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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 Edwards asks this Court to stay enforcement of its subpoenas for a brief period of time to permit this Court to first rule on the pending motion for summary judgment on all of Epsteins claims that have been filed by Edwards If any of Epsteins claims somehow survive the pending summary judgment motion then this Court could rule on the proper scope of the subpoena and any privilege or other issues which remain to be litigated Edwards proposes a schedule to rapidly bring these issues to resolution and urges the Court to adopt it Edwards also requests a protective order narrowing the scope of the production requests made by Epstein and requiring billionaire Epstein to pay all reasonable costs associated with responding to his discovery requests BACKGROUND FACTS As this court is well aware from a summary judgment motion filed by Edwards Plaintiff Jeffrey Epstein a convicted sex offender has sued legal counsel Bradley Edwards Esq for conduct that occurred in the course of Edwards representation of multiple young female victims of Epsteins sexual abuse Edwards filed and pursued civil lawsuits against Epstein to recover damages for Epsteins extensive pattern of molestations In retaliation and to try and intimidate Edwards and his young clients Epstein brought this lawsuit in this court alleging that Edwards had somehow fabricated and/or exaggerated the claims Edwards has now filed a comprehensive motion for summary judgment against Epstein detailing how he is entitled to judgment on each and every one of Epsteins frivolous claims Epstein has yet to file any response to Edwards comprehensive summary judgment motion Nonetheless he continues to harass Edwards through discovery requests connected with this case In particular on April Epstein propounded an extremely broad Request for Production RFP to Edwards See Exhibit A Containing some different requested items the RFP seeks all sorts of electronically stored information including a raft of internal emails between Edwards and other attorneys paralegals expert witnesses investigators and others who worked on the civil lawsuits against Epstein On May Edwards duly responded to the request for production Through his legal counsel Edwards noted that many of the requests sought attorney-client or work-product privileged information and others were overly broad and unduly burdensome See Exhibit While Edwards was raising his objections to the subpoena lodged against him Epstein duplicated his requests by serving a separate subpoena for the same information On April four days after making the requests to Edwards without waiting for his responses to the requests much less a court ruling on Edwards objections Epstein served a subpoena duces tecum for documents on bankruptcy court-appointed trustee Herb Stettin A bit of background may be helpful here Mr Stettin never represented any of the underage females who had been sexually abused by Epstein Instead Mr Stettin has possession of certain records related to this case and many more entirely unrelated to this case because he was court-appointed as bankruptcy trustee for the now-defunct law firm of Rothstein Rosenfeldt Adler RRA Edwards had a brief connection to RRA For a short period of time during his representation of his young clients Edwards was employed by RRA It was then revealed that the law firm president Scott Rothstein had been running a criminal Ponzi scheme out of the law firm Shortly after learning of the fraud Edwards left RRA Later RRA declared bankruptcy and the bankruptcy court appointed Herb Stettin trustee of the estate of RRA charging him with handling financial claims regarding the assets of the firm RRAs electronic database including all electronically stored files and emails were left in the possession of Stettin Because Stettin was not involved in the sexual abuse litigation against Epstein he does not have detailed knowledge of the persons or subjects discussed in the various e-mails and other records On June a hearing was set before this court on Epsteins Motion to Compel the Trustee to produce the documents responsive to Epsteins subpoena On that date Stettins counsel Edwards counsel and counsel for Epstein all met in the hallway outside the courtroom and worked out an agreed resolution to the dispute All counsel agreed that Stettin would tum over to Edwardss counsel all documents responsive to the subpoena and that Edwards counsel would then prepare a privilege log and produce all documents that are not subject to objection or privilege At that point Epstein could pursue any further arguments that he wanted in this Court regarding materials not produced As a result of the agreement the Court never held the hearing on the Motion to Compel Epsteins counsel agreed to draft a proposed consent order for all the parties Despite the agreement between the parties Epsteins counsel never prepared that agreed order Instead Epstein decided to launch litigation in yet another forum the United States Bankruptcy Court for the Southern District of Florida On July Epstein filed a Motion to Compel production of numerous documents from Trustee Stettin in the bankruptcy proceeding being overseen by the bankruptcy court Judge Raymond Ray See Jeffrey Epsteins Motion to Compel Production of Documents from Trustee Pursuant to Document Production Protocol Established by DE In re Rothstein Rosenfeldt Adler Case No DE attached as Exhibit In his motion Epstein recounted that he had served a subpoena on the trustee See id at Epstein did not inform the bankruptcy court however that he was seeking the same information from Edwards and that Edwards had raised claims of privilege Nor did Epstein mention that he had previously filed a motion to compel before this Court Instead Epstein claimed to the bankruptcy court that roduction of these documents from the Trustee is critical to issues in the state court lawsuit Without access to the emails in question Movant will suffer unfair prejudice and will be unable to obtain information critical to his lawsuit Id at Epstein also stated that he was willing to reimburse the Estate for its reasonable expenses incurred in reviewing the documents for privileged matters and preparing a Privilege Log Id at In response on July Edwards filed a Motion for Protective Order DE Exhibit and an amended Motion for Protective Order DE Exhibit to restrict this production so that privileged or other non-discoverable material was not produced A hearing was held on that Motion and on August the bankruptcy court entered an Order that appointed as Special Master former Broward County Circuit Judge Robert Camey to take all materials responsive to the subpoena from Stettin and to prepare a privilege log DE Exhibit Special Master Camey did take possession of the materials however after reviewing the materials he immediately realized that there were obvious problems if he the Special Master prepared a privilege log Specifically lacking familiarity with the sexual abuse litigation the Special Master had no way to determine which materials were relevant and of those relevant materials which were privileged Moreover the privileges were not the Special Masters to assert or waive Rather the attorney-client privilege and other privileges were held by clients of Edwards and Edwards himself As a result of these problems on September Special Master Carney filed a Motion to Clarify Order Appointing Special Master DE Exhibit On September Edwards then filed another Motion for Protective Order DE attached