Case Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV-80119-MARRA/JOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant Related cases REPLY TO ROTHSTEIN ROSENFELDT ADLERS P.A.S RESPONSE TO DEFENDANTS EMERGENCY MOTION FOR ORDER FOR THE PRESERVATION OF EVIDENCE DE AS TO JANE DOE EPSTEIN CASE NO 08-CIV Defendant Jeffrey Epstein Epstein by and through his undersigned attorneys hereby files his Reply to Rothstein Rosenfeldt Adler P.A RRA Response to Defendants Emergency Motion for Order for the Preservation of Evidence DE and states It now appears that the Honorable Herbert Stettin Mr Stettin is the sole individual as the Chief Restructuring Officer in charge of RRA assets including electronic and paper records There also appears to be no objection to the entry of the preservation order consistent with his fiduciary/trustee duties for RRA although certain documents may no longer exist within his possession Par of the response reflects that some plus boxes of documents were obtained by the Department of Justice from search warrants served on the offices of Case Document Entered on FLSD Docket Page of RRA it is believed that the Department of Justice also sequestered about boxes of documents related to this Epstein case In fact there are three Epstein cases which have been brought by the RRA firm one being in federal court two in state court Mr Stettin confirms Defendants belief that there are serious ethical and potentially criminal issues that may impact Plaintiffs ability to pursue their cases Unfortunately time is critical with regard to this case in that there are deadlines to Disclose Experts and Exchange Reports by October but Plaintiff has not seen her expert has no report and only made herself available for the Defendants exam on November deposition discovery deadline is November and a calendar call of February for the February trial docket While the undersigned understands that Mr Stettin may be working expeditiously to deal with critical and pressing needs of stabilizing the firm a delay of days for his deposition which has been set in the state court case in the th Judicial Circuit Court Palm Beach County State of Florida L.M Epstein Case No AB not the case sub-judice will place his deposition sometime during the first days of January after every pre-trial deadline has expired If in fact there has been inappropriate and/or illegal conduct associated with the prosecution of this case by RRA or any of its attorneys or by the Plaintff herself which might result in sanctions dismissal or other remedy Defendant Epstein will be severely prejudiced WHEREFORE Defendant Epstein request that the courts preservation order be made permanent which does not seem inconsistent with Mr Stettins position as expressed by his lawyers but deny the relief sought for delaying the deposition unless the Case Document Entered on FLSD Docket Page of court is disposed to modify the current scheduling deadlines and trial date that exist in this case ritton Jr Florida ar Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of the Court using CM/ECF I also certify that the foregoing document is being served this day on all counsel of recor entified on the following Service List in the manner specified by CM/ECF on this Id day of November By ROBERT RITTON JR ESQ FloridaBarNo rcrit bclclaw.com MICHAEL PIKE ESQ Florida Bar mpike bclclaw.com BURMAN CRITTON LUTTIER COLEMAN Flagler Drive Suite West Palm Beach FL Phone Fax Counsel for Defendant Jeffrey Epstein Certificate of Service Jane Doe No Jeffrey Epstein Case No 08-CV-80119-MARRA/JOHNSON Stuart Mermelstein Esq Adam Horowitz Esq Brad Edwards Esq Rothstein Rosenfeldt Adler Case Document Entered on FLSD Docket Page of Mermelstein Horowitz P.A Biscayne Boulevard Suite Miami FL Fax ssm sexabuseattomey.com ahorowitz sexabuseattorney.com Counsel for Plaintiffs In related Cases Nos Richard Horace Willits Esq Richard Willits P.A th Avenue North Suite Lake Worth FL Fax Counsel for Plaintiff in Related Case No reelrhw hotmail.com Jack Scarola Esq Jack Hill Esq Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach FL Fax i sx searcylaw.com iph searcylaw.com Counsel for Plaintiff C.MA Bruce Reinhart Esq Bruce Reinhart P.A Australian Avenue Suite West Palm Beach FL Fax ecf brucereinhartlaw.com East Las Olas Boulevard Suite Fort Lauderdale FL Phone Fax bedwards rra-law.com Counsel for Plaintiff in Related Case No Paul Cassell Esq ProHac Vice South Room Salt Lake City UT Fax cassellp law.utah.edu Co-counsel for Plaintiff Jane Doe Isidro Garcia Esq Garcia Law Firm P.A Datura Street Suite West Palm Beach FL isidrogarcia bellsouth.net Counsel for Plaintiff in Related Case No Robert Josefsberg Esq Katherine Ezell Esq Podhurst Orseck P.A West Flagler Street Suite Miami FL Fax rjosefsberg podhurst.com kezell podhurst.com Counsel for Plaintiffs in Related Cases Nos and Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Case Document Entered on FLSD Docket Page of Counsel for Defendant Sarah Kellen Theodore Leopold Esq Spencer Kuvin Esq Leopold Kuvin P.A PGA Blvd Suite Palm Beach Gardens FL Fax Counsel for Plaintiff in Related Case No Fax jagesg bellsouth.net Counsel for Defendant Jeffrey Epstein Charles Lichtman Esq Isaac Marcushamer Esq Berger Singerman P.A East Broward Boulevard th Floor Fax clichtman bergersingerman.com imarcushamer bergersingerman.com Proposed Attorneys for Alleged Debtor
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