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Epstein Release Interview Victim Statements Evidence Maxwell
← Back to Epstein v. Rothstein, No. 50-2009-CA-040800-XXXX-MB (Fla. 15th Cir. Ct. 2009)
Extracted Text

On May the Trustee filed a Motion for Protective Order addressing issues primarily relating to costs associated with reviewing and compiling responsive documents to the subpoena A copy of the Motion for Protective Order is annexed hereto as Exhibit On June counsel for L.M filed a Motion for Protective Order A copy of the Motion for Protective Order is annexed hereto as Exhibit Within the bankruptcy court the Trustee obtained a protective order dealing with its production of documents The Trustee believes that the documents requested in the Subpoena are subject to the attorney-client privilege and/or work product doctrine or are simply actually the clients documents even though the Trustee holds the attorney-client privilege as to RRA However since the former RRA attorneys never obtained their files from RRA when the firm was closed the Trustee is effectively standing in the shoes of the former RRA attorneys and clients and thus the Subpoena cannot request discovery from the Trustee to somehow circumvent the attorney-client privilege WHEREFORE for the foregoing reasons the Trustee requests this Court to grant this Motion and enter an Order of protection prohibiting Plaintiff from obtaining the discovery sought in the Subpoena Respectfully submitted BERGER SINGERMAN Counsel for the Trustee Biscayne Blvd Tenth Floor Miami Florida facsimile Florida Bar No 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 Burman Critton Luttier Coleman Banyan Blvd Suite West Palm Beach FL Mr Marc Nurik Esq Law Offices of Marc Nurik One East Broward Blvd Suite Ft Lauderdale FL Mr Jack Scarola Palm Beach Lakes Blvd West Palm Beach FL Mr Gary Farmer Esq Farmer Jaffe Weissing et al Andrews Ave Suite Fort Lauderdale FL and Mr Jack Goldberger Esq Atterbury Goldberger et al Australian Ave South Suite West Palm Beach FL and to Rodney Janis Esq Fowler White Burnett P.A Phillips Point West Tower Flagler Dr Ste West Palm Beach Florida this day of June JEFFREY EPSTEIN Plaintiff SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendants IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN ANO FOR PALM BEACH COUNTY FLORIDA Complex Litigation Fla Civ Case No AG SUBPOENA DUCES TECUM FOR 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 Fl 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 8Qct1 R,c CRITTON JR ttorneys for Defendant Jeffrey Epstein Burman Critton Luttier Coleman Banyan Blvd Suite West Palm Beach FL EXHIBIT I 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 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 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 RRAD 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 Trusteen 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 RRA 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 a-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 Document Entered on FLSD Docket Page of UNITED STA TES DISTRICT COURT SOtm-lERN DISTRICT OF FLORIDA CASE NO 09-61780-CIV-ZLOCH/ROSENBAUM UNITED STA TES OF AMERICA Plaintiff VARIOUS REAL PROPERTIES PURCHASED BY OR WITH OR ON BEHALF OF SC01T ROTHSTEIN SPECIFICALLY REAL PROPERTY AND APPURTENANCES LOCATED AT CASTILLA ISLE FORT LAUDERDALE FLORIDA REAL PROPERTY AND APPURTENANCES LOCATEDAT2308CASTILLA ISLE FORT LAUDERDALE FLORIDA REAL PROPERTY AND APPURTENANCES LOCATED AT CASTil..LA 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 Case Document Entered on FLSD Docket Page of INTERESTS Bl AND CONTRIBUTIONS SPECIFICALLY RP9 REAL PROPERTY AND APPURTENANCES LOCATED AT CASTILLA ISLE FORT LAUDERDALE FLORJDA RPIO REAL PROPERTY AND APPURTENANCES LOCATED AT NW 14TH Case Document Entered on FLSD Docket Page of Case Document Entered on FLSD Docket Page of VV WHITE MERCEDES BENZ VIN VVl WARREN HULL VV18 AQUARIVA HULL VV YAMAHA Case Document Entered on FLSD Docket Page of TI IN AMERICAN EXPRESS OJFT CARDS TS ADDITIONAL WATCHES T9 ourr AR COLLECTION BA I FIDELITY INVESTMENTS STOCK ACCOUNT IN THE NAME OF SCOTT R01llSTEIN VALUED AT APPROXIMATELY BA2 OIBRALTAR BANK ACCOUNT IN 11fE NAME OF WA WW LLC IN THE APPROXIMATE AMOUNT OF I_ BAJ OlBRALTAR BANK ACCOUN I rN Tira APPROXIMATE AMOUNT OF BA4 OIBRAL TAR BANK ACCOUNT IN THE APPROXIMATE AMOUNT OF BAS OIBRAL TAR BANK ACCOUNT IN THE APPROXIMATE AMOUNT OF BA6 BANK POPULAJRE MOROCCO BANK ACCOUNT IN 1llE NAME OF Scarr ROTiiSTEIN IN nm APPROXIMATE AMOUNT OF BA BANK POPULAIRE MOROCCO ACCOUNT IN 1llE NAME