Filing E-Filed PM JEFFREY EPSTEIN Plaintiff/Counter-Defendant SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants/Counter-Plaintiff IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEINS MOTION TO ADDRESS SCHEDULING AND PROFESSIONALISM Plaintiff/Counter-Defendant Jeffrey Epstein Epstein moves to address scheduling and professionalism and states Introduction This Court is committed to and adamant about professionalism Are the Standards and Local Rule No mandatory or discretionary Recent events appeal and stay and the discovery of e-mails that total eviscerate Counter-Plaintiff Bradley Edwards Edwards claims and shines a light on his true motivation have prompted unprofessional behavior from Edwards and his counsel evidenced by the unilateral setting of hearings certificates of conferring that never happened and intentional ex parte attendance at a hearing despite knowing of Epsteins counsels unavailability The tenor of demands by Edwards counsel is more than litigation tactics for which any lawyer trial or appellate should develop a thicker skin Rather Edwards counsels unilateral setting of hearings violation of Local Rule No and failure to acknowledge the FILED PALM BEACH COUNTY FL SHARON BOCK CLERK PM Standards of Professionalism and Civility adopted by this Circuit must end and Epsteins counsel is asking this Court to address it The lack of professionalism serves neither clients nor our profession The Standards Our Oath and Local Rule No Despite our ethic-bound duty to zealously represent and advocate for our clients attorneys practicing in Palm Beach County as well as in South Florida are required to abide by certain standards of professional courtesy Approved in by the Board of Directors of the Palm Beach County Bar Association and endorsed the same year by the judges of the th Judicial Circuit the Standards of Professional Courtesy and Civility Standards are grounded in good-faith civil and respectful communication between counsel See Preamble In the Florida Supreme Court amended the oath of admission to The Florida Bar to include a promise of fairness integrity and civility to the court and opponents in all written and oral communications See Oath of Civility Despite these efforts the advancement of technology and more particularly e-mail required an updating of the Ideals and Goals Thus in May the Florida Bar Standing Committee on Professionalism SCOP was asked by Bar leadership to review and develop uniform professionalism guidelines including electronic communications for statewide distribution The Professionalism Expectations were drafted and approved by SCOP then approved by The Florida Bar Board of Governors on January Id The Standards more The Standards were adopted by Broward Indian River Martin Miami-Dade Monroe Okeechobee and St Lucie Counties The Standards were originally published in expectations locally adopted should be read together with the statewide applicable Professionalism Expectations More specifically applicable to setting hearings and e-mail communication the current ChiefJudge of the Fifteenth Judicial Circuit signed on July an amendment to Local Rule No which had been approved in This rule governs Uniform Motion Calendar UMC and Specially Set Hearings This Local Rule ORDERED that before an attorney may file and serve a Notice of Hearing for a UMC hearing he or she shall attempt to resolve the matter and shall certify the good-faith attempt to resolve The term attempt to resolve the matter was further explained to mean that it Shall require counsel to make reasonable efforts to speak to one another in person or via telephone and engage in reasonable compromises in a genuine effort to resolve or narrow the disputes before seeking Court intervention All parties are to act courteously and professionally in the attempted resolution of the disputes prior to filing and serving a Notice of Hearing including responding timely to counsel who initiated the attempt to resolve the matter See Local Rule No paragraph To ensure the above occurred the Local Rule then requires an officer of the court to certify and shall designate with a check mark or other marking the specific certification that apply Movants attorney has spoken in person or by telephone with the attorney for all parties who may be affected by the relief sought in the motion in a good faith effort to resolve or narrow the issues raised Movants attorney has attempted to speak in person or by telephone with the attorney for all parties who may be affected by the relief sought in the motion The Professionalism Expectations