as Exhibit In that motion Edwards explained that Epstein asks this Bankruptcy Court to usurp the properly exercised jurisdiction of the Circuit Court over a subpoena duces tecum issued by the state court in connection with an action pending before the state court Id at Edwards further noted that he had previously objected to this information being turned over in state court and that this was Epsteins attempt to backdoor his way into obtaining information to which he is not entitled Id at On October the bankruptcy court entered an amended order modifying the production procedures and the role of the Special Master DE attached as Exhibit I In this Amended Order Respecting Production of Documents Regarding Jeffrey Epstein the bankruptcy court directed the Trustee to produce all of the materials in question to Edwards law firm Farmer Jaffe Weissing Edwards Fistos Lehrman Farmer Jaffe was then directed to produce a privilege log of all materials The privilege log was to be provided to the Special Master The Special Master was in turn to schedule a hearing where all parties in interest will have the opportunity to provide written submissions respecting the privilege log and to make argument on all issues relevant to the applicability of privilege as to the documents listed on the Farmer Jaffe privilege log That hearing shall be transcribed by a court reporter Id at Then following completion of the aforementioned hearing the Special Master shall prepare a report making all appropriate findings and recommendations to the Court which shall be served on all parties in interest and filed with the Court along with the transcript of the Special Masters hearing If an objection to the report is filed by any party in interest then this Court shall schedule and hold a hearing to resolve with finality the issues of privilege as consistent with the appropriate law and procedures set forth herein Id Following the entry of this order Trustees counsel delivered several disks containing more than pages of materials to Farmer Jaffe Some of these materials are e-mails from the RRA computers and other materials are electronically stored case files containing pleadings discovery correspondence between counsel and other case related materials While some of these materials are connected with the Epstein litigation many of them are not Most of the materials do not appear to be responsive to the Epstein subpoena originally served On November Edwards filed a motion in bankruptcy court requesting relief from the Amended Order See Motion for Relief from Amended Order DE and to Compel Jeffrey Epstein to Pay for the Production of all Documents in Response to His Request DE Attached as Exhibit It was then also discovered that the disks provided to Edwards were not identical to those provided to Special Master Carney and a meeting was set up between Special Master Carney and Edwards to compare the disks and get the correct disks in Edwards hands to begin review of the materials As a result on November Special Master Carney met with Edwards The disk problem was sorted out and Edwards was then provided the same materials that Special Master Carney had from which Edwards was ordered pursuant to DE to begin preparing a privilege log During the meeting with Special Master Carney it became apparent that the result of Edwardss creation of a privilege log and his anticipated objections to the production of irrelevant and privileged materials was on a path for a hearing ultimately before the bankruptcy court ruling on the scope of this Courts subpoena and possible restrictions from it DISCUSSION THIS COURT RATHER THAN THE BANKRUPTCY COURT IS THE PROPER FORUM FOR LITIGATING THE SCOPE OF SUBPOENAS SERVED IN THIS CASE As is apparent from the foregoing recitation of the facts Epstein has taken his meritless retaliatory lawsuit against Edwards into a different court the bankruptcy court and then sought to have rulings on the application of privileges in this Courts case made by that court This backdoor approach is not proper as the issues surrounding this Courts subpoenas belong before this Court for several reasons First and foremost Epstein is now deploying his retaliatory lawsuit to burden Edwards and other lawyers at his firm with requests to review tens of thousands of pages of documents for privilege claims and other discovery issues Because the Trustee has produced what amounts to every single piece of paper that even remotely relates to an Epstein case rather than just those documents responsive to the subpoena Edwards is now forced to review more than documents to create a privilege log While it might be appropriate to force the attorneys to review some portion of those documents if a viable lawsuit were at hand Epsteins lawsuit is entirely meritless As explained at length in Edwards pending motion for summary judgment Epsteins case should be summarily rejected for three separate reasons First under the well-established sword and shield doctrine Epstein cannot assert a Fifth Amendment privilege to deny access to relevant discovery about his lawsuit while simultaneous trying to force Edwards to pay damages Second because Epstein has repeatedly taken the Fifth when asked numerous relevant questions about his lawsuit no reasonable jury could find in his favor And third and most fundamentally Epsteins lawsuit completely lacks any factual basis whatsoever and does not even make an attempt at alleging a viable damage theory If the Court were to agree with Edwards and grant his summary judgment motion on any of these three separate grounds then it seems likely that the entire discovery dispute surrounding Epsteins subpoenas to Edwards and the trustee would be considerably narrowed or perhaps even eliminated entirely It makes no sense that extensive satellite litigation is on-going in the bankruptcy court about subpoenas in Epsteins case when Epsteins case itself is meritless and malicious Of course the bankruptcy court has to assume that Epsteins case has merit as it is bound to recognize a presumptively valid subpoena that Epstein has issued through this Court Only this Court can rule on the lack of merit to Epsteins case and then narrow or eliminate this separate litigation about the subpoenas Second even assuming arguendo that Epsteins case could survive the pending summary judgment motion the bankruptcy court is simply not the proper forum for determining privilege claims in this case Without in any way challenging the legal acumen of the bankruptcy court the ultimate issues of privilege in this case must be decided by this Court Whatever the bankruptcy court may conclude about certain privilege arguments in the context of discovery this Court will have to ultimately rule on those privilege claims at trial It makes no sense to have two different judges taking time to rule on the same issues Rather one court should make one binding ruling one time on the privilege issues The only court that can issue a final ruling Even if the Court grants summary judgment for Edwards this case will continue before this Court on Edwards counterclaim against Epstein controlling at trial is this Court Therefore this Court should rule on the discovery issues as well Third only this Court can fairly evaluate Edwards claims regarding the scope of the subpoenas Epstein has issued through this Court extremely broad subpoenas which are unduly burdensome on Edwards and his law firm Yet the bankruptcy court does not have authority to grant relief from those subpoenas only this Court can do that Under rule of the Florida Rules of Civil Procedure the