OF AHNICK KHALID UP TO THE AMOUNT OF BAS BANK POPULAIRE MOROCCO ACCOUNT IN nm NAME OF STEVE CAPUTI UP TO THE AMOUNT OF Bil STOCK CERTIFICATES OR BENEFICIAL INTEREST IN SHARES OF CA PIT AL STOCK IN GIBRALTAR PRN ATE BANK TRUST SCOTT ROTHSTEINS EQUITY INTEREST IN QTASK Scorrw ROTIISTEINS EQUITY INTEREST IN BROWARD BANK OF COMMERCE Bf SCOTT ROTHSTEINS EQUITY INTEREST IN BOVA RISTORANTE BIS SCOTT ROTHSTEINS EQUITY INTEREST IN Case Document Entered on FLSD Docket Page of BOVACUCINA Bl6 SCOTT ROTHSTEIN EQUITY INTEREST IN BOVA PlUME Bl7 SCOTI RoTHSTEINS EQUITY INTEREST IN CArt IGUANA PEMBROKE PINES FLORIDA BIS SCOIT ROTHSTEIN EQUITY INrEREST IN CART SHIELD USA LLC Bl9 SCOTT RoTHSTEJNS EQUITY INTEREST IN RENA TO WATCHES SCOTTW RcmtSTEJNS EQUITY INTEREST IN EDIFYLLC Bil I SCOTT ROTHSTEJNS EQUlTY rNTEREST 1N GEORGIO VODKA SCOTTW RcmtSTEINS EQUITY INTERESN SEA CLUB BI13 SCOTTW ROTifSTElNS EQUITY INTEREST IN NORTI-1 STAR MORTGAGE Bl14 SCOTT ROTifSTEINS EQurrY INTEREST IN KIP HUNTER Case Document Entered on FLSD Docket Page of AT I OLD DIXIE fflGHWA BOCA RA TON FLORIDA Bl22 Scarr ROTHSTEINS EQUITY fNTEREST IN AND RENTS DERIVED FROM THB CAR WASH LOCATED AT FEDERAL HIGHWAY BOCA RATON FLORIDA PROMISSORY NOTE BY UNTOLOBE IN PAVOROF SCOTTW ROTHSTEIN ALL EQUITY INTEREST HELD BY OR ON BEHALF OF SCOTr ROTHSTEIN IN VARIOUS CORPORA ONS AND EN11TIF.S Cl IN CAMPAIGN CONTlBUTIONS MADE TO ALEX SINK AND VOLUNTARILY OFFERED AND TIJRNED OVER TO THE UNITED STATES ON BEHALP OF ALEX SINK C2 IN CAMPAIGN CONTRIBUTIONS TO REPUBLICAN PARTY OF FLORIDA FLORIDA ACCOUNT ANO VOLUNTARIL.V OFFERED AND ruRNED OVER TO TH UNITED STATES BY TI-IE REPUBLICAN PARTY OF FLORIDA C3 IN CAMPAIGN CONTRIBUTIONS TO REPUBLICAN PARTY OF FLORIDA FEDERAL ACCOUNT AND VOLUNT ARit OPFERED AND TURNED OVER TO THE UNITED STA TES BY nra REPUBLICAN PARTY OF FLORIDA C4 IN CAMPAIGN CONTRIBt.rnONS TO REPUBLICAN PARTY OF FLORIDA AND VOLUNTARILY OFFERED AND TURNED OVER TO TiiE UNITED SiAIBS BY THE REPUBLICAN PARTY OF FLORIDA CS IN CAMPAIGN CONTRIBUTIONS TO REPUBLICAN PARTY OF FLoRJDA BY ROTHSTEIN BUSINESS ENTITY KNOWN AS WA WW AND vowm ARIL OFFERED AND TURNED OVER TO TI-IE lTED STATES BY THE REPUBLICAN PARTY OF FLORIDA C6 CHARITABLE DONATION TO JOE DIMAOOIO CHD.DRENS HOSPITAL WHICH HOSPITAL ADVISED TiiE UNfraD STA TES OF 1llE DONATION FROM 1l-lE ROTHSTEIN FAMILY FOUNDATION C7 CHARITABLE OONATION TO HOLY CROSS HOSPITAL WHICH HOSPITAL ADVISED Tl-IE UNITED STA TES OF TiiE DONATION FROM TiiE ROTHSTElN FAMILY FOUNDATION Case Document Entered on FLSD Docket Page of CS IN CAMPAIGN CONTRIBUTlONS TO GOVERNOR CHARLIE CRIST AND VOLUNTARILY OFFERED AND TURNED OVER TO THE UNITED STA TES BY THE OFFICE OF CHARLIE CRIST AND C9 ALL FUNDS VOLUNTARILY TURNED OVER TO 1lfE UNITED STA TES IRS/FBI SINCE IN OR ABOUT OCTOBER CN RESPONSE TO PUBLICITY INVOLVING ScOTI ROTHSTEIN Defendants WARRANT OF ARREST IN REM FOR NON-REAL PROPERTIES TO THE INTERNAL REVENUE SERVlCE THE UNITED STA TES 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 of law 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 Claim 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 BY WITNESS THE HONORABLE WILLIAM ZLOCH UNITED STATES DISTRICT JUDGE DA TE lbf STEVEN LARIMORE CLERK UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA ilrlAAi nEl UTYCLERK JEFFREY EPSTEIN Plaintiff IN THE CIRCUIT COURT OF THE FIFfEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Complex Litigation Fla Civ Case No AG SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendants BANKRUPTCY TRUSTEES MOTION FOR PROTECTIVE ORDER Pursuant to Rule Herbert Stettin Trustee of the Bankruptcy Estate of Rothstein Rosenfeld Adler P.A files this Motion for Protective Order and states On November Rothstein Rosenfeldt Adler P.A RRA was put into involuntary bankruptcy That case is pending as In Re Estate of Rothstein Rosenfeld Adler P.A On November Herbert Stettin was appointed Trustee of RRA On November an Order for Relief was entered by this Court On April Plaintiff caused a subpoena duces tecum to be served on the Trustee for production of documents A copy of the subpoena duces tecum is annexed hereto as Exhibit A The Trustees responsibility under the involuntary bankruptcy filing is to wind down the business affairs of RRA In that regard the Trustee has three people in his employ EXHIBIT I rdol Miami Tallabassoo south Biscayne Boulevard Suile Mlam Facsimile Complex Litigation Fla Civ and has various 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 finns 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 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 Boca Raton