EFTA01248250.pdf
ftradle I.dv.ads
Direct C•7266
kActimis wrra-lav,.com
Rothstein Rosenfeldt Adler
Attorneys at Law
August 4, 2009
Via Fedex
And First Class Mail
Alfredo Rodri uez
Re: Jane Doe v. Epstein,
Our File No. 09-22784
Dear Mr. Rodriguez,
During the first part of your deposition you indicated that you would be able to
locate some documents and information to bring to the continuation of your deposition
scheduled for this Friday, August 7, 2009. Some of those things were:
• Your journals, logs, notes or personal memos that reflect the names and
phone numbers of the girls ("masseuses") that visited the house;
• The cards from the investigators that visited you on various occasions;
• Names/numbers of the cab companies or drivers used to take the girls to and
from the house;
• Name and address of Epstein's company that paid you your salary;
• Leslie Groffs address and/or phone number;
• Name of the girl that took care of the pool;
• List of all clubs where Epstein was a member;
Repay To Las Olds City Centre • 401 East Laa Olas Boulevard • Suite 1650 • FOP Lauderdale. Ronda 33301 Telaptiont (954) 512-3456 • Fax )954;527.9662
BOCA RATON • FORT LAUDERDALE • MIAMI • NEW YORK CITY • TALLAHASSEE • WASHINGTON CI C. • WEST PALM BEACH
WWW.I .CO111
3501.183-055
Page I of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00094609
EFTA01248250
' November 9, 2009
Page 2 of 3
• Full name, address and phone number for ancEn New York;
• Any copies of message pads or schedules;
• The confidentiality agreement;
• Copy of the house manual;
• Copies of documents reflecting banks where Epstein had accounts; and
• Names of any of Epstein's businesses.
Please bring whatever other related information that you have. I appreciate your
cooperation in this regard.
Very Truly Yours,
ROTHSTEIN ROSENFELDT ADLER
Bradley J. Edwards, Esq.
FOR THE FIRM
BJEfij
1012
3501.183-055
Page .2 of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00094610
EFTA01248251
Pagc 1 of 2
Bradley J. Edwards
From: Alfredo Rodnguez
Sent: Monday. August 10. ZUO9 1 45 PM
To: Bradley J. Edwards
Subject: Re: Epstein
Hello Brad:
I've got the info you need.
I will send it to you as soon as I get back home.
Would you please give me your cell phone number?
Best regards,
Alfredo Rodriguez
--- On Mon, 8/10/09, Bradley J. Edwards > wrote:
From: Bradley J. Edwards
Subject: Epstein
To: "-
Date: Monday, August 10, 2009, 6:51 PM
Hi Alfredo,
I didn't ask your phone number during the deposition, but I'd like to have it in case I have a question. I
was reading back over my notes, and I was wondering if you remembered Epstein's email address or the
name of the computer person from Ohio. Thank you for being so truthful in this case. I know you were in
a tough spot. I wish you well.
Sincerely,
Bradley J. Edwards
Partner
Rothstein Rosenfeldt Adler' Attorneys at Law
Las Olas City Centre
401 East Las Olas Boulevard , Suite 1650
1013
11/8/2009
3501.183-055
Page 3 of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00094611
EFTA01248252
Page 2 of 2
Fort Lauderdale. FL 33301
facsimile
1014
11/8/2009
3501.183-055
Page 4 of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00094612
EFTA01248253
Page 1 of 2
Bradley J. Edwards
From: Bradley J. Edwards
Sent: Tuesday, August 11, 2009 8:43 AM
To: 'Alfredo Rodriguez'
Subject: RE: Epstein
Sure. My cell phone number is My direct line at work I'll wait to hear from you.
Thanks. Take care.
Bradley J. Edwards
Partner
Rothstein Rosenfeldt Adler' Attorneys at Law
Las Olas City Centre
401 East Las Olas Boulevard, Suite 1650
Fort Lauderdale. FL 33301
facsimile
From: Alfredo Rodriguez [mailto:
Sent: Monday, August 10, 2009 :45 PM
To: Bradley J. Edwards
Subject: Re: Epstein
Hello Brad:
I've got the info you need.
