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D?J CTX P!Z b!o C,C qrM 10Cy qr8 I fX2 9R lO KV CTX Oo CTX A qr r?qr rq YY Lsy7H4 C,6E IL CTX U3 CTX J,O3_3xx qrM?r q?CX Y9/C 9CX CTX Y10Cy CX CX CX YC YY FV uTl bEWa ȓjJ-8 Gc G??Q9E 9Wq CTX CTX Up i I A 9_ qr qr YY D.X 7s F??Y bc3_c iH CTX CTX A qr 10Cy YY EMq 7H AY mK9Z BY A2 P6L N7 CTX CTX a I I i qr rC CTX CTX 7O I FMM qr qr i I I3 CTX Z6 I L(K4 P:u Z6P CTX y8 Complex Litigation Fla Civ and has vanous professionals whose employment have been approved by the United States Bankruptcy County Additionally Scott Rothstein who apparently managed the affairs of the law firm has been criminally charged by the United States of America with various violations of federal law to which he has pied guilty Associated with those charges the United States of America seized the law firms bank accounts See Exhibit annexed hereto Consequently the very limited financial resources are primarily devoted to trying to bring money into the estate as opposed to expending money on unrelated third party litigation such as this one While the Trustee has indicated in a different lawsuit his willingness to try to produce to Mr Epstein the documents he needs in order that the Trustees responsibility for winding-up the affairs of the Estate is not impeded and because of the limited finances available to the Trustee he requests that the Court order that all costs associated with responding to Mr Epsteins subpoena duces tecum be borne by Mr Epstein and that at least of the estimated costs be paid to the Trustee prior to any responsibility for undertaking a search for the documents The Trustee also requests that the time for responding to the subpoena duces tecum be adjourned until such time as this Court or Mr Epstein and the Trustee are able to resolve the issues raised in this Motion for Protective Order Wherefore for the foregoing reasons the Trustee requests this Court to grant this motion BF RGER SINGERMAN 2Sl a a I a Boca Raton Farr Lauderdale Miami Tallahassee South Biscayne Boulevard Suite Miami Florida Telephone Facsimile Complex Litigation Fla Civ Respectfully submitted BERGER SINGERMAN Counsel for the Trustee Biscayne Blvd Tenth Floor Miami Florida CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served by U.S Mail and facsimile on Mr Robert Critton Jr Banyan Blvd Suite West Palm Beach Fl Mr Marc Nurik One East Broward Blvd Suite Ft Lauderdale FL Mr Jack Scarola Palm Beach Lakes Blvd West Palm Beach FL Mr Gary Farmer Andrews Ave Suite Fort Lauderdale FL and Mr Jack Goldberger Australian Ave South Suite West Palm Beach FL this of Boca Raton Fort Lauderdale Miami Tallahassee South Biscayne Boulevard Suite Miami Florida Telephone Facsimile JEFFREY EPSTEIN Plaintiff SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendants IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Complex Litigation Fla Civ Case No AG SUBPOENA DUCES TE CUM FCR DEPOSITION DOCUMENTS ONLY THE STATE OF FLORIDA TO Herbert Stettin Trustee in Bankruptcy for Rothstein Rosenfeldt Adler PA C/O James Cunningham Jr Esq Berger Singerman P.A South Biscayne Blvd Suite Miami FL YOU ARE COMMANDED to appear at Prose Court Reporting NE rd Avenue Suite Ft Lauderdale FL on May p.m bring with you the following See attached Exhibit A If you fail to appear you may be in contempt of court You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by the attorney or the Court you II respond to this subpoena as directed DATED this th day of April CRITTON JR ttorneys for Defendant Jeffrey Epstein Burman Critton Luttier Coleman Banyan Blvd Suite West Palm Beach FL iEXHIB A EXHIBIT A DEFINITIONS AND INSTRUCTIONS A Document means any written or graphic matter or other means of preserving thought or expression and all tangible things from which information can be processed or transcribed including the originals and all non-identical copies whether different from the original by reason of any notation made on such copy or otherwise including but not limited to correspondence memoranda notes messages letters purchase orders telegrams teletype telefax bulletins e-mails electronic data meetings reports or other communications interoffice and intra-office telephone calls diaries