike Fistos | Legal Research RE: Causes of action against Epstein | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 25997 | 10/23/2009 | Scott Rothstein | [REDACTED] Adler | Legal Research RE: causes of action against Epstein | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 26741-26763 | 10/23/2009 | Attorneys at RRA | Bradley [REDACTED] | Legal Research RE: causes of action against Epstein | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 25774-25777 | 05/12/2009 | Bradley Edwards | Susan Stirling | Filed Motions | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 18177-18179 | 08/24/2009 | Ken Jenne | [REDACTED] | Epstein Probation | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by |
# Jaffe, Weissinp" Fistos & Lehrman
| NO. | DATE | TO | FROM | DESCRIPTION | OBJECTION |
| ----------- | ---------- | ----------------------------- | ------------------ | --------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------- |
| 18164-18165 | 08/03/2009 | [REDACTED] | Mike Fisten | Copperfield Depo | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 18771-18773 | 04/27/2009 | Marc Nurik | [REDACTED] | Legal Research RE: causes of action against Epstein | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 18742-18744 | 09/10/2009 | Jacquie [REDACTED] | [REDACTED] | Dershowitz Depo | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 18737-18741 | 09/10/2009 | Jacquie [REDACTED] | [REDACTED] | Depo technicalities | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 20263-20282 | 10/14/2009 | Pat [REDACTED]
Mike Fisten | Ronald Wise | Vehicle Registrations-Visoski | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 20219-20262 | 10/14/2009 | Pat [REDACTED]
Mike Fisten | Ronald Wise | Visoski Research & Questions | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 17225-17230 | 07/22/2009 | Bradley Edwards | Jacquie [REDACTED] | Wayne Black Retainer | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 17038-17040 | 10/29/2009 | Cara [REDACTED] | Jacquie [REDACTED] | RE: Subpoenas for Epstein's attorneys | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 16916-16928 | 10/19/2009 | [REDACTED] | Jacquie [REDACTED] | Witness List | W/P; Attorney Client Privilege; Irrelevant and |
# Jaffe, WeIssing, Fistos& Lehrman
a I
| MI | DATE | TO | FROM | DESCRIPTION | OBJECTION |
| ----------- | ---------- | ----------------- | -------------------- | ----------------------------- | -------------------------------------------------- |
| | | | | | lead to the discovery of admissible |
| 13315 | 08/03/3009 | Denis Kleinfeld | Beth Williamson | Litigation Strategy | |
| | | | | | Work Product;attorney client |
| | | | | | lead to the discovery of admissible |
| 01080-01081 | 06/22/2039 | | | | |
| | | Robert C. Buschel | | Jane Doe brother | Attorney/Client privilege and/or work product |
| 01077 | 05/28/2009 | Robert C. Buschel | | | |
| | | | Bradley J. | Doe family member | Attorney/Client privilege and/or work product |
| 0244502446 | 05/05/2009 | | J. Susan K. Stirling | at Atlantic asphalt | |
| 03049 | 09/21/2009 | | J. U.F. | New addition tot | case Attorney/Client privilege and/or work product |
| 02425-02426 | 06/17/2009 | Susan K. Stirling | J. | Jane Doe v. Dukenik | Attorney/Client privilege and/or work product |
| 02669 | 09/24/2009 | | I. Jacquie | Subpoena for Adriana Muclnska | |
| 02647 | 08/06/2009 | Mike Fisten | | Samantha Lee | info Attorney/Client privilege and/or work product |
| 03688-03691 | 04/03/2009 | Robin | T. | | |
| | | | | Case number assignments | Attorney/Client privilege and/or work product |
| 03692-03693 | 05/06/2009 | | J. Susan K. Stlrline | Case list | Attorney/Client privilege and/or work product |
| 1567845680 | 09/29/2009 | Jacqule | Bradley J. | Subpoena for Adriana | Attorney/Client privilege and/or work product |
| 15689 | 10/01/2009 | Jacqule | J. | Client information | Attorney/Client privilege and/or won( product |
| 02546-02547 | 09/22/2009 | D.F. | Bra cy J. | Client communication | Attorney/Client privilege and/or work product |
| 02809-02810 | 09/28/2009 | N.R. | | Client communication | Attorney/Client privilege and/or work product |
| 02262 | 07/23/2009 | Jacqule Johnson | J. | Discussion re: | client/victim |
| 02807-02808 | 10/01/2009 | N.R. | 1. | Client communication | Attorney/Client privilege and/or work product |
| 03760-03828 | 04/01/2009 | %FtA Ptrsonnel | A personne | Client names/types of action/ | |
| 03759 | 04/01/2009 | Russell Adler | | | |
| 08358-08359 | 09/14/2009 | Pat | | Client Info | Attorney/Client privilege and/or work product |
