EFTA00596643Set 9
2008-08-1343p13,103w
effort to
secure substantial punitive damages.
In the fall of 2009, Michael Fisten, an investigator working for Jane Doe, heard
from an author that Daily News reporter George Rush ... tape recording of
Epstein discussing the sexual abuse of minor girls. The author told Fisten that Rush
had played the tape for her and two other persons. The author concluded ... that tape." Fisten then called Rush. Rush described the tape at great length to
Fisten, including damning admissions made by Epstein. Rush also later called Brad
Edwards (the attorney
https://www.justice.gov/epstein/files/DataSet%209/EFTA00596643.pdf
EFTA00728061Set 9
2010-04-0723p6,600w
showing critical for securing substantial punitive
damages.
In the fall of 2009, Michael Fisten, an investigator working for Edwards, heard from an
author that Daily News reporter George Rush ... recording of Epstein discussing the
sexual abuse of minor girls. The author told Fisten that Rush had played the recording for her
and two other persons. The author concluded ... that tape." Fisten then called
Rush. Rush described the tape at great length to Fisten, including damning admissions made by
Epstein. Rush also later called Brad Edwards and again described
https://www.justice.gov/epstein/files/DataSet%209/EFTA00728061.pdf
EFTA00725319Set 9
2009-11-2034p7,791w
individually,
DEBBIE VILLEGAS, individually,
DAVID BODEN, individually,
ANDREW BARNETT, individually,
KENNETH JENNE, individually,
MICHAEL FISTEN, individually,
L.M., individually,
E.W., individually, and
JANE DOE, individually
Defendants.
COMPLAINT
Plaintiff, JEFFERY EPSTEIN, (hereinafter ... individually, DEBBIE
VILLEGAS, individually, DAVID BODEN, individually, ANDREW BARNETT, individually,
KENNETH JENNE, individually, MICHAEL FISTEN, individually, L.M., individually,
E.W., individually, and JANE DOE, individually. Accordingly, EPSTEIN states:
EFTA00725319
Epstein ... limited to, the Civil Actions (defined below) involving Epstein.
15. Defendant, MICHAEL FISTEN ("FISTEN"), is an individual residing in
County, Florida. At all times relevant hereto, FISTEN was an employee
https://www.justice.gov/epstein/files/DataSet%209/EFTA00725319.pdf
EFTA00587914Set 9
2009-11-2030p7,249w
RUSSELL ADLER, individually,
BRADLEY J. EDWARDS, individually,
WILLIAM BERGER, individually,
KENNETH JENNE, individually,
MICHAEL FISTEN, individually, and
L.M., individually,
Defendants.
COMPLAINT
Plaintiff, JEFFERY EPSTEIN, (hereinafter "EPSTEIN"), by and through ... RUSSELL ADLER, individually,
BRADLEY J. EDWARDS, individually, WILLIAM BERGER, individually, KENNETH
JENNE, individually, MICHAEL FISTEN, individually, and L.M., individually.
Accordingly, EPSTEIN states:
General Allegations
1. This is an action ... either knew or
should have known that JENNE (convicted former Broward County Sheriff) and FISTEN
(former disgraced Miami-Dade Police Officer) were providing banker's boxes of
EPSTEIN files (estimated
https://www.justice.gov/epstein/files/DataSet%209/EFTA00587914.pdf
EFTA00725289Set 9
2009-11-2030p7,253w
RUSSELL ADLER, individually,
BRADLEY J. EDWARDS, individually,
WILLIAM BERGER, individually,
KENNETH JENNE, individually,
MICHAEL FISTEN, individually, and
L.M., individually,
Defendants.
COMPLAINT
Plaintiff, JEFFERY EPSTEIN, (hereinafter "EPSTEIN"), by and through ... RUSSELL ADLER, individually,
BRADLEY J. EDWARDS, individually, WILLIAM BERGER, individually, KENNETH
JENNE, individually, MICHAEL FISTEN, individually, and L.M., individually.