trial judge may limit or prohibit discovery to protect a party or person from annoyance embarrassment oppression or undue burden or expense As explained in Rasmussen South Florida Blood Service Inc So.2d Fla under this rule trial judges possess broad discretion to restrict discovery But that discretion rests in the trial court id which obviously is familiar with the litigation pending before it The bankruptcy court cannot exercise discretion to restrict this Courts subpoenas Finally the bankruptcy court simply lacks jurisdiction to rule regarding privilege issues that have arisen in this Courts case It is well settled that the bankruptcy courts jurisdiction is limited to cases under title core bankruptcy proceedings that either arise under the Bankruptcy Code or arise in a case under the Code or cases in which all interested parties consent to the bankruptcy court having jurisdiction to enter a final order in a matter that is related to a case under the Bankruptcy Code In re Ray F.3d WL th Cir internal quotations omitted Ruling on privilege claims from a subpoena issued by this Court in a tort suit filed by Epstein who is not a party to the bankruptcy proceeding against Edwards who is likewise not a party to the bankruptcy proceeding does not fall within any of these grants of jurisdiction to the bankruptcy court and therefore Epsteins proposed procedure is without jurisdictional foundation THIS COURT SHOULD ENTER A PROTECTIVE ORDER AND ESTABLISH A SCHEDULE FOR RESOLVING THE PENDING SUMMARY JUDGMENT MOTION AND THEN ANY SURVIVING PRIVILEGE ISSUES While Edwards could file a jurisdictional objection to the bankruptcy court ruling on this issue he does not want to spawn further litigation that could delay a resolution of the privilege issues Instead Edwards proposes that this Court simply assert jurisdiction over its subpoena and the litigation that has arisen from it The subpoena to Edwards and to the trustee that Epstein has propounded were issued on the authority of this Court Accordingly it is indisputable that this Court can simply withdraw or stay enforcement of its subpoena thereby simply consolidating the litigation surrounding its subpoena into this Court This Court could then make binding rulings on both the merits or lack thereof of Epsteins lawsuit and any surviving privilege issues concerning the subpoenas Edwards therefore respectfully proposes that the Court take the following actions I Hold its scheduled hearing on Edwards summary motion on January The Court shall then rule on whether any of Epsteins claims survive Edwards summary judgment motion After making those rulings the Court should then rule on whether Epsteins subpoenas should be quashed in light of its rulings If the Court concludes that parts of the subpoenas remain viable then the Court could rule on any remaining claims of privilege or other objections that have not been mooted by its summary judgment rulings Stay further enforcement of its subpoenas to the trustee and to Edwards pending further rulings by this Court on the merits of Epsteins underlying lawsuit and any privilege or other issues that Edwards might raise to the subpoenas Direct Edwards to prepare a privilege log regarding documents that are actually responsive to the subpoenas Such privilege log shall be prepared within days following this Courts ruling on Edwards pending summary judgment motion assuming any claim by Epstein survives At that time Edwards shall also produce to Epstein any documents that are responsive to the subpoenas to Edwards and to the trustee and for which there is no privilege or other objection to production i.e vagueness in the subpoena or not reasonably calculated to lead to discovery of admissible evidence Epstein shall then file any objections to claim of privilege or other objections within days following Edwards response Edwards shall file any response to Epstein within days following receipt of the objections In addition it is clear that there is an imbalance of financial resources between billionaire Jeffrey Epstein and the parties on whom he is serving subpoenas This Court possesses the authority to direct the requesting party to pay the costs and expenses of providing discovery PHILIP PADOVANO FLORJDA CIVIL PRACTICE at edition citing CBS Inc Jackson So.2d Fla Mt Sinai Med Ctr Inc Perez-Torbay So.2d Fla 3d DCA Given the vast sums available to Epstein to pursue his meritless litigation he should be directed to pay to Farmer Jaffe and Stettin all costs associated with responding to his discovery requests including reasonable costs of attorneys time and any copying or other expenses Because proceedings are on-gomg the bankruptcy court regarding these issues Edwards is simultaneously giving notice to the bankruptcy court the trustee and the Special Master that this pleading is being filed and providing a copy of this pleading to each of them CONCLUSION This Court should stay further enforcement of its subpoena to Edwards and to the trustee Stettin pending further ruling on the pending summary judgment motion regarding Epsteins lawsuit This Court should also enter a protective order narrowing the scope of Epsteins requests and requiring Epstein to pay all reasonable expenses associated with responding to his requests This Court should then grant Edwards pending summary judgment motion against Epstein and then rule on any surviving privilege or other issues concerning Epsteins subpoenas I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Fax and U.S Mail to all Counsel on the attached list day ofNove er ea Denney Scarola Barnhart Shipley Palm Beach Lakes Boulevard est Palm Beach Florida Phone Fax Attorney for Bradley Edwards COUNSEL LIST Jack A Goldberger Esquire Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Phone Fax Farmer Jaffe Weissing Edwards Fistos Lehrman PL Andrews Avenue Suite Fort Lauderdale FL Phone Fax Marc Nurik Esquire Law Offices of Marc Nurik One Broward Blvd Suite Fort Lauderdale FL Phone Fax Joseph Ackerman Jr Esquire Fowler White Burnett P.A Phillips Point West Flagler Drive West Palm Beach FL Phone Fax The Honorable Herbert Stettin Trustee One Biscayne Tower Suite Two South Biscayne Boulevard Miami Florida Robert Carney Special Master Saratoga Lane West Palm Beach FL 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 Epstein pursuant to Fla Civ requests that Defendant BRADLEY EDWARDS Edwards produce or make available for inspection documents responsive to the requests below within thirty days from the date of service 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 EXHIBIT A 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 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 investigative bills photocopies faxes Westlaw computerized research travel expenses and witness fees and expert witness fees and costs Trustee 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 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 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 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 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 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 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 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 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 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 billionaire or a similar reference was mentioned a Scott Rothstein Russell Adler William Berger Michael Fisten Kenneth Jenne David Boden Deborah Villegas Andrew Barnett 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 sent by fax