# Jaffe, WeissIn Fistos & Lehrman
'❑ I ,P1
a
| | DATE | TO | FROM | DESCRIPTION | OBJECTION |
| ----------- | ---------- | ------------------ | -------------------- | ------------------------------------------------------------------------- | ----------------------------------------------------------------------------------------------------------------------------------------------------- |
| | | | | | privacy rights |
| 05295-05297 | 07/23/2009 | Attorneys at RRA | Priscilla Nascimento | RE: Epstein Conference Room Reserved | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 05298 | 08/03/2009 | Mike Fisten | [REDACTED] | Discussion of Epstein strategy | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 05261 | 07/23/2009 | Amy Swan | [REDACTED] | Victim Psychological Assessment | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 18358-18359 | 07/24/2009 | [REDACTED] | Ken Jenne | Investigation into Epstein's planes | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 04431-04432 | 08/14/2009 | Jacquie [REDACTED] | Bradley Edwards | RE: Epstein-Maxwell Subpoena | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 04419-04420 | 04/09/2009 | [REDACTED] Edwards | Paul Cassell | RICO Statement | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 04403-04416 | 10/17/2009 | Paul Cassell | [REDACTED] | Punitive Damages | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
| 04387-04402 | 08/19/2009 | Paul Cassell | [REDACTED] | Victim Complaints, Forensic accountants, & Epstein's Fraudulent Transfers | W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights |
Jaffe Weissing, Fistos & Lehrman
| | DATE | TO | FROM | DESCRIPTION | OBJECTION | | | |
| ----------- | ---------- | --------- | --------------- | ----------------------------- | --------- | -------- | --------------- | ---------- |
| 04893.04896 | 09/10/2009 | Jacquie | | Epstein Discovery | Work | product; | attorney/client | privilege; |
| 04890 | 09/10/2009 | lacquie | | Epstein Discovery | Work | product; | attorney/client | privilege; |
| 04884.04885 | 09/10/2009 | | lacquie | Epstein Discovery | Work | product; | attorney/client | privilege; |
| 01469 | 07/17/2009 | Ken Jenne | | Discussions about the Epstein | | | | |
| | | | | | Work | product; | attorney/client | privilege; |
| 04745.04747 | 08/04/2009 | | lacquie | Epstein depo in New York | Work | product; | attorney/client | privilege; |
| 04738-04744 | 08/25/2009 | | Paul Cassell | Hearing regarding the Epstein | | | | |
| | | | | | Work | product; | attorney/client | privilege; |
| 04660 | 10/22/2009 | | | | | | | |
| | 4 | t | | | | | | |
| | | | Marc Nurik | Epstein AUSA— Attorneys Fees | Work | product; | attorney/client | privilege; |
| 04642-04646 | 09/11/2009 | | Beth Williamson | Discussions about Brad's | | | | |
| | | | | | Work | product; | attorney/client | privilege; |
# Jaffe. Weissin Fistos & Lehrman
k..o
| | DATE TO | FROM | DESCRIPTION | | OBJECTION |
| ---------------------- | -------------------------- | ------------------- | ----------------------- | ----------- | ----------------------------------------------------- |
| 05693-05695 | 05/28/2009 | Confidential Source | Litigation Strategy | | W/P Priv.; not reasonably calculated to lead to |
| 05698 | 08/21/2009 | ConfidentialSource | Litigation Strategy | | A., 1 W/P Priv.; not reasonably calculated to lead to |
| 05706-05709 | 05/28/2009 | Confidential Source | Litigation Strategy | | N.., W/P Priv.; not reasonably calculated to lead to |
| 05720-05721 05/29/2009 | | Confidential Source | Providing New Witnesses | | W/P Priv.; not reasonably calculated to lead to |
| 05738-05739 | 05/29/2009 | ConfidentialSource | Providing New Wit | ses | W/P Priv.; not reasonably calculated to lead to |
| 05743.05745 | 05/29/2009 | Confidential Source | Litigation Strategy | | W/P Priv.; not reasonably calculated to lead tc |
| 05754 | 08/03/2009 | Confidential Source | Litigation Strategy | | W/P Priv.; not reasonably calculated to lead to |
| 05759-05762 | 06/01/2009 | Confidential Source | Providing New Witnesses | | W/P Priv.; not reasonably calculated to lead to |
| 05765-05768 | 06/23/2009 | ConfidentialSoyike | | | |
| | | | Litigation Strategy | | W/P Priv.; not reasonably calculated to lead to |
| 0577105773 | 06/03/2009 | Confidential Source | Additional | Information | RE: |
| 05777-05779 | 06/03/2009 | Confidential Source | Additional | Information | RE: |
| 05784-05786 | 06/03/2009 Bradley Ed -s | Confidential Source | Providing New Witnesses | | W/P Priv.; not reasonably calculated to lead to |