Accordingly, EPSTEIN states:
General Allegations
1. This is an action ... either knew or
should have known that JENNE (convicted former Broward County Sheriff) and FISTEN
(former disgraced Miami-Dade Police Officer) were providing banker's boxes of
EPSTEIN files (estimated
https://www.justice.gov/epstein/files/DataSet%209/EFTA00725289.pdf
EFTA00611238Set 9
2009-07-2242p32,388w
with the Jeffrey Epstein case? 1 Q. Did you meet, did you know Mr. Fisten
2 A. I didn't say that anybody did. So, no, 2 before you started ... could just spend whatever money you 4 Q. No. All right. And Mr. Fisten, did you
5 wanted to in prosecuting your cases; is that 5 direct Mr. Piston ... judgment for the transcript to be expedited 10 A. I directed Mr. Fisten to interview people and
11 then i would order it expedited and nobody ever told
https://www.justice.gov/epstein/files/DataSet%209/EFTA00611238.pdf
EFTA00728441Set 9
2010-09-1440p7,851w
annexed Affidavit of Bradley James
Edwards dated September 14, 2010, the Affidavit of Michael Fisten dated September 14,
2010, the Affirmation of Robert Y. Lewis dated September ... noted, my Affirmation is based on the Affidavits
of Bradley James Edwards and Michael Fisten, both dated September 14, 2010, as well as
a review of the files and records ... Recorded Interview of Epstein Concerning His Molestation
5. In the fall of 2009, Michael Fisten, an investigator working for
Edwards, heard from an author that Daily News reporter George Rush
https://www.justice.gov/epstein/files/DataSet%209/EFTA00728441.pdf
EFTA01250614Set 9
2010-04-3038p10,141w
advised by one of plaintiff's attorneys that there is an
additional individual -- Michael Fisten, private investigator for Doe's attorney Bradley Edwards
-- to whom I described certain aspects ... affidavit. Hearing that refreshed my memory that in fact I did speak to
Mr. Fisten about the interview. The attorney's representation that the interview with Mr. Epstein
must have ... occurred prior to October 22, 2009, because my conversation with Mr. Fisten took
place on or about that date, is also correct. My statement in my prior affidavit that
https://www.justice.gov/epstein/files/DataSet%209/EFTA01250614.pdf
EFTA01810347Set 10
2009-10-224p1,234w
recently advised by one of plaintiffs attorneys that there is an
additional individual — Michael Fisten, private investigator for Doe's attorney Bradley Edwards
— to whom I described certain aspects ... affidavit. Hearing that refreshed my memory that in fact I did speak to
Mr. Fisten about the interview. The attorney's representation that the interview with Mr. Epstein
must have ... occurred prior to October 22, 2009, because my conversation with Mr. Fisten took
place on or about that date, is also correct. My statement in my prior affidavit that
https://www.justice.gov/epstein/files/DataSet%2010/EFTA01810347.pdf
EFTA01126056Set 9
2009-10-1318p4,484w
employed a team of investigators on the Epstein Actions, including Michael
Fisten ("Fisten") and former Broward County Sheriff and convicted felon Ken Jenne ("Jenne").
-4-
FOWLER WHITE BURNETT P.A.
EFTA01126059 ... Epstein v Rothstein, Edwards
Case No.: 502009CA040800XXXXMBAG
Second Amended Complaint
12. Fisten and Jenne were the primary investigators assigned to Edwards, and
routinely reported to Edwards and Rothstein regarding their ... files into a conference room at RRA to be examined by potential investors. Then, Fisten and
Jenne brought in the case files for the Epstein Actions, which numbered as many
https://www.justice.gov/epstein/files/DataSet%209/EFTA01126056.pdf
EFTA00584195Set 9
2009-10-1317p4,666w
employed a team of investigators on the Epstein Actions, including Michael
Fisten ("Fisten") and former Broward County Sheriff and convicted felon Ken Jenne ("Jenne").
12. Fisten and Jenne were ... files into a conference room at RRA to be examined by potential investors. Then, Fisten and
Jenne brought in the case files for the Epstein Actions, which numbered as many ... meeting with other partners of
RRA, to look at the Epstein case files that Fisten and Jenne had stacked around the conference
room.
17. On or about October
https://www.justice.gov/epstein/files/DataSet%209/EFTA00584195.pdf
EFTA01100592Set 9
2009-10-1316p4,350w
employed a team of investigators on the Epstein Actions, including Michael
Fisten ("Fisten") and former Broward County Sheriff and convicted felon Ken Jenne ("Jenne").