and U.S Mail 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 P.A Australian Avenue South Andrews Avenue Suite Fort Lauderdale FL fax Attorneys for Defendant L.M Jack Scarola Esq Suite West Palm Beach FL Fax 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 Suite 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 Suite West Pal By Ro ritton Jr Florida Bar Michael Pike 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 his 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 attorney-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 EXHIBITB Case No Edwards Response to 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 attorney-client 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 kAJl HAY t1 furnished via U.S Mail to all counsel on the attached list on Jack Scarola Searcy Denney Scarola Barnhart Shipley P.A Attorneys for Defendant Bradley Edwards Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Case No Edwards Response to Request for Production dated 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 Gary Farmer Jr Farmer Jaffe Weissing Edwards Fistos Lehrman P.L Andrews Avenue Suite Fort Lauderdale FL Phone Fax Attorneys for Marc Nurik Law Offices of Marc Nurik One East Broward Boulevard Suite Fort Lauderdale FL Phone Fax Counsel for Scott Rothstein INRE Case Doc Filed Page of UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA Fort Lauderdale Division w.flsb.uscow1s.gov ROTHSTEIN ROSENFELDT ADLER P.A Case No Chapter Debtor JEFFREY EPSTEINS MOTION TO COMPEL PRODUCTION OF DOCUMENTS FROM TRUSTEE PURSUANT TO DOCUMENT PRODUCTION PROTOCOL ESTABLISHED BY DE JEFFREY EPSTEIN EPSTEIN by and through undersigned counsel respectfully moves this Honorable Court pursuant to the provisions of Fed.R.Civ.37 a which is incorporated into bankruptcy practice by Fed.R.Bankr.P for an Order compelling HERBERT DocrS07 Page2of8 Case No so requested approval of a proposed Document Production Protocol to be used across the board with respect to future d9cument requests that he anticipated receiving from third parties both within and outside this bankruptcy case DE On May this Court entered an Order Granting Trustees Motion Seeking a Protective Order and Approving Proposed Document Production Protocol DE This Order established the process for anyone wishing discovery from the Trustee Its operation is not limited to discovery in the bankruptcy case Moreover that Order at paragraph retained jurisdiction with respect to all matters arising from or related to the implementation or interpretation of said Order i.e all discovery sought from the Trustee without any limitation on the forum EPSTEIN is currently a party Plaintiff to a lawsuit in the Circuit Court of the Fifteenth Judicial Circuit in and for Palm Beach County Florida Case No CA MB AG The action is entitled Jeffrey Epstein Plaintiff vs Scott Rothstein individually Bradley Edwards individually and L.M individually On or about April counsel for EPSTEIN in the state court had served a Subpoena Duces Tecum for Deposition Documents Only on Case Doc Filed Page of Case No TORRES indicated that he anticipated finalizing review of the emails for attorney/client privilege information by May and intended to produce the documents along with the Privilege Log by May Exhibit A attached TORRES letter He verbally indicated that he had further responsive documents other than emails It did not happen In the meantime on May the Trustee had filed his Motion in this Court seeking to establish the Document Production Protocol and this Court entered its Order DE supra On the strength of the Document Production Protocol Trustees counsel now demanded that Movant enter into a Joint Motion for Entry of Stipulated Protective Order and a Protective Order the forms established by the Order setting the Document Production Protocol Movants counsel forwarded to TORRES the paralegal and CHARLES LICHTMAN ESQ the executed Joint Ex Parte Motion and the proposed Stipulated Protective Order Counsel for the Trustee did not file them nor have they ever produced the required information notwithstanding that TORRES had written that the materials would be ready before the end of May Production of these documents from the Trustee is critical to issues in the state court lawsuit Without access to the emails in question Movant will suffer unfair prejudice and will be unable to obtain information critical to his lawsuit To date the Trustee apparently claims privilege over all of these documents but no Privilege Log has ever been provided In addition there is the potential that the crime-fraud exemption to the attorney/client privilege would ultimately apply rendering any claimed privilege even one that is improperly claimed to be moot FOWLER WHITE Case Doc Filed Page of Case No Movant is willing to reimburse the Estate for its reasonable expenses incurred in reviewing the documents for privileged matters and preparing a Privilege Log Counsel for Movant certifies that we have communicated with Trustee and his counsel in an effort to resolve this issue prior to filing this Motion WHEREFORE Movant respectfully prays that this Court a enter the standard stipulated Protective Order so that Movant will be in compliance with the Document Production Protocol and order the Trustee to comply with the Subpoena originally served on April almost three months ago ald Neiwirth Fla Bar No FOWLER WHITE Case Doc Filed Page of Case No CERTIFICATE OF SERVICE I HEREBY CERTIFY that on July I electronically filed the foregoing document with the Clerk of the Court using CM/ECF I also certify that the foregoing document is being served this day on all counsel of record or pro se parties identified on the attached Service List in the manner specified either via transmission of Notices of Electronic Filing generated by CM/ECF or in some other authorized manner for those counsel or parties who are not authorized to receive electronically Notices of Electronic Filing Ronald iw""i rth Ronald Neiwirth FOWLER WHITE Case Doc Filed Pag of BERGER SINGERMAN attorn.,ys at law GIVING 8ACK MOVING FORWARD Boca Raton Fort La11derdale Miami Tallahauu Luis Tortes Llorrcs bergcmngennan.com May VIA FACSIMll,E AND E-MAIL Robert Critton Jr Esq David A arema Esq BURMAN CRTITON LUTIIBR COLEMAN Flagler Driv Suite West Palm Beach FL Re Subpoena Directed to Herbert Stettin in the case styled L.M Jeffrey Epstein Case No AD Dear Mr Critton and Mr Yarema Pursuant to the subpoena directed to Herbert Stettin Trustee dated April Subpoena and the various communications we have had regarding the search parameters to be utilized in order to comply with the Subpoena please be advised that the Trustee has retrieved approximately e-mails that might be responsive to the Subpoena We want to make clear that the Trustee does not have the capability to run electronic search.es over all of RRAs documents Therefore the e-mails which have been identified are from Scott Rothsteins and Bradley Edwards e-mail accounts We anticipate finalizing the review of e-mails for attorney-client privilegt information by Friday May and we intend to produce responsive documents along with a privilege log by Monday May Should you have any questions or concerns please feel free to contact me at Sincerely cc James Cunningham Jr Esq itNDtu:W lJ EXH1srr IJ2_ East Las Olas Boulevard Suite Fort Lauderdale Florida Telephone facslmlle I I I i Case Doc Filed Page of Case No SERVICE LIST Charles Lichtman Esq Berger Singerman P.A East Las Olas Blvd Ft Lauderdale FL Via CM/ECF and email Marianella Morales Esq A venida Francisco de Miranda Torre Provincial A Piso