Draft: efta02777198

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.

4. 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.

5. 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.

6. On January 3, 2011, Epstein sent a second subpoena requesting the following documents 'from the Bankruptcy Trustee:

7. --- 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.

8. On May 5, 2011, responded with •ns and claims of privilege. did not prepare ^aprivilege log even though th ercd him to do so.

9. 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.

10. 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.

12. 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:

13. 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.

15. 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 15^th 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, 15^th 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 SIS^e 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 15^th 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 7^th 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, 15^th 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