chronological data minutes books reports charts ledgers invoices worksheets receipts returns trade information regarding fabric carpets samples etc computer printouts prospectuses financial statements schedules affidavits contracts cancelled checks transcripts statistics surveys magazine or newspaper articles releases and any and all drafts alterations and modifications changes and amendments of any of the foregoing graphs or aural records or representations of any kind including without limitation photographs charts graphs microfiche microfilm video tape recordings motion pictures and electronic mechanical or electric recordings or representations of any kind including without limitation tapes cassettes discs and recordings and including the file and file cover The term Document also means any and all computer records data files directories electronic mail and information of whatever kind whether printed out or stored on or retrievable from floppy diskette compact diskette magnetic tape optical or magnetic-optical disk computer memory hard drive zip drive jaz drive orb drive microdisk external memory stick software or any other fixed or removable storage media including without limitation all back-up copies dormant or remnant files and any and all miscellaneous files and/or file fragments regardless of the media on which they reside and regardless of whether the data consists in an active file deleted file or file fragment Communications means any oral or written statement dialogue colloquialism discussion conversation or agreement Plaintiff means L.M LM Jeffrey Epstein Palm Beach County Case E.W Jeffrey Epstein Palm Beach County Case Jane Doe Jane Doe Jeffrey Epstein United States District Court Case 08-civ-80893-Marra/Johnson and any other person who is or was represented by Rothstein Rosenfeldt Adler that has not yet filed an action against Jeffrey Epstein and any employee agent or attorney for any plaintiff and/or any other person acting for or on behalf of any plaintiff or under her authority and control RRA means Rothstein Rosenfeldt Adler P.A Money means any tangible thing of value Costs include but are not limited to court costs filing fees Sheriffs service and any other necessary service of legal papers or notices or subpoenas court reporters charges long distance telephone charges postage courier services or Federal Express or UPS investigative costs photocopies faxes Westlaw computerized research travel expenses and witness fees and expert witness fees and costs If you are unable to identify each Plaintiff please contact Robert Critton Jr at their names will be provided pursuant to a confidentiality agreement Trustee means Herbert Stettin as bankruptcy trustee for RRA DUCES TECUM For the time period from March to present any and all documents between or on behalf of RRA its employees or agents or clients and any third party regarding a purported settlement of any litigation between Jeffrey Epstein and a RRA client or Plaintiff or the financing of any litigation between Jeffrey Epstein and a RRA client or Plaintiff whether existing clients or fabricated clients including but not limited to a Documents indicating that litigation with Jeffrey Epstein has been settled Soliciting or receiving money in return for settlement funds allegedly paid or to be paid by Jeffrey Epstein Soliciting money to help finance ongoing litigation against Jeffrey Epstein Soliciting money to be given to or used on behalf of the Plaintiffs in litigation against Jeffrey Epstein Communication between third party investors or potential investors and the Plaintiffs or their attorneys involved in litigation against Jeffrey Epstein Payments made by RRA to or on behalf of any Plaintiff Any and all fee agreements that exist or have existed between the following a Any Plaintiff and Bradley Edwards or any entity with which he has been associated Any Plaintiff and the law firm RRA All emails data correspondence memos or similar documents between Bradley Edwards Scott Rothstein William Berger and Russell Adler and/or any attorney or representative of R.RA and any investor or third party person or entity regarding Jeffrey Epstein or which mentions Jeffrey Epstein including Mike