Caracas Venezuela Via CM/ECF John Genovese Esq Bank of America Tower at International Place S.E Street Miarm FL Via CM/ECF Office of the U.S Trustee S.W First Avenue Miami FL Via CM/ECF Thomas Tew Esq Tew-Cardenas LLP Four Seasons Tower FL Brickell Avenue Miami FL Via CM/ECF Conrad Scherer LLP South Federal Highway Ft Lauderdale FL Via CM/ECF Michael Seese Esq Hinshaw Culbertson LLP Broward Blvd Ft Lauderdale FL Via CM/ECF William George Salim Jr Moskowitz Mandell Salim Corporate Dr Ft Lauderdale FL Via CM/ECF Special Assistant U.S Attorney P.O Box Stop S.W st Avenue ll14 Miami FL Via U.S Mail Kendall Coffey Esq Office in the Grove Penthouse South Bayshore Drive Miami FL Via CM/ECF The Honorable Herbert Stettin One Biscayne Tower Two South Biscayne Blvd Miami FL Via U.S Mail and email John Bianco Esq Tripp Scott I S.E Sixth Street th FL Ft Lauderdale FL Via CM/ECF Alison Lehr Esq Assistant U.S Attorney N.E th Street FL Miami FL Via CM/ECF Jeffrey Sonn Esq Sonn Erez PLC Broward Financial Center Broward Blvd Ft Lauderdale FL Via CM/ECF Honorable Jeffrey Sloman Acting U.S Attorney N.E th Street Miami FL Via U.S Mail Internal Revenue Service Centralized Insolvency Operations POB Philadelphia PA Via U.S Mail Daniel Mink Ovadia Levy c/o Renato Watches Inc N.W Street Sunrise FL Via U.S Mail FOWLER WHITE Case Doc Filed Page of USI Attn Anthony Gruppo West Cypress Creek Road Ft Lauderdale FL Anthony.gruppo usi.biz Via email United Healthcare Department CH Palatine IL Via U.S Mail Special Assistant U.S Attorney IRS District Counsel Pine Island Road Plantation FL Via U.S Mail Leon County Tax Collector Calhoun Street Tallahassee FL Via U.S Mail Miami-Dade County Tax Collector Flagler Street th Floor Miami FL Via U.S Mail Palm Beach County Tax Collector P.O Box West Palm Beach FL Via U.S Mail Carpenter Berger PL Andrew Avenue Ft Lauderdale FL Via U.S Mail Mark Haltzman Esq Lamm Rubenstone LLC Horizon Blvd Trevose PA mhaltzman larnmrubenstone.com Via email and John Scarola Esq Palm Beach Lakes Blvd West Palm Beach FL U.S Mail mep searchlaw.com Via email and U.S Mail Case No The Honorable Eric Holder Jr Attorney General of the U.S Pennsylvania Avenue NW Room Washington DC Via U.S Mail Marc Nurik Esq East Broward Blvd Ft Lauderdale FL marc nuriklaw.com Via email Bast Amron LLP SunTrust International Center One S.E Third Avenue Miami FL Via CM/ECF Frank McGinn Esq Barlett Hackett Feinberg P.C Federal Street th FL Boston MA Via CM/ECF Daro H.M Carr Esq Nesbit Street Punta Gorda FL Via CM/ECF Jane A Bee Esq Blank Rome LLP North th Street Philadelphia PA bee blankrome.com Via email Roderick Coleman Esq Dixie Highway Boca Raton FL Robert Busche Esq S.E Third Avenue Ft Lauderdale FL Via CM/ECF buschel bglaw.pa.com Via email and U.S Mail FOWLER WHITE Case Doc Filed Page of IN RE UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION w.flsb.uscourts.gov ROTHSTEIN ROSENFELDT ADLER P.A CASE NO CHAPTER Debtor I MOTION FOR PROTECTIVE ORDER TO EXCLUDE THE PRODUCTION FROM TRUSTEE Case Doc Filed Page of privilege and/or attorney work product II Background Movant L.M is a party plaintiff in a civil lawsuit against party defendant Jeffrey Epstein in which she alleges that Epstein sexually exploited abused and/or assaulted her when she was a minors The parties recently reached a confidential settlement of this lawsuit on the eve of trial Movants counsel Brad Edwards was employed by RRA During this time Attorney Edwards securely and confidentially maintained hard-copies of certain file materials and maintained substantial parts of client case files and investigative files in the Qtask application and other software systems maintained by RRA This Court has entered other Orders in this case to preserve the privileges of RRAs former clients See Order Granting Motion for Protective Order D.E Epstein filed a lawsuit against Scott Rothstein L.M counsel Brad Edwards and L.M individually Epstein has sought to prove up his meritless claims against Attorney Edwards and L.M in part by invoking his Fifth Amendment privilege in deposition in this case seventy-seven times On Date Epsteins counsel had a subpoena duces tecum issued from the Circuit Court in L.M Epstein Case th Judicial Circuit in and for Palm Beach County Florida Attorney Brad Edwards is plaintiffs counsel in this lawsuit Epstein was also a party defendant in dozens of other civil lawsuits prosecuted by other woman who allege that Epstein sexually exploited abused and/or assaulted them when they were minors See Motion for Protective Order to Exclude Production of Privileged Documents and Testimony from Qtask Inc D.E Epstein Rothstein et al Case th Judicial Circuit in and for Palm Beach County Florida Dep Jeffrey Epstein Epstein Rothstein et al March Case Doc Filed Page of Epstein Rothstein et al seeking production from Trustee Herbert Stettin of Attorney Edwards case files and investigative files which relate to L.M and his other legitimate clients who possessed bona fide claims or potential claims against Epstein On Date L.M through counsel filed objections to the subpoena in the Circuit Court Likewise L.M filed a motion for protective order in the Circuit Court where the subject subpoena had been issued In addition the Trustee filed a motion for protective order in the Circuit Court Thereafter the Circuit Court entered an agreed order on these motions for protective order protecting privileged and work product materials from production to Epstein Now Epstein has come to the Bankruptcy Court to pursue the discovery of privileged and attorney work product materials which the Circuit Court would not allow See Epsteins Motion to Compel DE I Memorandum of Law A Discovery Issues Related to the State Court Issued Subpoena Are Not Properly Before the Bankruptcy Court Despite Epsteins stated position to the contrary neither U.S.C or confer jurisdiction on this honorable Court to adjudicate a discovery matter arising purely under state law claims filed in state court which are not before the Bankruptcy Court Epstein seeks to perform an end run around the Circuit Courts proper exercise of its jurisdiction to adjudicate matters pending before it including subpoenas issued from that court Moreover the honorable Circuit Court has already ruled on a motion for protective order on the subject state court issued subpoena duces tecum Accordingly for reasons of comity this honorable Court should deny Epsteins motion to compel Case Doc Filed Page of The Discovery Sought is Privileged and/or Attorney Work Product and Beyond the Permissible Scope of Discovery Privileges are invoked by the client who possesses the privilege or by the attorney on behalf of the client i Scope of Permissible Discovery Rule excludes privileged matters from the scope of permissible discovery Epstein seeks the production of documents from clients privileged case files and investigative files These documents are beyond the scope of discovery permitted by Rule ii Protective Orders Rule states that a court may protect a party or person from whom discovery is sought based on good cause shown A party or any person from whom discovery is sought may move for a protective order in the court where the action is pending or as an alternative on matters relating to a deposition in the court for the district where the deposition will be taken The motion must include a certification that the movant has in good faith conferred or attempted to confer with other affected parties in an effort to resolve the dispute without court action The court may for good cause issue an order to protect a party or person from annoyance