I will send it to you as soon as I get back home.
Would you please give me your cell phone number?
Best regards,
Alfredo Rodriguez
-- On Mon, 8/10/09, Bradley J. Edwards <bedwards@rra-law.com> wrote:
From: Bradley J. Edwards
Subject: Epstein
To: '
Date: Monday, August I0, 2009, 6:51 PM
Hi Alfredo,
I didn't ask your phone number during the deposition, but I'd like to have it in case I have a question. I
was reading back over my notes, and I was wondering if you remembered Epstein's email address or the
name of the computer person from Ohio. Thank you for being so truthful in this case. I know you were in
a tough spot. I wish you well.
Sincerely,
Bradley J. Edwards
Partner
1015
11/8/2009
3501.183-055
Page 5 of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_000946 I3
EFTA01248254
Page 2 of 2
Righstein Rosenfeldt Adler' Attorneys at Law
Las Olas City Centre
401 East Las Olas Boulevard . Suite 1650
Fo La derd I FL 33301
facsimile
1016
11/8/2009
3501.183-055
Page 6 of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00094614
EFTA01248255
Page 1 of 2
Bradley J. Edwards
From: Bradley J. Edwards
Sent: Saturday, August 22, 2009 11:23 AM
To: 'Alfredo Rodriguez'
Subject: RE: Epstein
Alfredo,
I have been trying to call you for days and it seems your phone is shut off. Is there a new number where you can
be reached? Give me a call whenever you have a chance. Thanks. Hope all is well.
Sincerely,
Bradley J. Edwards
Partner
Rothstein Rosenfeldt Adler' Attorneys at Law
Las Olas City Centre
401 East Las Olas Boulevard, Suite 1650
Fort Lauderdale, FL 33301
- facsimile
From: Alfredo Rodriguez [mailto
Sent: Monday, August 10, 2009 :.15 PM
To: Bradley 3. Edwards
Subject: Re: Epstein
Hello Brad:
I've got the info you need.
I will send it to you as soon as I get back home.
Would you please give me your cell phone number?
Best regards,
Alfredo Rodriguez
--- On Mon, 8/10/09, Bradley J. Edwards <I > wrote:
From: Bradley J. Edwards <1
Sub'ect: E stein
To:
Dat . , , .
Hi Alfredo,
I didn't ask your phone number during the deposition, but I'd like to have it in case I have a question. I
was reading back over my notes, and I was wondering if you remembered Epstein's email address or the
name of the computer person from Ohio. Thank you for being so truthful in this case. I know you were in
a tough spot I wish you well.
1017
11/8/2009
3501.183-055
Page 7 of9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_000946 IS
EFTA01248256
Page 2 of 2
Sincerely,
Bradley J. Edwards
Partner
Rothstein Rosenfeldt Adler' Attorneys at Law
Las Olas City Centre
401 East Las Olas Boulevard . Suite 1650
Fort Lauderdale, FL 33301
- facsimile
1018
11/8/2009
3501.183-055
Page 8 of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00094616
EFTA01248257
Page I of 1
Bradley J. Edwards
From: Bradley J. Edwards
Sent: Monday. October 19.2009 11:52 AM
To: 'Alfredo Rodriguez'
Subject: Hello
Alfredo,
You have literally fallen off the face of the earth. I hope everything is ok. I want to talk to you. Please call me
ASAP. The number I was reaching you on is no longer good. Please call me when you get this email. Again. I
hope all is well.