Fisten Kenneth Jenne Patrick Roberts or Rick Rich Fandrey All emails data correspondence memos or similar documents between Bradley Edwards Scott Rothstein and/or any attorney or representative of RRA regarding Jeffrey Epstein or which mentions Jeffrey Epstein including Mike Fisten Kenneth Jenne Patrick Roberts or Rick Rich Fandrey Due to the potential volume of documents involved the parties and the Court should consider appointment of a special master and/or an in camera inspection to address any objections claims of privilege and generally manage the production of documents All agreements or documents of any nature which were provided to or received from an investor or potential investor relating to any case real or fabricated involving Jeffrey Epstein and any of the following a Scott Rothstein Bradley Edwards RRA any entity formed by RRA or Bradley Edwards or Scott Rothstein to create investment opportunities for third party investors to invest in any plaintiffs case against Jeffrey Epstein All fee sharing agreements between Bradley Edwards RRA or Scott Rothstein and/or any other attorney or investor relating to any aspect of any Plaintiffs case All documents made available to any investor or potential investor by Bradley Edwards RRA Scott Rothstein or any of Scott Rothsteins entities to solicit investors for any case involving Jeffrey Epstein All document reflecting the names and addresses of all individuals or entities who invested or purported to invest in any aspect of any case against Jeffrey Epstein All documents evidencing payment of any bill or cost in each Plaintiffs case against Jeffrey Epstein and the source for said payments of any Costs All documents wherein the Trustee of RRA has asserted a lien for attorneys fees or Costs arising out of work done and Costs incurred related to the Plaintiffs cases during the time Plaintiffs cases were represented by RRA All documents and tangible things retrieved from the trash at El Brillo Way Palm Beach Florida which is alleged to be the home of Jeffrey Epstein All conversations recorded from any telephones which purported to be that of Jeffrey Epstein that are contained in any media audio tapes CDs DVDs zip drives hard drives or any other electronic format and any written transcriptions All conversations recorded from any telephones which purported to be from Jeffrey Epsteins attorneys including Roy Black Alan Dershowitz or Jack Goldberger that are contained in any media audio tapes CDs DVDs zip drives hard drives or any other electronic format and any written transcriptions All intercepted phone conversations authorized by RRA including but not limited to any one of its attorneys or investigators or anyone retained by or working for RRA related to Jeffrey Epstein that are contained in any media audio tapes CDs DVDs zip drives hard drives or any other electronic format and any written transcriptions All intercepted or acquired electronic mail e-mails to and from Jeffrey Epstein authorized by RRA including but not limited to any one of its attorneys or investigators or anyone retained by or working for RRA All intercepted or acquired electronic mail e-mails to and from the attorneys for Jeffrey Epstein including but not limited to Roy Black Alan Dershowitz or Jack Goldberger authorized by RRA including but not limited to any one of its attorneys or investigators or anyone retained by or working for RRA All documents related to the amount of Costs that were incurred by RRA in its representation of Jane Doe L.M and E.W and is claiming or has claimed All documents which purport to evidence any transfer of funds or property from Jeffrey Epstein to RRA Rothstein or any Rothstein-related entity for the settlement of any case real or fabricated against Jeffrey Epstein All documents which purport to mention any transfer of funders or property from Jeffrey Epstein to RRA Rothstein or any Rothstein-related entity for the settlement of any case real or fabricated against Jeffrey Epstein All documents relating to any investment joint-venture or business enterprise involving RRA Rothstein or a Rothstein-related entity that reference any claim real or fabricated against Epstein All emails exchanged between any of the