embarrassment oppression or undue burden or expense including one or more of the following A forbidding the disclosure or discovery specifying terms including time and place for the disclosure or discovery prescribing a discovery method other than the one selected by the party seeking discovery forbidding inquiry into certain matters or limiting the scope of disclosure or discovery to certain matters designating the persons who may be present while the discovery is conducted requiring that a deposition be sealed and opened only on court order requiring that a trade secret or other confidential research development or commercial information not be revealed or be revealed only in a specified way and Case Doc Filed Page of requiring that the parties simultaneously file specified documents or information in sealed envelopes to be opened as the court directs Fed.R.Civ.P Epstein seeks the production from the Trustee of privileged confidential and attorney work product materials from the case files and investigative files of L.M and other clients who possess claims against Epstein The requested documents relating to the bona fide cases of clients are not relevant or calculated to lead to the discovery of admissible evidence in the instant bankruptcy action or any adversary proceeding presently before this Court Therefore the requested documents are beyond the scope of permissible discovery The requested materials are not discoverable under the Florida Rules of Civil Procedure the Federal Rules of Civil Procedure the Bankruptcy Rules of Civil Procedure or any other possibly applicable system of rules Moreover the document production methodology established by order of this Court was not intended to be a conduit of privileged and work product of RRAs former clients to the clients litigation adversaries Epsteins counsel distorts and misrepresents the purpose of the document production methodology by arguing that it was created to facilitate such improper discovery Epsteins counsel further attempts to skirt the issue of privilege by failing to meaningfully identify the nature of the requested materials other than describing emails and documents other than emails The materials requested by Epstein essentially case files client files and investigative files are patently and obviously privileged Epsteins counsel offers no argument cognizable under any set of possibly applicable rules to demonstrate entitlement to these privileged and work product materials WHEREFORE based on the foregoing Epstein is not permitted to obtain production of Case Doc Filed Page of documents and ESI from the Trustee which comprise the privileged confidential or attorney work product portions of case files or investigativ files and Movant requests that the Court deny Epsteins motion to compel grant the foregoing motion for protective order and enter a protective order excluding the production of any documents or ESI by the Trustee which relate to any cases or matter of L.M or other clients and granting any other relief the Court deems appropriate to protect the clients of Farmer Jaffe Weissing I HEREBY CERTIFY that pursuant to L.R Movants counsel has contacted Epsteins counsel in a good faith attempt to resolve the matter without a hearing and I further certify that a true and correct copy of the foregoing was served on electronically to the examinee the debtor the attorney for the debtor the trustee all CM/ECF subscribers and by email or U.S Mail on those parties listed on the attached service list this 19th day of July I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule A FARMER JAFFE WEISSING EDWARDS FISTOS LEHRMAN P.L North Andrews Avenue Suite Fort Lauderdale FL Telephone Facsimile By ls/Seth Lehrman Seth Lehrman FLBN seth pathtojustice.com Case Doc Filed Page of SERVICE LIST CASE NO Marianella Morales Esquire VIA EMAIL Authorized Agent For Joining Creditors Avenida Francisco de Miranda Torre Provincial A Pisa Caracas Venezuela John Genovese Esq VIA CM/ECF Robert Elgidely Esq Theresa M.B Van Vliet Esq Genovese Joblove Battista PA Bank Of America Tower at International Place S.E 2nd Street Suite Miami Florida Phone Fax Kendall Coffey Esq VIA EMAIL Coffey Burlington Office in the Grove Penthouse South Bayshore Drive Miami Florida kcoffey coffeyburlington.com Hon Herbert Stettin VIA EMAIL One Biscayne Tower Suite Two South Biscayne Boulevard Miami Florida John Bianco Esq VIA CM/ECF John Mulli Esquire Tripp Scott Southeast Sixth Street Fifteenth Floor Fort Lauderdale Fl gb trippscott.com Alison Lehr VIA EMAIL Assistant United States Attorney N.E 4th Street 7th Floor Miami Florida Phone Fax Alison.Lehr usdoj.gov Stuart A Rosenfeldt Esq VIA EMAIL Rothstein Rosenfeldt Adler PA East Las Olas Boulevard Suite Fort Lauderdale Florida srosenfeldt rra-law.com Jeffrey Sonn Esq VIA EMAIL Sonn Erez PLC Broward Financial Center Broward Boulevard Suite Fort Lauderdale Florida Phone Fax jsonn sonnerez.com Office of the US Trustee VIA CM/ECF Southwest First A venue Suite Miami Florida Thomas Tew Esq VIA EMAIL Lynn Maynard Gollin Esq Tew-Cardenas LLP Four Seasons Tower 15th Floor Brickell A venue Miami Florida tt tewlaw.com lmg tewlaw.com Case Doc Filed Page of Conrad Scherer LLP VIA EMAIL South Federal Highway Fort Lauderdale FL Tel bs conradscherer.com Si lver conradscherer.com Michael Seese Esq VIA EMAIL Hinshaw Culbertson LLP I Broward Blvd Ste IO Ft Lauderdale Florida Tel Fax mseese hinshawlaw.com Internal Revenue Service Centralized Insolvency Operations P.O Box Philadelphia PA Via U.S Mail Internal Revenue Service Special Procedures Insolvency SW 6th Court Plantation FL Tel Fax Via U.S Mail Special Asst U.S Attorney P.O Box Stop SW I st A venue Miami Fl Fax Via U.S Mail Grant Smith Esq VIA EMAIL Rothstein Rosenfeldt Adler P.A East Las Olas Blvd Suite Fort Lauderdale FL gsmith rra-law.com United Healthcare Dept CH Palatine IL Via US Mail Special Asst U.S Attorney IRS District Counsel I Pine Island Rd Ste Plantation FL Via U.S Mail The Honorable Eric Holder Jr Attorney General of the U.S Pennsylvania A venue NW Room Washington DC Via U.S Mail Honorable Jeffrey Sloman Acting U.S Attorney NE 4th Street Miami Fl Via U.S Mail Daniel Mink Ovadia Levy c/o Renato Watches Inc NW 14th Street Sunrise Florida Via U.S Mail William George Salim Jr VIA CM/ECF Moskowitz Mandell Salim Corporate Dr Ste Fort Lauderdale Florida wsalim mmsslaw.com Tel Fax USI VIA EMAIL Attn Anthony Gruppo West Cypress Creek Road Suite Fort Lauderdale FL Tel Anthony.gruppo usi.biz Case Doc Filed Page of Marc Nurik Esq VIA EMAIL Rothstein Rosenfeldt Adler P.A East Las Olas Blvd Suite Fort Lauderdale FL I mnurik rra-Iaw.com BAST AMRON LLP VIA CM/ECF SunTrust International Center One Southeast Third A venue Suite Miami Florida Telephone Facsimile bamron bastamron.com jbast bastamron.com Mark Bloom Esq VIA EMAIL Greenberg Traurig LLP Brickell A venue Miami FL bloomm gtlaw.com Robert Critton Esq VIA EMAIL Burman Critton Luttier Coleman Banyan Blvd Suite West Palm Beach FL rcrit bclclaw.com Roth Scholl VIA EMAIL Attn Jeffrey Roth Esq Attorneys For Creditor Blue Capital Us East Coast Properties L.P South Dixie Highway Coral Gables Fl Telephone jeff rothandscholl.com Rogers Morris Ziegler LLP VIA EMAIL East Broward Blvd Suite Fort Lauderdale FL Tel Fax mfbooth rmzlaw.com Arthur Neiwirth Esq VIA CM/ECF One Broward Blvd Suite Ft Lauderdale FL Tel Fax aneiwirth qpwblaw.com The Florida Bar VIA EMAIL Adria Quintela Esq Alan Anthony Pascal Esq Lake Shore Plaza II Concord Terrace Suite Sunrise FL aquintel flabar.org apascal flabar.org Micheal Moskowitz Esq VIA MAIL Corporate