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order A copy of Judge Rays Order is attached as Exhibit to this motion Retired Broward County Circuit Judge Robert Carney has begun the process of reviewing the documents and hearing initial arguments on the privilege issue The Plaintiff needs to obtain all unprivileged documents and depose knowledgeable witnesses to properly prepare for trial The documents are crucial to the Plaintiffs preparation of his claim It is highly unlikely the Plaintiff will be able to obtain these records in time for the Plaintiff to conduct the necessary discovery in order to be ready to try this case on its presently set docket The Plaintiff anticipates that after receiving and reviewing these records that amendments to his pleadings will need to occur While a default has been entered against Defendant Rothstein there is a pending motion to set aside the default together with a motion to strike the affidavit of Mr Rothstein seeing to set aside the default If the court sets aside the default the case will no longer be at issue Defendant Edwards frequently invoked the privileges of work product and attorney client for his answers to his deposition which require a ruling by the court Further if the Epstein Rothstein et al Case No Plaintiffs Motion for Continuance documents from the Bankruptcy trustee are produced Defendant Edwards needs to be deposed on those documents Initial sets of discovery requests have been propounded by the Plaintiff and Defendant Edwards to which objections have been made and a court ruling will need to be made The Plaintiff anticipates at this time that the number of witnesses who may have relevant unprivileged knowledge of the issues in this case are likely to exceed twenty-five people It is not possible realistically to depose these people until the records are reviewed from the Bankruptcy Trustee and all privilege claims are resolved The Defendants will not be prejudiced by the Court granting Plaintiffs Motion for Continuance The filing of this Motion is made in good faith and not for the purposes of delay WHEREFORE Plaintiff Jeffrey Epstein by and through his undersigned counsel requests this Court to enter an Order granting his Motion for Continuance and striking this case from the Jury Trial Docket presently set in this matter on the eight week docket beginning October for the reasons stated above CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true agd correct copy of the foregoing has been duly furnis!m,_ via lFEmail Facsimile Wf_J.S Mail Hand Federal Express this lif_"aay of August to Gary Farmer Jr Esq Farmer Jaffe Weissing Edwards Fistos Lehrman PL Andrews Avenue Suite Fort Lauderdale FL Epstein Rothstein et al Case No Plaintiffs Motion for Continuance Jack Scarola Esq Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Blvd West Palm Beach FL Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian A venue South Suite West Palm Beach FL Marc urik Esq Law Offices of Marc Nurik One Broward Blvd Suite Ft Lauderdale FL nat MOTCON47-Motion for Continuance Epsteins JLA By Jos hL.Ackerman,Jr Fla Bar No FOWLER WHITE JEFFREY EPSTEIN Plaintiff SCOTT ROTHSTEIN individually BRADLEY EUW ARDS individually and L.M 1ndividua1ly Defendanls IN THE CIRCUIT COURT Of TTIE ST I UDTCIAL CIRCUIT IN ANO FOR PALM BRACH COUNTY FLORIDA GENERAL JURISDICTTON DIVISION CASE NO CA XX.XXMB AG CONSENT OF PLAINTTFF JEFFREY EPSTEIN TO MOTION TO CONTINUE TRIAL PLEASR TAKE NOTICE thatthe Plaintiff.Jeffrey Epstein,pursuantto Fla R.Jud.Adrnin gives his consent to a Mot.ion for Continuance 1fthc Trial of this matter presently set for the eight wcckjury trial docket beginning October DATED this day of August EXHIBIT FOWLER WHITf lit IKNt:"t"T P.A lHII.J.tPS POINT TOWER SUIT I SOUTH Ft Glt;Rl RJVf WP.ST lALM UcA Fl.ORIDA I I Case Doc Filed Page of AN ORDERED in the Southern District of Florida on INRE Raymond Ray Judge United States Bankruptcy Court UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION w.flsb.uscourts.gov ROTHSTEIN ROSENFELDT ADLER P.A CASE NO CHAPTER Debtor ORDER RESPECTING PRODUCTION OF DOCUMENTS REGARDING JEFFREY EPSTEIN THIS CAUSE came before the Court for hearing on August upon i Motion to Compel Production of Documents from Trustee Pursuant to Document Production Protocol as established by D.E D.E ii Motion for Protective Order filed by Interested Party Farmer Jaffe Weissing Edwards Fistos and Lehrman P.L Farmer Jaffe D.E and its related amendment D.E The Court heard argument of all counsel present at the hearing and being otherwise duly advised in the premises EXHIBIT Case Doc Filed Page of DOES HEREBY ORDER The Court appoints former Broward County Circuit Judge Robert Carney as Special Master who shall work with counsel for the Trustee to obtain documents responsive to the subpoena served upon the Trustee by Jeffrey Epstein to i review all electronically stored information ESI and other documents in the Trustees possession including Qtask data for purposes of determining the applicability of the attorney/client and work product privileges that may inure to the benefit of L.M Brad Edwards and other current or former clients of Farmer Jaffe ii segregate any such privileged documents and i prepare a privilege log in accordance with standard practice and law Prior to engaging in this document review the Special Master shall meet with counsel for Epstein counsel for Farmer Jaffe and counsel for the Trustee to hear their respective positions concerning these matters Upon completion of the review by the Special Master the Special Master shall prepare and file a privilege log with the Court No documents or ESI shall be released to anyone until such time as the Special Master has notified the Court that he has concluded his review of the responsive documents and is in a position to report to the Court his findings and to obtain further instruction Upon the filing of such notice by the Special Master the Court shall set a continued hearing on the pending motions identified above All legal fees and costs incurred by the Special Master shall be paid by Epstein who has agreed to pay directly all such fees and costs Case Doc Filed Page of Submitted by Charles Lichtman Esq BERGER SINGERMAN P.A East Las Olas Boulevard Suite I Fort Lauderdale FL Telephone Facsimile clichtman bergersingerman.com Copy furnished to Charles Lichtman Esq Charles Lichtman is directed to serve this Order to all parties of interest and to file a Certificate of Service