following individuals wherein Epstein a Palm Beach billionaire or similar reference was mentioned a Scott Rothstein Russell Adler William Berger Michael Fisten Kenneth Jenne David Boden Deborah Villegas Andrew Barnett i Patrick Rocberts Richard Rick Fandry Christina Kitterman I Brad Edwards All documents related to or referencing potential deponents in the Jane Doe L.M or E.W cases All Q-Task Projects that refer to Jeffrey Epstein All Q-Task Projects that refer to L.M E.W or Jane Doe All documents that identify all individuals who were granted access invited guests or who had access to the Q-Task Projects referred to in request nos and All documents communications and letters sent by you assessing liens against the recoveries in a L.M Epstein Case No E.W Epstein Case No Jane Doe Epstein Case No 08-CV-80119-MARRA/JOHNSON All documents related to the Costs that you as bankruptcy Trustee are claiming related to L.M E.W and Jane Does cases against Epstein This includes any data or electronic printout of Costs which the Trustee of RRA is claiming Any employment agreements or letters describing compensation and benefits for Bradley Edwards during his employment with RRA All documents from the Fortress software program that refer or relate to Jeffrey Epstein All documents from the Fortress software program that refer or relate to L.M E.W or Jane Doe For the time period April through November all emails to and from any employee partner shareholder attorney agent or client of RRA that reference any of the following a A.J Discala D3 Capital Club LLC Bill Clinton Alan Dershowitz David Copperfield Kevin Spacey Chris Tucker Prince Andrew i Jean-Luc Brunel Tommy Motolla Bill Richardson I Donald Trump Case JZ Document Entered on FLSD Docket Page of UNITED STA TES DISTRICT COURT SOUTHERN DIS-::RICT OF FLORIDA CASE NO 09-61780-CIV-ZLOCH/ROSENBAUM UNITED ST A TES OF AMERICA Plaintiff VARIOUS REAL PROPERTIES PURCHASED OR WITH OR ON BEHALF OF SCOTT ROTHSTEIN SPECIFICALLY I REAL PROPERTY AND APPURTENANCES LOCATED AT CASTILLA ISLE FORT LAUDERDALE FLORIDA REAL PROPERTY AND APPURTENANCES LOCATED AT CASTILLA ISLE FORT LAUDERDALE FLORIDA REAL PROPERTY AND APPURTENANCES LOCATED AT CASTILLA ISLE FORT LAUDERDALE FLORIDA REAL PROPERTY AND APPURTENANCES LOCATED AT ISLA BAHIA DRIVE FORT LAUDERDALE FLORIDA REAL PROPERTY AND APPURTENANCES LOCATED AT ISLA BAHIA DRIVE FORT LAUDERDALE FLORIDA REAL PROPERTY AND APPURTENANCES LOCATED AT SE 2ND Case Document Entered on FLSD Docket Page of INTERESTS Bl AND CONTRIBUTIONS SPECIFICALLY RP9 REAL PROPERTY AND APPURTENANCES LOCATED AT CASTILLA ISLE FORT LAUDERDALE FLORIDA RPJ0 REAL PROPERTY AND APPURTENANCES LOCATED AT NW Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of VV WHITE MERCEDES BENZ VIN VV I WARREN HULL VVJ AQUARIVA HULL VV YAMAHA Case Document Entered on FLSD Docket Page of T7 IN AMERICAN EXPRESS GIFT CARDS T8 ADDITIONAL WATCHES T9 GUITAR COLLECTION BA FIDELITY INVESTMENTS STOCK ACCOUNT IN THE NAME OF SCOTT ROTHSTEIN VALUED AT APPROXIMATELY BA2 GIBRALTAR BANK ACCOUNT IN THE NAME OF WA WW LLC IN THE APPROXlMATE AMOUNT OF BA3 GIBRALTAR BANK ACCOUNT IN THE APPROXIMATE AMOUNT OF BA4 GIBRALTAR BANK ACCOUNT IN THE APPROXIMATE AMOUNT OF BAS GIBRALTAR BANK ACCOUNT IN THE APPROXIMATE AMOUNT OF I BA6 BANK POPULAIRE MOROCCO BANK ACCOUNT I IN THE NAME OF SCOTT ROTHSTEIN IN THE APPROXIMATE AMOUNT OF BA BANK POPULAIRE MOROCCO ACCOUNT IN THE NAME OF AHNICK KHALID UP TO THE AMOUNT OF BA8 BANK POPULAIRE MOROCCO ACCOUNT TN THE NAME OF STEVE CAPUTI UP TO THE AMOUNT OF Bil STOCK CERTIFICATES OR BENEFICIAL INTEREST IN SHARES OF CA PIT AL STOCK IN GIBRALTAR PRIVATE BANK TRUST SCOTT ROTHSTEINS EQUITY INTEREST IN QTASK BI3 SCOTT ROTHSTEINS EQUITY INTEREST IN BROWARD SANK OF COMMERCE SCOTT ROTHSTEINS EQUITY INTEREST IN BOVA RISTORANTE SCOTT ROT!