Drive Suite Ft Lauderdale FL mmoskowitz mmsslaw.com Francis Carter Esq VIA E-MAIL Katz Barron Squitero Faust Bayshore Drive 7th Floor Miami Florida Tel Fax fl katzbarron.com Bradley Shraiberg Esq VIA EMAIL NW Executive Drive Suite Boca Raton Florida Tel Fax bshraiberg sfl-pa.com Case Doc Filed Page of Henry Wulf Esq VIA EMAIL CARLTON FIELDS P.A Okeechobee Blvd Suite West Palm Beach Florida Telephone Facsimile E-Mail hwulf carltonfields.com EMESS Capital LLC VIA EMAIL c/o Bruce A Katzen Esq Biscayne Blvd 17th Floor Miami Florida Telephone Facsimile E-Mail bkatzen klugerkaplan.com Ronald Neiwirth Esq VIA EMAIL Joseph Ackerman Jr Esq Fowler White Burnett P.A Flagler Dr Ste Palm Beach FL Email jla fowler-white.com meiwirth fowler-white.com Ira Sochet Trustee VIA EMAIL Revocable Intervivos Trust of Ira Sochet c/o Phil Hudson Esq South Biscayne Blvd Suite Miami Florida Telephone Facsimile E-Mail pmhudson amstein.com Coquina Investments VIA EMAIL c/o Patricia A Redmond Esq West Flagler Street Suite Miami Florida Telephone Facsimile E-Mail predmond steamsweaver.com Case Doc Filed Page of IN RE UNITED ST A TES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION w.tlsb.uscourts.gov ROTHSTEIN ROSENFELDT ADLER P.A CASE NO CHAPTER Debtor I AMENDED MOTION FOR PROTECTIVE ORDER TO EXCLUDE THE PRODUCTION FROM TRUSTEE Case Doc Filed Page of privilege and/or attorney work product II Background Movant L.M is a party plaintiff in a civil lawsuit against party defendant Jeffrey Epstein in which she alleges that Epstein sexually exploited abused and/or assaulted her when she was a minors The parties recently reached a confidential settlement of this lawsuit on the eve of trial Movants counsel Brad Edwards was employed by RRA During this time Attorney Edwards securely and confidentially maintained hard-copies of certain file materials and maintained substantial parts of client case files and investigative files in the Qtask application and other software systems maintained by RRA This Court has entered other Orders in this case to preserve the privileges of RRAs former clients See Order Granting Motion for Protective Order D.E Epstein filed a lawsuit against Scott Rothstein L.M counsel Brad Edwards and L.M individually Epstein has sought to prove up his meritless claims against Attorney Edwards and L.M in part by invoking his Fifth Amendment privilege in deposition in this case seventy-seven times On April I I Epsteins counsel had a subpoena duces tecum issued from the Circuit L.M Epstein Case I th Judicial Circuit in and for Palm Beach County Florida Attorney Brad Edwards is plaintiffs counsel in this lawsuit Epstein was also a party defendant in dozens of other civil lawsuits prosecuted by other woman who allege that Epstein sexually exploited abused and/or assaulted them when they were minors See Motion for Protective Order to Exclude Production of Privileged Documents and Testimony from Qtask Inc D.E Epstein Rothstein et al Case th Judicial Circuit in and for Palm Beach County Florida Dep Jeffrey Epstein Epstein Rothstein et al March Case Doc Filed Page of Court in Epstein Rothstein et al seeking production from Trustee Herbert Stettin of Attorney Edwards case files and investigative files which relate to L.M and his other legitimate clients who possessed bona fide claims or potential claims against Epstein On June L.M through counsel filed objections to the subpoena in the Circuit Court Likewise L.M filed a motion for protective order in the Circuit Court where the subject subpoena had been issued In addition the Trustee filed a motion for protective order in the Circuit Court Thereafter the Circuit Court entered an agreed order on these motions for protective order protecting privileged and work product materials from production to Epstein Now Epstein has come to the Bankruptcy Court to pursue the discovery of privileged and attorney work product materials which the Circuit Court would not allow See Epsteins Motion to Compel DE Ill Memorandum of Law A Discovery Issues Related to the State Court Issued Subpoena Are Not Properly Before the Bankruptcy Court Despite Epsteins stated position to the contrary neither U.S.C or confer jurisdiction on this honorable Court to adjudicate a discovery matter arising purely under state law claims filed in state court which are not before the Bankruptcy Court Epstein seeks to perform an end run around the Circuit Courts proper exercise of its jurisdiction to adjudicate matters pending before it including subpoenas issued from that court Moreover the honorable Circuit Court has already ruled on a motion for protective order on the subject state court issued subpoena duces tecum Accordingly for reasons of comity this honorable Court should deny Case Doc Filed Page of Epsteins motion to compel The Discovery Sought is Privileged and/or Attorney Work Product and Beyond the Permissible Scope of Discovery Privileges are invoked by the client who possesses the privilege or by the attorney on behalf of the client i Scope of Permissible Discovery Rule excludes privileged matters from the scope of permissible discovery Epstein seeks the production of documents from clients privileged case files and investigative files These documents are beyond the scope of discovery permitted by Rule ii Protective Orders Rule states that a court may protect a party or person from whom discovery is sought based on good cause shown A party or any person from whom discovery is sought may move for a protective order in the court where the action is pending or as an alternative on matters relating to a deposition in the court for the district where the deposition will be taken The motion must include a certification that the movant has in good faith conferred or attempted to confer with other affected parties in an effort to resolve the dispute without court action The court may for good cause issue an order to protect a party or person from annoyance embarrassment oppression or undue burden or expense including one or more of the following A forbidding the disclosure or discovery specifying terms including time and place for the disclosure or discovery prescribing a discovery method other than the one selected by the party seeking discovery forbidding inquiry into certain matters or limiting the scope of disclosure or discovery to certain matters designating the persons who may be present while the discovery is conducted requiring that a deposition be sealed and opened only on court order Case Doc Filed Page of requiring that a trade secret or other confidential research development or commercial information not be revealed or be revealed only in a specified way and requiring that the parties simultaneously file specified documents or information in sealed envelopes to be opened as the court directs Fed.R.Civ.P Epstein seeks the production from the Trustee of privileged confidential and attorney work product materials from the case files and investigative files of L.M and other clients who possess claims against Epstein The requested documents relating to the bona fide cases of clients are not relevant or calculated to lead to the discovery of admissible evidence in the instant bankruptcy action or any adversary proceeding presently before this Court Therefore the requested documents are beyond the scope of permissible discovery The requested materials are not discoverable under the Florida Rules of Civil Procedure the Federal Rules of Civil Procedure the Bankruptcy Rules of Civil Procedure or any other possibly applicable system of rules Moreover the document production methodology established