replaced the Ideals and Goals of Professionalism that existed since The July amendment to Local Rule was approved by the Florida Supreme Court on June paragraph One or more of the parties who may be affected by the motion are self represented If a party fails to make a good-faith attempt at resolving the issues this Court has discretion to do certain things including imposing sanctions Id paragraph Record Facts On March at p.m the Fourth District Court of Appeal granted Edwards Motion to Lift the Stay of this case in part On March at p.m Edwards counsel David Vitale Jr of the Searcy Denny law firm requested undersigned counsels availability on Thursday March for a status conference UMC hearing Undersigned counsel promptly responded and advised that they had a conflict on March Counsel thereafter agreed to schedule a UMC hearing on Monday March the very next UMC hearing calendar day On March at p.m Edwards counsel filed a Motion for Status Conference and a Notice of Hearing setting the Motion for UMC hearing on March as agreed Twelve hours later on March at a.m Jack Scarola of the Searcy Denny law firm demanded to know the basis for undersigned counsels unavailability on March stating In the absence of a reasonable explanation for the delay I intend to appear before Hafele tomorrow to address the rescheduling of pretrial issues and trial Exhibit A Although not required to provide such a detailed explanation undersigned counsel in the spirit of professionalism and the conduct expected of both counsel set out in the Standards advised Mr Scarola of the conflict out-of-town travel Mr Scarola refused to accept undersigned counsels representations and instead unilaterally re-noticed the hearing for March knowing undersigned counsel was not available Mr Scarola appeared ex parte before this Court on March in violation of Local Rule No the Professionalism Expectations and the Standards The parties then appeared before this Court on the previously agreed-upon date March with Mr Scarola attempting to have the Court issue orders with a case style change that he had sent to the Court ex parte over objection of Epsteins counsel Exhibit This Court ruled that the case style/names would not be changed until this Court rules or the appellate court rules regarding severance Thereafter the second violation of Local Rule and unprofessional emails from Mr Scarola ensued Later that day at p.m on March Edwards counsel noticed two Motions for hearing without speaking with anyone representing Epstein to clear the dates as required by Local Rule No and the Standards Undersigned counsel Kara Rockenbach e-mailed Jack Scarola at p.m Dear Jack The below/attached was neither cleared with my office nor am I available for the UMC only days away Further it does not comply with local Rule No or our Standards of Professional Courtesy To be clear no one from your office contacted any one in my office regarding your below Notice and Re-Notice of Hearing setting Edwards Motion for Status Conference and Motion to Change Case Caption filed today In one notice of hearing you indicate NIA regarding compliance with Rule No and in the second notice pertaining to case caption change you checked the line attesting to having spoken in person or by telephone with the attorneys for all parties who may be affected by relief sought in the motion in a good faith effort to resolve or narrow the issues raised Yet you have not contacted anyone in my office regarding either motion The verification is inaccurate Had you complied I would have informed you of my longstanding unavailability and discussed the substance of the motion you filed today the intent of Rule No Please refrain from unilaterally setting hearings This is the second time the first being March when you knew Scott and I were both out of town but proceeded to court ex parte In compliance with the Standards we are looking at what our availability is the week of April Please send proposed UMC dates and we will check our calendars We are not available March Sincerely Kara Exhibit Instead of sending proposed UMC dates as requested for the week of April only days away Mr Scarola responded by demanding Scott Links and Jack Goldbergers availability for the UMC only three business days away Inaccurately Mr Scarola stated that we have communicated repeatedly regarding your position on changing the case style and indicated here is nothing to discuss which is why he indicated NIA for the Local Rule No certification This simply is not the intent of Local Rule No the Standards nor the Professionalism Expectations