12. Fisten and Jenne were ... files into a conference room at RRA to be examined by potential investors. Then, Fisten and
Jenne brought in the case files for the Epstein Actions, which numbered as many ... meeting with other partners of
RRA, to look at the Epstein case files that Fisten and Jenne had stacked around the conference
room.
17. On or about October
https://www.justice.gov/epstein/files/DataSet%209/EFTA01100592.pdf
EFTA00584212Set 9
2009-10-1316p4,327w
employed a team of investigators on the Epstein Actions, including Michael
Fisten ("Fisten") and former Broward County Sheriff and convicted felon Ken Jenne ("Jenne").
12. Fisten and Jenne were ... files into a conference room at RRA to be examined by potential investors. Then, Fisten and
Jenne brought in the case files for the Epstein Actions, which numbered as many ... meeting with other partners of
RRA, to look at the Epstein case files that Fisten and Jenne had stacked around the conference
room.
17. On or about October
https://www.justice.gov/epstein/files/DataSet%209/EFTA00584212.pdf
EFTA00607583Set 9
2009-10-1316p4,352w
employed a team of investigators on the Epstein Actions, including Michael
Fisten ("Fisten") and former Broward County Sheriff and convicted felon Ken Jenne ("Jenne").
12. Fisten and Jenne were ... files into a conference room at RRA to be examined by potential investors. Then, Fisten and
Jenne brought in the case files for the Epstein Actions, which numbered as many ... meeting with other partners of
RRA, to look at the Epstein case files that Fisten and Jenne had stacked around the conference
room.
17. On or about October
https://www.justice.gov/epstein/files/DataSet%209/EFTA00607583.pdf
EFTA01084240Set 9
2009-10-1317p4,664w
employed a team of investigators on the Epstein Actions, including Michael
Fisten ("Fisten") and former Broward County Sheriff and convicted felon Ken Jenne ("Jenne").
12. Fisten and Jenne were ... files into a conference room at RRA to be examined by potential investors. Then, Fisten and
Jenne brought in the case files for the Epstein Actions, which numbered as many ... meeting with other partners of
RRA, to look at the Epstein case files that Fisten and Jenne had stacked around the conference
room.
17. On or about October
https://www.justice.gov/epstein/files/DataSet%209/EFTA01084240.pdf
EFTA01084208Set 9
2009-10-1316p4,434w
employed a team of investigators on the Epstein Actions, including Michael
Fisten ("Fisten") and former Broward County Sheriff and convicted felon Ken Jenne ("Jenne").
12. Fisten and Jenne were ... files into a conference room at RRA to be examined by potential investors. Then, Fisten and
Jenne brought in the case files for the Epstein Actions, which numbered as many ... groups, was permitted by Rothstein to look at the Epstein case file boxes
that Fisten and Jenne had stacked around the conference room.
-4-
FOWLER WHITE BURNETT P.A. • 901 PHILLIPS
https://www.justice.gov/epstein/files/DataSet%209/EFTA01084208.pdf
EFTA01093224Set 9
2009-10-1316p4,352w
employed a team of investigators on the Epstein Actions, including Michael
Fisten ("Fisten") and former Broward County Sheriff and convicted felon Ken Jenne ("Jenne").
12. Fisten and Jenne were ... files into a conference room at RRA to be examined by potential investors. Then, Fisten and
Jenne brought in the case files for the Epstein Actions, which numbered as many ... meeting with other partners of
RRA, to look at the Epstein case files that Fisten and Jenne had stacked around the conference
room.
17. On or about October
https://www.justice.gov/epstein/files/DataSet%209/EFTA01093224.pdf
EFTA01079777Set 9
2009-10-1316p4,267w
employed a team of investigators on the Epstein Actions, including Michael
Fisten ("Fisten") and former Broward County Sheriff and convicted felon Ken Jenne ("Jenne").
12. Fisten and Jenne were ... files into a conference room at RRA to be examined by potential investors. Then, Fisten and
Jenne brought in the case files for the Epstein Actions, which numbered as many ... meeting with other partners of
RRA, to look at the Epstein case files that Fisten and Jenne had stacked around the conference
room.
17. On or about October
https://www.justice.gov/epstein/files/DataSet%209/EFTA01079777.pdf