Farr Lauderdala Miami 1ollohassee South Biscayne Boulevard Suile Miami Florida I Telephone lacslmlle Complex Litigation Fla Civ Respectfully submitted BERGER SINGERMAN Counsel for the Trustee Biscayne Blvd Tenth Floor Miami Florida facsi"Y rJ 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 ofM lloco llafon Fort Lauderdale Miami Tallabassec South islscayne Boulevard suite I Miami Florida Telephone Facslmlle JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendant IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO MOTION FOR PROTECTIVE ORDER COMES NOW L.M by and through undersigned counsel and pursuant to Florida Rule of Civil Procedure and hereby files this Motion for Protective Order regarding the documents and information sought by Plaintiff Jeffrey Epstein in the Deposition Duces Tecum served on Herbert Stettin Trustee in Bankruptcy for Rothstein Rosenfeldt Adler PA RRA and as grounds states as follows L.M is one of many victims of Epsteins sexual exploitation as such her civil lawsuit against Epstein is currently active and pending L.M was represented by attorneys at RRA prior to the collapse of that firm Epstein served a deposition duces tecum on Herbert Stettin trustee for RRA requesting documents and information that are clearly protected by attorney EXHIBIT Case No Motion for Protective Order client and work product privilege See Exhibit A depo duces tecum served on Herbert Stettin as RRA trustee Epstein is attempting to use his lawsuit against L.M as a vehicle to pierce the attorney client and work product privilege and gain access to privileged information related to L.M.s civil action against him Epstein served Requests for Production on Brad Edwards L.M.s attorney who Epstein also named as a Defendant in the instant action that discovery requests identical information to that sought by the Duces Tecum served on Herbert Stettin Appropriate work-product and attorney-client privilege objections were made to those requests See Exhibit Epsteins requests for Production to Brad Edwards and answers thereto The trustee for RRA is effectively standing in the shoes of the former RRA attorneys and clients on issues such as this and thus Epstein cannot request discovery from the RRA trustee to circumvent the privilege The discovery Epstein is seeking should not be allowed as it is clearly protected by privilege WHEREFORE L.M and her counsel respectfully move this Court to enter an Order of protection preventing Epstein from obtaining the discovery he is seeking in his Subpoena Duces ecum to Herbert Stettin Case No Motion for Protective Order CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via U.S Mail and email to all counsel on the attached list on June Gary Farmer Jr Fanner Jaffe Welssing Edwards Flstos Lehrman PL Andrews Ave Suite Fort Lauderdale FL fax Atto Defendant L.M Case No Motion for Protective Order COUNSEL LIST Robert Critton Jr Esquire Michael Pike Esquire Burman Critton Luttier Coleman LLP Banyan Boulevard Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Jack Goldberger Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Jack Scarola Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorneys for Defendant Bradley Edwards Marc Nurik Law Offices of Marc Nurik One East Broward Boulevard Suite Fort Lauderdale FL Fax Counsel for Scott Rothstein JEFFREY EPSTEIN Plaintiff SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M lndiVidually 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 TECUM FOR DEPOSmON 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 a1 Prose Court Reporting NE Avenue Suite Fl 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 CRITTON JR ttomeys for Defendant Jeffrey Epstein Burman Critton Luttler Coleman Banyan Blvd Suite West Palm Beach FL BY J_ JR ESQ For the Court EXHIBIT A EXHIBIT A DEFINITIONS AND INSTRUCTIONS A aoocument 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 extemal 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 flies 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 E.W Jeffrey Epstein Palm Beach County Case Jane Doe Jane Doe Jeffrey Epstein United States District Court Case OB-clv-80893-Marra/Johnson and any other person who Is or was represented by Rothstein Rosenfeldt Adler that has not yet flied 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 aMoneY means any tangible thing of value acosts 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 RRA 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 investorsD 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 Dershowftz 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 