| 05791-05794 | 06/03/2009 Bradley Edwards | Confidential Source | Additional | Information | RE: |
| 05803 | 07/22/2009 12/ e96/ | Confidential Source | Litigation Strategy | | W/P Priv.; not reasonably calculated to lead to |
| 05836-05837 | 07/08/2009 Eiradley | Confidential Source | Litigation Strategy | | W/P Priv.; not reasonably calculated to lead to |
| 05842-05843 | 07/08/2009 | Confidential Source | Providing New Witnesses | | W/P Priv.; not reasonably calculated to lead to |
# Jaffe Weissin Fistos & Lehrman
| | DATE TO | FROM | DESCRIPTION | OBJECTION |
| ---------------------- | -------------------------- | --------------------------- | ---------------------------- | ----------------------------------------------- |
| 05848 | 07/28/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 05852.05853 | 07/29/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 05857-05858 | 07/31/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 05952-05953 | 08/25/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 06192-06197 | 06/23/2009 | Confidential Source | Secret Plea Deal For pstein | |
| 06198-06201 06/24/2009 | Confidential | | | |
| | | | Secret Plea Deal For Epstein | W/P Pdv.; not reasonably calculated to lead to |
| 06203 | 07/23/2009 | Confidential Source | LitigaX Strategy | W/P Priv.; not reasonably calculated to lead to |
| 06401 | 09/23/2009 | Confidential Source | Provlkg New Witnesses | W/P Priv.; not reasonably calculated to lead to |
| 06643-06651 09/17/2009 | | Confidential Source | litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 06788.06789 | 09/28/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonabiy calculated to lead to |
| 06942-06943 | 09/26/2009 Confidential | | | |
| | | | Additional Information | RE: |
| 06953 | 08/14/2009 | Edwards Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 06955-06957 | 10/02/2009 Bradley Edwards | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 06959-06961 | 08/11/2009 Bradley Edwards | Confidential Source | Secret Plea Deal For Epstein | W/P Priv.; not reasonably calculated to lead to |
| 06963.06980 | 08/11/2009 | | | |
| | Bradley | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 06986-06989 | 10/03/2009 | Confidential Source | Secret Plea Deal For Epstein | W/P Priv.; not reasonably calculated to lead to |
| 07010-07014 | 10/04/2009 | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
# Jaffe, Weissin Fistos & Lehrman
| | DATE | TO | FROM | DESCRIPTION | OBJECTION |
| ----------- | ----------- | ---------------- | ------------------- | ------------------------ | ----------------------------------------------- |
| 07017-07018 | 09/04/2009 | Confidential | | | |
| | | | | Providing New Witnesses | W/P PrIL; not reasonably calculated to lead to |
| 07143-07144 | 10/01/2009 | Confidential | | | |
| | | | | Litigation Strategy 114/ | W/P Priv.; not reasonably calculated to lead to |
| 07147-07150 | 09/18/2009 | | Confidential Source | Providing New witnesses | W/P Priv.; not reasonably calculated to lead to |
| | 10/13/2009 | Confidential | | | |
| | | | | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 07605-07615 | 09/07/2009 | | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 07646-07647 | 09/08/2009 | | Confidential Source | ProvIdi / nittaWitnesses | W/P Priv.; not reasonably calculated to lead to |
| 07674-07697 | 09/08/2009 | | Confidential Source | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to |
| 08376 | 10/04/2009 | Confidential | | | |
| | | | | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to |
| 08380 | 09/18/2009 | | Con Source | | |
| | | | / -A• | | |
| | | | | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 08427-08430 | 09/24/2009 | | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 08450 | 05/17/2009 | Edwards | Confidential Source | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to |
| 08507 | 10/03/2009 | Bradley Ed.'s | Confidential Source | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 10092-10098 | 08/31/2009 | Bradley Edwards | Confidential Source | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to |
| 01610 | 06/03/3009 | Is 'Confidential | | | |
| | | | | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 01612 | 06/0.4/2009 | Confidential | | | |
| | | | | Litigation Strategy | W/P Priv.; not reasonably calculated to lead to |
| 01451-01458 | 05/27/2009 | Confidential | | | |
| | | | | Providing New Witnesses | W/P Priv.; not reasonably calculated to lead to |