-ISTEINS EQUITY INTEREST IN Case Document Entered on FLSD Docket Page of BOY A CU CINA Bl6 SCOTT ROTHSTEINS EQUITY INTEREST IN BOVA PRIME Bl7 SCOTT ROTHSTEINS EQUITY INTEREST IN CAFE IGUANA PEMBROKE PINES FLORIDA Bl8 SCOTT ROTHSTEINS EQUITY INTEREST IN CART SHIELD USA LLC Bl9 SCOTT ROTHSTEINS EQUITY INTEREST IN RENA TO WATCHES Bil SCOTT ROTHSTEINS EQUITY INTEREST IN EDIFY LLC SCOTT ROTHSTEINS EQUITY INTEREST IN GEORGIO VODKA Bl SCOTT ROTHSTEINS EQUITY INTEREST IN SEA CLUB BJ13 SCOTT ROTHSTEJNS EQUITY INTEREST IN NORTH STAR MORTGAGE BJ SCOTT ROTHSTEINS EQUJTY INTEREST IN KIP HUNTER Case Document Entered on FLSD Docket Page of AT OLD DIXIE HIGHWAY BOCA RATON FLORIDA SCOTT R0THSTEINS EQUITY INTEREST IN AND RENTS DERIVED FROM THE CAR WASH LOCATED AT FEDERAL HIGHWAY BOCA RATON FLORIDA PROMISSORY NOTE BY UNIGLOBE IN FAVOR OF SCOTT ROTHSTEIN ALL EQUITY INTEREST HELD BY OR ON BEHALF OF SCOTT ROTHSTEIN IN ARJOUS CORPORATIONS AND ENTITIES IN CAMPAIGN CONTRIBUTIONS MADE TO ALEX SINK AND VOLUNTARILY OFFERED AND TURNED OVER TO THE UNITED STATES ON BEHALF OF ALEX SINK C2 IN CAMPAIGN CONTRIBUTIONS TO REPUBLICAN PARTY OF FLORIDA FLORIDA ACCOUNT AND VOLUNTARILY OFFERED AND TURNED OVER TO THE UNITED STATES BY THE REPUBLICAN PARTY OF FLORIDA C3 IN CAMPAIGN CONTRIBUTIONS TO REPUBLICAN PARTY OF FLORIDA FEDERAL ACCOUNT AND VO LUNT ARIL OFFERED AND TURNED OVER TO THE UNITED STATES BY THE REPUBLICAN PARTY OF FLORIDA C4 IN CAMPAIGN CONTRJBUTIONS TO REPUBLICAN PARTY OF FLORIDA AND VOLUNTARILY OFFERED AND TURNED OVER TO THE UNITED ST A TES BY THE REPUBLICAN PARTY OF FLORIDA CS IN CAMPAIGN CONTRIBUTIONS TO REPUBLICAN PARTY OF FLORIDA BY ROTHSTEIN BUSINESS ENTITY KNOWN AS WA WW AND VOLUNTARILY OFFERED AND TURNED OVER TO THE UNITED STATES BY THE REPUBLICAN PARTY OF FLORIDA C6 CHARITABLE DONATION TO JOE DIMAGGIO CHILDRENS HOSPITAL WHICH HOSP IT AL ADVISED THE UNrTED ST A TES OF THE DONATION FROM THE ROTHSTEIN FAMILY FOUNDATION C7 CHARITABLE DONATION TO HOLY CROSS HOSPITAL WHICH HOSPITAL ADVISED THE UNITED ST ATES OF THE DONATION FROM THE ROTHSTEIN FAMILY FOUNDATION Case Document Entered on FLSD Docket Page of CS IN CAMPAIGN CONTRIBUTIONS TO GOVERNOR CHARLIE CRIST AND VOLUNTARILY OFFERED AND TURNED OVER TO THE UNITED ST ATES BY THE OFFICE OF CHARLIE CRIST AND C9 ALL FUNDS VOLUNTARILY TURNED OVER TO THE UNITED STATES IRS/FBI SINCE IN OR ABOUT OCTOBER IN RESPONSE TO PUBLICITY INVOLVING SCOTT ROTHSTEIN Defendants I WARRANT OF ARREST IN REM FOR NON-REAL PROPERTIES TO THE INTERNAL REVENUE SERVICE THE UNITED STATES MARSHALS OR ANY OTHER AUTHORIZED FEDERAL LAW ENFORCEMENT OFFICER WHEREAS on November the United States of America filed an Amended Verified Complaint for Forfeiture in Rem against the above-named defendants also referred to as defendant properties for the violations oflaw enumerated in said Complaint DE and WHEREAS the Court has found that probable cause exists that the defendants are subject to forfeiture NOW THEREFORE you are hereby commanded to take the defendants into your possession for safe custody If the character or situation of the property is such that the taking of actual possession is impracticable you shall execute this process by affixing a copy thereof to the property in a conspicuous place and/or by leaving a copy of the Amended Verified Complaint and process with the person having possession or his agent YOU ARE FURTHER commanded to cite and admonish the owner and/or possessor of the defendants and any person or firm known to claim any interest therein to file in the United States District Court North Miami Avenue Miami Florida within thirty days Case Document Entered on FLSD Docket Page of following receipt of this Warrant a Verified Ciaim in accordance with Rule Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions and to therewith or within twenty days thereafter file an Answer or other responsive pleading to the Amended Verified Complaint a copy of which Complaint you shall supply with this Warrant and to serve copies of said Claim and Answer upon the United States Attorney NE 4th Street Miami Florida Attention Alison Lehr Assistant United States Attorney and that upon failure of the owner possessor or any party claiming an interest in the defendant properties to do so that the defendant properties may then be forfeited to the United States by default and without further notice or hearing AND YOU ARE FURTHER commanded to make due and prompt return of this Warrant to this Court upon its execution WITNESS THE HONORABLE _Y WILLIAM ZLOCH UNITED STA TES DISTRICT JUDGE DATE STEVEN LAR1MORE CLERK UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORJDA BY i DEPUTY CLERK