limHecl 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 indMduals 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 225Projects 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 0-Task Projects referred to in request nos and All documents communications and letters sent by you assessing liens against the recoveries fn 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 aFortress software program that refer or relate to Jeffrey Epstein All documents from the 225Fortress 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 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 EPSTEINS REQUEST TO PRODUCE TO EDWARDS Defendant JEFFREY EPSTEIN 260Epstein pursuant to Fla Civ requests that Defendant BRADLEY EDWARDS Edwardsa produce or make available for inspection documents responsive to the requests below within thirty days from the date of service DEFINITIONS AND INSTRUCTIONS A Documenr means any written or graphic matter or other means of preserving thought or expression and all tangible things from which infonnation can be processed or transcribed including the orlglnals 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 I II I EXHIBIT 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 tenn Documenf 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 extemal 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 E.W Jeffrey Epstein Palm Beach County Case Jane Doe Jane Doe Jeffrey Epstein United States District Court Case 08-clv-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 aRRAa means Rothstein Rosenfeldt Adler P.A aMoney8 means any tangible thing of value acostsa 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 investigative bills photocopies faxes Westlaw computerized research travel expenses and witness fees and expert witness fees and costs Trusteea means Herbert Stettin as bankruptcy trustee for RRA REQUEST FOR PRODUCTION 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 Due to the potenliaJ volume of documents involved the parties and the Court should consider appolnbnent of a special master and/or an In camera inspection to address any objections claims of privilege and generally manage the production of documents 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 RRA and any investor or third party person or entity regarding Jeffrey Epstein or which mentions Jeffrey Epstein in_cluding 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 Pabick Roberts or Rick Rich Fandrey 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 invoMng Jeffrey Epstein and any of the following a ScottW Rothstein Bradley Edwards RRA any entity fonned 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 AD 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 invoMng 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 the Costs and payment of any bill or Costs in each Plaintiffs case against Jeffrey Epstein and the source for said payments of any Costs All documents received by you or your current firm 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 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 audi 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 AU Intercepted phone conversations authorized by RRA including but not limited to any one of its attomeys or investigators or anyone retained by or working for RRA related to Jeffrey Epstein that are saved or stored 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 or 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 Gofdberger authorized by RRA including but not limited to any one of its attomeys or investigators or anyone retained by or working for RRA All documents supporting the contention that a sexual assault took place on an airplane purportedly owned by Jeffrey Epstein or a Jeffrey Epstein entity at any time between and All documents related to the amount of all Costs that were incurred by you in the representation of you and/or your law firm in representing Jane Doe L.M and E.W prior to joining RRA All documents setting forth to the amount of Costs were incurred by RRA in its representation of Jane Doe L.M and E.W during the time you were employed by RRA or that is being claimed by the Trustee In the attached transcript dated July you stated to Judge Hafele with regard to the E.W and L.M cases the following What the evidence is really going to show is that Mr Epstein at least dating back as far as our investigation resources have permitted back to or has every single day of his life made an attempt to sexually abuse children Were not talking about five were not talking about were not talking about were not talking