Epsteins counsel seek this Court to address scheduling and professionalism Undersigned counsel informed Mr Scarola of the same in the most sincere words Jack weve had enough of your unprofessional behavior We will be seeking the assistance of the court Stop with the bullying tactics and unprofessional behavior Youve been a lawyer for a really long time with a really great reputation Please refrain from such unbecoming behavior Honestly Ive had a lot of respect for you over the years You are better than you are acting recently Its just a case Exhibit Before this motion could even be drafted let alone filed Mr Scarola continued the electronic barrage with successive emails a a.m We will be setting a series of UMC hearings on all pending motions Should you choose not to respond to this request by the close of business today we will set these hearings unilaterally no time to respond a.m I suggest you set your motion to sanction me on Thursday I will not object to the short notice This may be just a case to you but for me it is about this Picture of Oath of Attorney without the updated Oath of Civility Exhibits and Mr Scarola also continues to demand hearing availability for Jack Goldberger Epsteins criminal counsel who is co-counsel in this case As Mr Scarola well knows and has been reminded Link Rockenbach has taken the lead role in this case and has been drafting court filings and handling the majority of the hearings Mr Scarola simply cannot dictate who Epstein chooses to handle hearings in this case ARGUMENT Undersigned counsel was readily willing to professionally forego the five-business-day notice requirements of the Standards and agreed to set the status conference on Monday March two business days after the Thursday March date initially proposed by Edwards counsel Edwards counsel agreed to the March date as well and then about faced and demanded that the hearing be held on March There was no emergency that required Edwards counsel to short-set the hearing for March There is no justification for Edwards counsel to appear ex parte before this Court on March knowing undersigned counsel were out of state There is no excuse for Edwards counsel to place this Court in the untenable position of turning away an ex parte appearance as presented by Jack Scarola on March Thereafter the parties appeared before this Court on March as originally agreed upon Because Mr Scarola did not receive the ruling he sought on changing the case style/name the unilateral setting for hearing of two motions occurred This action was compounded by the plainly inaccurate certification by Mr Scarola that the parties had discussed the case style change issue we never did Although Mr Scarola may have read Epsteins Motion which objected to the case name/style change the parties never substantively discussed it Never When this was plainly pointed out along with the unavailability for the unilaterally set UMC hearing only three business days away Mr Scarola continued the unprofessional behavior and attempted to justify his local rule certifications Edwards counsel has acted in violation of the Professionalism Expectations identified above the Standards of Professional Courtesy and Civility Local Rule No and the Florida Rules of Civil Procedure by unilaterally setting the hearing on a date when Epsteins counsel was not available Continued behavior by Edwards counsel in failing to propose dates as requested for the week of April and violating the spirit if not the rule of the Standards and the Professionalism Expectations on setting future motions during the appellate interim require Epsteins counsel to seek this Court to address scheduling and professionalism Undersigned counsel is confident this Court will not tolerate violations of Local Rule No and unprofessional conduct with the scheduling of hearings Conclusion The lead lawyers on both sides of the have 30-plus years of experience including high profile contentious litigation with important legal issues And Yes both sets of lawyers are and will continue to be zealous advocates for their clients however compliance with the Local Rules and Professional Standards is not a choice Epsteins counsel requests this Court to address scheduling and professionalism Epstein requests this Court enter an order setting dates and times for pending motions require that Edwards counsel comply with Local Rule No and that the parties focus on the trial preparation of this matter Anything less is a waste of judicial resources CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on March through the Courts