Bradley J. Edwards
Partner
Rothstein Rosenfeldt Adler' Attorneys at Law
Las Olas City Centre
401 East Las Olas Boulevard, Suite 1650
FL 33301
facsimile
1019
11/8/2009
3501.183-055
Page 9 of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00094617
EFTA01248258
Direct C•7266
kActimis wrra-lav,.com
Rothstein Rosenfeldt Adler
Attorneys at Law
August 4, 2009
Via Fedex
And First Class Mail
Alfredo Rodri uez
Re: Jane Doe v. Epstein,
Our File No. 09-22784
Dear Mr. Rodriguez,
During the first part of your deposition you indicated that you would be able to
locate some documents and information to bring to the continuation of your deposition
scheduled for this Friday, August 7, 2009. Some of those things were:
• Your journals, logs, notes or personal memos that reflect the names and
phone numbers of the girls ("masseuses") that visited the house;
• The cards from the investigators that visited you on various occasions;
• Names/numbers of the cab companies or drivers used to take the girls to and
from the house;
• Name and address of Epstein's company that paid you your salary;
• Leslie Groffs address and/or phone number;
• Name of the girl that took care of the pool;
• List of all clubs where Epstein was a member;
Repay To Las Olds City Centre • 401 East Laa Olas Boulevard • Suite 1650 • FOP Lauderdale. Ronda 33301 Telaptiont (954) 512-3456 • Fax )954;527.9662
BOCA RATON • FORT LAUDERDALE • MIAMI • NEW YORK CITY • TALLAHASSEE • WASHINGTON CI C. • WEST PALM BEACH
WWW.I .CO111
3501.183-055
Page I of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00094609
EFTA01248250
' November 9, 2009
Page 2 of 3
• Full name, address and phone number for ancEn New York;
• Any copies of message pads or schedules;
• The confidentiality agreement;
• Copy of the house manual;
• Copies of documents reflecting banks where Epstein had accounts; and
• Names of any of Epstein's businesses.
Please bring whatever other related information that you have. I appreciate your
cooperation in this regard.
Very Truly Yours,
ROTHSTEIN ROSENFELDT ADLER
Bradley J. Edwards, Esq.
FOR THE FIRM
BJEfij
1012
3501.183-055
Page .2 of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00094610
EFTA01248251
Pagc 1 of 2
Bradley J. Edwards
From: Alfredo Rodnguez
Sent: Monday. August 10. ZUO9 1 45 PM
To: Bradley J. Edwards
Subject: Re: Epstein
Hello Brad:
I've got the info you need.
I will send it to you as soon as I get back home.
Would you please give me your cell phone number?
Best regards,
Alfredo Rodriguez
--- On Mon, 8/10/09, Bradley J. Edwards > wrote:
From: Bradley J. Edwards
Subject: Epstein
To: "-
Date: Monday, August 10, 2009, 6:51 PM
Hi Alfredo,
I didn't ask your phone number during the deposition, but I'd like to have it in case I have a question. I
was reading back over my notes, and I was wondering if you remembered Epstein's email address or the
name of the computer person from Ohio. Thank you for being so truthful in this case. I know you were in
a tough spot. I wish you well.
Sincerely,
Bradley J. Edwards
Partner
Rothstein Rosenfeldt Adler' Attorneys at Law
Las Olas City Centre
401 East Las Olas Boulevard , Suite 1650
1013
11/8/2009
3501.183-055
Page 3 of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_00094611
EFTA01248252
Page 2 of 2
Fort Lauderdale. FL 33301
facsimile
1014
11/8/2009
3501.183-055
Page 4 of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00094612
EFTA01248253
Page 1 of 2
Bradley J. Edwards
From: Bradley J. Edwards
Sent: Tuesday, August 11, 2009 8:43 AM
To: 'Alfredo Rodriguez'
Subject: RE: Epstein
Sure. My cell phone number is My direct line at work I'll wait to hear from you.
Thanks. Take care.
Bradley J. Edwards
Partner
Rothstein Rosenfeldt Adler' Attorneys at Law
Las Olas City Centre
401 East Las Olas Boulevard, Suite 1650
Fort Lauderdale. FL 33301
facsimile
From: Alfredo Rodriguez [mailto:
Sent: Monday, August 10, 2009 :45 PM
To: Bradley J. Edwards
Subject: Re: Epstein
Hello Brad:
I've got the info you need.