about which I believe is the number known to law enforcement we are talking about thousands of children and it is through a very intricate and complicated system that he devised where he has as many as people working underneath him that he is paying well to schedule these appointments to locate these girls a A Provide all documents to support this assertion including any documents which are the source of the information All documents related to or mentioning potential deponents In the Jane Doe L.M or E.W cases All documents that support your claim of damages in your counterclaim in this case The written fee agreement with the Searcy Denney firm for their representation of you in this case All emails exchanged between you or anyone of your behalf and one or more of the following individuals wherein Epstein a Palm Beach biflionaire or a similar reference was mentioned a Scott Rothstein Russell Adler William Berger Michael Fisten Kenneth Jenne David Boden Deborah ViDegas Andrew Bamett i Patrick Roberts Richard Rick Fandrey Christina Kitterman A copy of your RRA business card Any employment agreements letter agreements or memos given to you by RRA or a representative or agent of RRA describing your compensation and benefits at RRA All documents and communications from Herbert Stettin as bankruptcy Trustee for RRA asserting liens against recoveries in a L.M Epstein Case No E.W Epstein case No Jane Doe Epstein Case No 08-CV-80119-MARRA/JOHNSON Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was ent by fax and U.S Mall to the following addressees on this 12th day of April Gary Farmer Jr Esq Farmer Jaffe Weissing Edwards Fistos Lehrman PL Jack Alan Goldberger Esq Atterbury Goldberger Weiss PA Australian Avenue South Andrews Avenue Suite Fort Lauderdale FL fax Attorneys for Defendant LM Jack Scarola Esq Suite West Palm Beach FL Co-Counsel for Defendant Jeffrey Epstein MARC NURIK ESQ Searcy Denney Scarola Barnhart Shipley P.A Law Offices of Marc Nurik One East Broward Boulevard Suite700 Palm Beach Lakes Blvd West Palm Beach FL Fort Lauderdale FL Fax Attorneys for Defendant Bradley Edwards Attorneys for Defendant Scott Rothstein BURMAN CRITTON LUTTIER COLEMAN LLP Banyan Boulevard Sulte400 West PalnYl-IA!:al-n By __ ritton Jr Florida Bar Michael Plke Florida Bar Counsel for Defendant Jeffrey Epstein IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendant __ DEFENDANT BRADLEY EDWARDS RESPONSE TO PLAINTIFFS REQUEST FOR PRODUCTION DATED APRIL Defendant BRADLEY EDWARDS hereby files is Response to Request for Production propounded by Plaintiff on April as follows None a Objection relevance not reasonably calculated to lead to the discovery of admissible evidence None Objection as to communications to or from investigators as that is protected by the work-product and or attomey-client privilege Objection any such communications are protected by the work-product and or attorney-client privilege None Objection relevance not reasonably calculated to lead to the discovery of admissible evidence vague overbroad without waiving objection there are no fee agreements with any Investor Case No Edwards Response tD Request for Production dated None None Objection relevance not reasonably calculated to lead to the discovery of admissible evidence Objection relevance not reasonably calculated to lead to the discovery of admissible evidence None None None None None None Objection relevance not reasonably calculated to lead to the discovery of admissible evidence vague overbroad ambiguous Objection relevance not reasonably calculated to lead to the discovery of admissible evidence Objection relevance not reasonably calculated to lead to the discovery of admissible evidence and protected by the work-product privilege Objection vague overbroad and any and all such documents are protected by the work-product privilege Objection vague overbroad and any and all such documents are protected by the work-product and attorney-client privilege Not yet determined case No Edwards Response to Request for Production dated Objection Objection attomey-cfient privilege and/or work-product privilege None in Defendants possession None None in Defendants possession Case No Edwards Response to Request for Production dated CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing has been f"A1CA-vP furnished via U.S Mail to all counsel on the attached 11st on Jack Scarcia Searcy Denney Scarcia Barnhart Shipley PA Attorneys for Defendant Bradley Edwards Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax By la arNo
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