e-filing portal pursuant to Florida Rule of Judicial Administration LINK ROCKENBACH PA Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Rachel Glasser FBN Primary Scott linkrocklaw.com Primary Kara linkrocklaw.com Primary Rachel linkrocklaw.com Secondary Tina linkrocklaw.com Secondary Troy linkrocklaw.com Secondary Eservice linkrocklaw.com Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Jack Scarola Karen Terry David Vitale Jr Searcy Denny Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach FL mep searcylaw.com jsx searcylaw.com dvitale searcylaw.com scarolateam searcylaw.com terryteam searcylaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Edwards Pottinger LLC Andrews Avenue Suite Fort Lauderdale FL brad epllc.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Jack A Goldberger Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL goldberger agwpa.com smahoney agwpa.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Philip Burlington Nichole Segal Burlington Rockenbach P.A Courthouse Commons Suite West Railroad A venue West Palm Beach FL pmb FLAppellateLaw.com njs FLAppellateLaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Marc Nurik Law Offices of Marc Nurik One Broward Boulevard Suite Ft Lauderdale FL marc nuriklaw.com Counsel for Defendant Scott Rothstein Paul Cassell University Salt Lake City UT cassellp law utah edu Limited Intervenor Co-Counsel for L.M E.W and Jane Doe Jay Howell Jay Howell Associates Cesery Blvd Suite Jacksonville FL jayhowell.com Limited Intervenor Co-Counsel for L.M E.W and Jane Doe EXHIBIT A Tina Campbell 267From Sent Jack Scarola JSX Searc:yLaW.com Wednesday March AM ott J.Link Tina Campb II Phil Burlingt Paul CasseU njs flappeilatelaw.com MaryMcCann Kimberly Marsh Karen This e;.mail may contain privileged or confidential information If it is not 1eaht for you please delete itand 11otify LI immediately Please confirm receipt of time sensiUv co1munications because email deliveries may be layed or unsuccessful We do not provide tax advice bur communications may not be relied Upon to avoid halties thatmay Qe imposed by the Internal Revenue Service ry1ar20 PM,,David VitaleJr dvitale searcylaw.com wrote Sorry but doesthat mean that rieithetyou or Kara areavaiiable for hearing on Thursday David VitaleJr Esq Searcy Denney Scarola Barnhart and Shipley P.A Palm Beach Lakes Blvd West Palm Beach FL Office Cell Fax dvitale searcylaw.com w;searcylaw.com image001.jpg I From ScottJ Link 267mailto:Scott linkrocklaw.com Sent March PM To David P.VitaleJr dvitale searcylaw.com I Cc Kara Berard Rockenbach Kara linkrocklaw.com Tina Campbell Tina linkrocklaw.com Kimberly Marsh kmarsh searcylaw.com Mary rvic 242ann mmccann Searcylaw.com jack Scarola JSX SearcyLaw.com Chris Rodgers crodgers SearcyLaw.com Karen E;Terry EXHIBIT Tina Campbell From Sent David Vitale Jr dvitale searcylaw.com Wednesday March PM To Scott Link Cc Kara Berard Rockenbach;Jack Scarola Tina Campbell Karen Terry brad epilc.com Rachel Jenny Glasser Jack Goldberger Subject RE Epstein Ed1Nards PrQposed Orders You may do Vhat you believe is appropriate as will we David Vitale Jr Esq SearcyDenney Scarola Barnhartand Shipley P.A Palm Beach Lakes Blvd West Palm Beach FL Office Cell Fax dvitale searcylaw.com w.searcylaw.com __ From Scott Link mailto:Scott iinl rocklaw.com Sent March 2biff Pl To David Vitale Jr dvitale searcylaw.com Cc Kara Berard Rockenbach Kara linkroddaw.com JackScarola JSX Sea_rcyLaw.com Tina Campbell Tina linkrncklaw com Kare11.E This mail may contain privileged or confidential information it is not meant.for you please delete it and_ notify us im1edictt_ IY Please confirm receipt of time sensitive c9mmunjcations pecause email deliveries may be delayed or UIJ 247UccessfuL Ne do not provide tax advice Our c9mrnunications may not be relied upon to avoid penalties that may be imposed by the Internal Revenue Service On Mar at Prv1 D_avid Vifale Jr dvitale searcylaw.com wrote No your office circulated them this morning and asked whether you had ouf approval to submit them to the Court Given thatwe disagree we wont be able to submit a single order on each matter and will simply submit two competing orders.That would seem to eliminate the need for a UMC hearing on a 267motion that hasnt yet been filed David Vitale Jr Esq Searcy Denney Scarola Bafnha"rt and Shipley P.A Palm Beach Lakes Blvd West Palm Beach FL Office Cell Fax dvitale searcylaw.com w.searcylaw.com image00l.jpg From Scott un mailto:Scott linkrocklaw.corri Sent March PM To David Vitale Jr dvitale searcylaw.com Cc Kara Berard Rockenbach