I will send it to you as soon as I get back home.
Would you please give me your cell phone number?
Best regards,
Alfredo Rodriguez
-- On Mon, 8/10/09, Bradley J. Edwards <bedwards@rra-law.com> wrote:
From: Bradley J. Edwards
Subject: Epstein
To: '
Date: Monday, August I0, 2009, 6:51 PM
Hi Alfredo,
I didn't ask your phone number during the deposition, but I'd like to have it in case I have a question. I
was reading back over my notes, and I was wondering if you remembered Epstein's email address or the
name of the computer person from Ohio. Thank you for being so truthful in this case. I know you were in
a tough spot. I wish you well.
Sincerely,
Bradley J. Edwards
Partner
1015
11/8/2009
3501.183-055
Page 5 of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_000946 I3
EFTA01248254
Page 2 of 2
Righstein Rosenfeldt Adler' Attorneys at Law
Las Olas City Centre
401 East Las Olas Boulevard . Suite 1650
Fo La derd I FL 33301
facsimile
1016
11/8/2009
3501.183-055
Page 6 of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00094614
EFTA01248255
Page 1 of 2
Bradley J. Edwards
From: Bradley J. Edwards
Sent: Saturday, August 22, 2009 11:23 AM
To: 'Alfredo Rodriguez'
Subject: RE: Epstein
Alfredo,
I have been trying to call you for days and it seems your phone is shut off. Is there a new number where you can
be reached? Give me a call whenever you have a chance. Thanks. Hope all is well.
Sincerely,
Bradley J. Edwards
Partner
Rothstein Rosenfeldt Adler' Attorneys at Law
Las Olas City Centre
401 East Las Olas Boulevard, Suite 1650
Fort Lauderdale, FL 33301
- facsimile
From: Alfredo Rodriguez [mailto
Sent: Monday, August 10, 2009 :.15 PM
To: Bradley 3. Edwards
Subject: Re: Epstein
Hello Brad:
I've got the info you need.
I will send it to you as soon as I get back home.
Would you please give me your cell phone number?
Best regards,
Alfredo Rodriguez
--- On Mon, 8/10/09, Bradley J. Edwards <I > wrote:
From: Bradley J. Edwards <1
Sub'ect: E stein
To:
Dat . , , .
Hi Alfredo,
I didn't ask your phone number during the deposition, but I'd like to have it in case I have a question. I
was reading back over my notes, and I was wondering if you remembered Epstein's email address or the
name of the computer person from Ohio. Thank you for being so truthful in this case. I know you were in
a tough spot I wish you well.
1017
11/8/2009
3501.183-055
Page 7 of9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA_000946 IS
EFTA01248256
Page 2 of 2
Sincerely,
Bradley J. Edwards
Partner
Rothstein Rosenfeldt Adler' Attorneys at Law
Las Olas City Centre
401 East Las Olas Boulevard . Suite 1650
Fort Lauderdale, FL 33301
- facsimile
1018
11/8/2009
3501.183-055
Page 8 of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00094616
EFTA01248257
Page I of 1
Bradley J. Edwards
From: Bradley J. Edwards
Sent: Monday. October 19.2009 11:52 AM
To: 'Alfredo Rodriguez'
Subject: Hello
Alfredo,
You have literally fallen off the face of the earth. I hope everything is ok. I want to talk to you. Please call me
ASAP. The number I was reaching you on is no longer good. Please call me when you get this email. Again. I
hope all is well.
Bradley J. Edwards
Partner
Rothstein Rosenfeldt Adler' Attorneys at Law
Las Olas City Centre
401 East Las Olas Boulevard, Suite 1650
FL 33301
facsimile
1019
11/8/2009
3501.183-055
Page 9 of 9
SUBJECT TO PROTECTIVE ORDER PARAGRAPHS 7, 8, 9, 10, 15, and 17
EFTA 00094617
EFTA01248258