ara linkrocklaw.com fack Scarnla JSX SearcyLaw.com Tin_a Campbell Tina linkrocklaw.com _Karen E.Terry image003.jpg This e-mail may contain privileged or confidential information If it is not meant for you please delete it and notify us immediately Please cqnfir1 receipt of time sensitive communications because email deliveries may be delayed or unsuccessful We do not provide tax advice Our communications may not be relied upon to avoid penalties that may be imposed by the Internal Revenue Service 6n Mar2.1 at _PM Davjd P._Vitc1le_Jr dvitale searcylaw.com wrote Having received no clarification we will submit both sets of oraers and Will note your general Objection to our orders as well as your specificobjection to the case style _used in our submissions Thanks David David Vitale Jr Esq Searcy Denney Scarola Barnhart _and Shipley P.A I Beach Lakes Blvd West Palm Beach FL Office Cell Fax dvitale searcylaw.com w.searcylaw.com imageO0l.jpg From David Vitale Jr Sent March PM To Kara Berard Rockenbach Kara linkrocklaw.com Cc Jack Scarola JSX SearcyLaw.com Tina Campbell Tina linkrncklaw.com Karen Terry On Mar at PM Kara Berard Rockenbach Kara linkrocklaw.com wrote David I disagree and object again to you submitting orders that without a hearing unilateraHy change the style of the case I will notice both sets of orders for Mondays UMC Sincerely Kara image003.jpg Kara Bera rel Rockenbach LINK ROCKENBACH PA 15Palm Beach Lakes Blvd Suite West Palm Beach FL office I cell fax I Email kara linkrocklaw.com This e-mail may contain privileged or confidential information If it is not meant for you please delete it and notify us immediately Please confirm receipt of time sensitive communications because email deliveries may be delayed or unsuccessful We do not provide tax advice Our communications may not be relied upon to avoid penalties that may be imp_osed the Internal Revenue Service From David P.Vitale Jr.mailto:dvitale searcylaw.com Sent Wednesday rvlarch AM To Kara Berard Rockenbach Kara linkrocklaw com Cc Jack Scarola JSX SearcyLaw.com TinaL Campbell Tina linkrocklaw.com Karen On Mar at AM Kara Berard Rockenbach Kara linkrocklaw.com wrote David We do not agree to your submitting your edited style changed orders Please set for an on Monday March Thank you Kara image00l.jpg Kara Berard Rockenbach LINK ROCKENBACH PA Palm Beach Lakes Blvct Suite West Palm Beach FL office I cell fax I Email kara linkrocklaw.com This e-mail may contain privileged or confidential information If it is not meant for you please delete it and notify us immediately Please confirm receipt of time sensitive communications because email deliveries may be 267elayed or unsuccessful.We do not provide tax advice Our communications may not be relied upon to avoid penalties that rnay.be_impe sed by the Internal Revenue Service From David P.Vitale Jr mailto:dvitale sea rcyiaw co ml Sent Weqnesday M.arch To Kara Berard Rockenbach Kara linkrocklaw.com Cc:Jack Scarola JSX Searcylaw:com Tina Campbell Tina linkrocklaw.com Kare_n Terry Sent from my iPhone Please excuse anytypos or errors On Mar at Kara Berard.Rockenbach Kara linkrocklaw.com 267wrote David Thank you for sending these;.We cannot agree to change the captionand we object to your edits Sincerely Kara image00l.jpg Kara Berard Rockenbach LINK ROCKENBACH PA Palm Beach Lakes Blvd Suite West Palm Beach FL office I cell fax Email kara linkrocklaw.com This mail may contain privileged or confidential information If it is not meant for you please delete it and notify us immediately Please confirm receipt of time sensitive communications because email deliveries may _be-delayed or unsuccessful We do not provide tax advice Our communications may not be 267relied upon to avoid penalUes that may be imposed by the Internal Revenue Service From David P.VitaleJr mailto:dvitale searcylaw.com Sent Wednesday March To 267Jack Scarola JSX SearcyLaw.com Tina Campbell Tina linkrocklaw.com Cc Karen E.Terry Our proposed edits are.attached Thanks David David Vitale Jr Esq._ Searcy Denney Scarola Barnhart and Shipley P.A Palm Beach Lakes Blvd West Palm Beach FL Office Cell Fax dvitale searcylaw.com w.searcylaw.com image001.jpg From Jack Scarola Sent March AM To Tina Campbell Tina linkrocklaw.com Cc Karen Terry Jack had approved this before the stay Order Denying in Part and Reserving in Part on Epsteins Motion for Protective Order and in Liniin of Unrelated Settlements we have i11corporated Davids cha11ges from March 6th and cleaned up soine formatting issues and Order Denying Ep_steins Motion to Strike Dr Jansen Please let us know if we have your approval to submit these Orders to the court Thank you image0Cll.jpg Tina Carnpbell CP/FRP Certified Paralegal I LINK ROCKENBACH PA Palm Beach Lakes Blvd Suite West Palm Beach FL office I fax I Emai_l tina linkrocklaw.com This e-mail may contain privileged or confidential information If it is not meant for you please delete it and notify us immedia_teiy Please confirm receipt of time sensitive communications because email deliveries may be delayed or unsuccessful We do not provide 267tax advice."Our.communications may not be relied upori to avoid pena lies that may be imposed by the 225lnternal Revenue Service Proposed Order on MIL re Sex Offer,de Registry.docx Proposed Order Denying Epsteins Motion to Strike Jansen.docx Proposed Qrder onl lotion re Settlement Disclosures FINAL.DOCX Privileged and Co11fidential I Electronic communication is not a secure mode of communication and EXHIBIT Tina Campbell From Sent To Cc Subject Attachments Dear Jack Kara Berard Rockenbach Mo11day March P_M Jack Scarola Karen EX 267HIBIT Tina Campbell __ From Sent To Cc Scott Link Monday March PM Jack Scarola Kara Berard Rockenbach Karen E.Terry David VitaleJr.;Tiria Campbell Jack Goldberger;smahoney agwpa.com Rachel Jenny Giasser 267MaryMc:Cann Subject Re SERVICl OF COURT DOCUMENT CASE NUMBER EPSTEIN JEFFREY ROTHSTEIN SCOTT Jack weve had eiiough ofyotirunpro:fess10fuil behavior We will be seeking the assistance of the court Stop withJhe bullying tactics and unprofessional behavior Youve been a lawyer for a reaUylong time with a really great reputation Please refrain from such unbecoming beliavior Honestly Ive had alotof respect for you over the years You are better than you are cth1g i:ecently Its just a case Scott Scott Link Boctrd Certified Business Litigation LINK ROCKENBACH PA Palrp Beach Lakes Blvd Suite West Palm Beach FL office fax I Email scott linkrocklaw.com LINK ROCICENBACH PA CIVIL TRIAL APPELLATE LAW This e-mail may contain privileged or.confidential information If it is notmeant for you please delete it and notify Us immediately Please confirm receipt of time sensitive communications because email deliveries may be delayed or Unsuccessful We do not provide tax adviGe QurGomrnunications may not be relied upon to avoid penalties that may be imposed by the Internal Revenue Service On Mar at PM Jack Scarola JSX SearcyLaw.com wrote have addressed your unavailability You have not addressed Scott;s unavailability or Jack Goldbergers.Are any of the three of you available on Wednesday We haye communicated repeatedly regarding your position on changing the case style Have you chai1ged your mind There.is nothing to discuss"regai;ding the needfola status conference which is whyI indicated that communication Was.not applicable OnMar a.t PM Kara Berard Rockenbach Kara linkrocklaw.com wrote Dear Jack EXHIBIT Tina Campbell From Sent To Cc Subject jack Scaroia JSX SearcyLaw.com Tuesday March AM ScottJ Link Karc1 Berard Rockenbach Kare11 E.Terry David Vitale Jr.;Tina LCampbell;Jack Goldberger smahoney agwpa.com Rachel Jenny Glasser Mary McCahn Re SERVICE OF COURT DOCUMENT CASE NUMBER XXMB EPSTEIN JEFFREY ROTHSTEIN SCOTT We wiffbe setting a series ofUMG hearings on all pending motions jury instructions vei:dictfor:tr1 ari.d deposition designation objections Please J:Jrovide the dates of availability of Epsteins lawyers over the course of the next thi weeks All pending motions will be 267notfoed for,hearing in the order in which they were filed Should you choose riot to respond to this request by the close of business today we willset these hearings unilaterally EXHIBIT Tina Campbell From Sent To Cc Subject Jack Scarola JSX Searcylaw:com Tuesday March AM Scott Link Kara Berard Rockenbach Karen E.Terry;David Vitale Jr.;Tina Campbell Jack Goldberger sinahoney agWpa.com Rachel Jenny Glasser;.Mary Mc:Cann Re SEIWICE OF:COl,JRT DOCUMEf JTC:A?E NUMBER EPSTEIN JEFFREY ROTHSTEIN SCOTT I suggest you set your motion to sanction me on Thursday twill not objectto the short notice This may be just acase"to you but forme it is about this ti 3fo st rt i i 1Ai Mar PM Scott J.Link Scott linkrocklaw.com wrote A A 4A E0 A4 DE a qr?q rq qrCX HhL Kg lg d?a d6U a M3 flW y??S m/y t0 I F/Z V/j 1a qC KS u?v vZ O5 a qr rCX qC 0V I I dc rM?M rM 10Cy n??m?n k?o?h I A I w?!ac qr MCX 10Cy ITy qr M3 Ґ??1rA5R h?H?T3P K?z X?K I v"x i X5 EO5 5a r?q CX 9r Cy rq rqC M3 ş?:c p/p0 5H V)V 6T Y2 G5 qrM?r?qr?r9 q?10Cy rCX qr l1 X?l 3K fm?Q Z2f CX CX gT L??T 2E Cy 3P EM3 J4T L?h??M q?ᡚ?Y r??O?rJt CTX i 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