by order of this Court was not intended to be a conduit of privileged and work product of RRAs former clients to the clients litigation adversaries Epsteins counsel distorts and misrepresents the purpose of the document production methodology by arguing that it was created to facilitate such improper discovery Epsteins counsel further attempts to skirt the issue of privilege by failing to meaningfully identify the nature of the requested materials other than describing emails and documents other than emails The materials requested by Epstein essentially case files client files and investigative files are patently and obviously privileged Epsteins counsel offers no argument cognizable under any set of possibly applicable rules to demonstrate entitlement to these privileged and work product materials Case Doc Filed Page of WHEREFORE based on the foregoing Epstein is not permitted to obtain production of documents and ESI from the Trustee which comprise the privileged confidential or attorney work product portions of case files or investigative files and Movant requests that the Court deny Epsteins motion to compel grant the foregoing motion for protective order and enter a protective order excluding the production of any documents or ESI by the Trustee which relate to any cases or matter of L.M or other clients and granting any other relief the Court deems appropriate to protect the clients of Farmer Jaffe Weissing I HEREBY CERTIFY that pursuant to L.R Movants counsel has contacted Epsteins counsel in a good faith attempt to resolve the matter without a hearing and I further certify that a true and correct copy of the foregoing was served on electronically to the examinee the debtor the attorney for the debtor the trustee all CM/ECF subscribers and by email or U.S Mail on those parties listed on the attached service list this 19th day of July I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule A FARMER JAFFE WEISSING EDWARDS FISTOS LEHRMAN P.L North Andrews Avenue Suite Fort Lauderdale FL Telephone Facsimile By ls/Seth Lehrman Seth Lehrman FLBN seth pathtoiustice.com Case Doc Filed Page of SERVICE LIST CASE NO Marianella Morales Esquire VIA EMAIL Authorized Agent For Joining Creditors A venida Francisco de Miranda Torre Provincial A Piso Caracas Venezuela John Genovese Esq VIA CM/ECF Robert Elgidely Esq Theresa M.B Van Vliet Esq Genovese Joblove Battista PA Bank Of America Tower at International Place S.E 2nd Street Suite Miami Florida Phone Fax Kendall Coffey Esq VIA EMAIL Coffey Burlington Office in the Grove Penthouse South Bayshore Drive Miami Florida kcoffey coffeyburlington.com Hon Herbert Stettin VIA EMAIL One Biscayne Tower Suite Two South Biscayne Boulevard Miami Florida John Bianco Esq VIA CM/ECF John Mulli Esquire Tripp Scott Southeast Sixth Street Fifteenth Floor Fort Lauderdale Fl gb tri ppscott com Alison Lehr VIA EMAIL Assistant United States Attorney N.E 4th Street 7th Floor Miami Florida Phone Fax Alison Lehr usdoj.gov Stuart A Rosenfeldt Esq VIA EMAIL Rothstein Rosenfeldt Adler PA East Las Olas Boulevard Suite Fort Lauderdale Florida srosenfeldt rra-law.com Jeffrey Sonn Esq VIA EMAIL Sonn Erez PLC Broward Financial Center Broward Boulevard Suite Fort Lauderdale Florida Phone Fax jsonn sonnerez.com Office of the US Trustee VIA CM/ECF Southwest First A venue Suite Miami Florida Thomas Tew Esq VIA EMAIL Lynn Maynard Gollin Esq Tew-Cardenas LLP Four Seasons Tower 15th Floor Brickell A venue Miami Florida tt tewlaw.com lmg tewlaw.com Case Doc Filed Page of Conrad Scherer LLP VIA EMAIL South Federal Highway Fort Lauderdale FL Tel bs conradscherer.com JSilver conradscherer.com Michael Seese Esq VIA EMAIL Hinshaw Culbertson LLP I Broward Blvd Ste IO I Ft Lauderdale Florida I Tel Fax mseese hinshawlaw.com Internal Revenue Service Centralized Insolvency Operations P.O Box Philadelphia PA Via U.S Mail Internal Revenue Service Special Procedures Insolvency SW 6th Court Plantation FL Tel Fax Via U.S Mail Special Asst U.S Attorney P.O Box Stop SW 1st Avenue Miami Fl Fax Via U.S Mail Grant Smith Esq VIA EMAIL Rothstein Rosenfeldt Adler P.A I East Las Olas Blvd Suite Fort Lauderdale FL gsmith rra-law.com United Healthcare Dept CH IO Palatine IL Via US Mail Special Asst U.S Attorney IRS District Counsel Pine Island Rd Ste Plantation FL Via U.S Mail The Honorable Eric Holder Jr Attorney General of the U.S Pennsylvania A venue NW Room Washington DC Via U.S Mail Honorable Jeffrey Sloman Acting U.S Attorney NE 4th Street Miami Fl Via U.S Mail Daniel Mink Ovadia Levy c/o Renato Watches Inc NW 14th Street Sunrise Florida Via U.S Mail William George Salim Jr VIA CM/ECF Moskowitz Mandell Salim Corporate Dr Ste Fort Lauderdale Florida wsalim mmsslaw.com Tel Fax USI VIA EMAIL Attn Anthony Gruppo West Cypress Creek Road Suite Fort Lauderdale FL Tel Anthony gruppo usi.biz Case Doc Filed Page of Marc Nurik Esq VIA EMAIL Rothstein Rosenfeldt Adler P.A East Las Olas Blvd Suite Fort Lauderdale FL mnurik rra-law.com BAST AMRON LLP VIA CM/ECF SunTrust International Center One Southeast Third A venue Suite Miami Florida Telephone Facsimile bamron bastamron.com jbast bastamron.com Mark Bloom Esq VIA EMAIL Greenberg Traurig LLP Brickell Avenue Miami FL bloomm gtlaw.com Robert Critton Esq VIA EMAIL Burman Critton Luttier Coleman Banyan Blvd Suite West Palm Beach FL rcrit bclclaw.com Roth Scholl VIA EMAIL Attn Jeffrey Roth Esq Attorneys For Creditor Blue Capital Us East Coast Properties L.P South Dixie Highway Coral Gables Fl Telephone jeff rothandscholl.com Rogers Morris Ziegler LLP VIA EMAIL East Broward Blvd Suite Fort Lauderdale FL Tel Fax mfbooth rmzlaw.com Arthur Neiwirth Esq VIA CM/ECF One Broward Blvd Suite Ft Lauderdale FL Tel Fax aneiwirth qpwblaw.com The Florida-Bar VIA EMAIL Adria Quintela Esq Alan Anthony Pascal Esq Lake Shore Plaza II Concord Terrace Suite Sunrise FL aquintel flabar.org apascal flabar.org Micheal Moskowitz Esq VIA MAIL Corporate Drive Suite Ft Lauderdale FL mmoskowitz mmsslaw.com Francis Carter Esq VIA E-MAIL Katz Barron Squitero Faust Bayshore Drive 7th Floor Miami Florida Tel Fax flc katzbarron.com Bradley Shraiberg Esq VIA EMAIL NW Executive Drive Suite Boca Raton Florida Tel Fax bshrai berg sfl-pa.com Case Doc Filed Page of Henry Wulf Esq VIA EMAIL CARLTON FIELDS P.A Okeechobee Blvd Suite West Palm Beach Florida Telephone Facsimile E-Mail hwulf carltonfields.com EMESS Capital LLC VIA EMAIL c/o Bruce A Katzen Esq Biscayne Blvd 17th Floor Miami Florida Telephone Facsimile E-Mail bkatzen klugerkaplan.com Ronald Neiwirth Esq VIA EMAIL Joseph Ackerman Jr Esq Fowler White Burnett P.A Flagler Dr Ste Palm Beach FL Email la fowler-white.com meiwirth fowler-white.com Ira Sachet Trustee VIA EMAIL Revocable Intervivos Trust of Ira Sachet c/o Phil Hudson Esq South Biscayne Blvd Suite Miami Florida Telephone Facsimile E-Mail pmhudson amstein.com Coquina Investments VIA EMAIL c/o Patricia A Redmond Esq West Flagler Street Suite Miami Florida Telephone Facsimile E-Mail predmond steamsweaver.com INRE Case Doc Filed Page of ANKJ?0 i I i 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 I 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 INRE Case Doc Filed Page of UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION flsb.uscourts.gov ROTHSTEIN ROSENFELDT ADLER P.A CASE NO CHAPTER Debtor MOTION TO CLARIFY ORDER APPOINTING SPECIAL MASTER Robert Carney this Courts appointed Special Master by Order dated August D.E moves for clarification of the above referenced order in the following material respects I Does Paragraph of the Order envision that the Special Master alone prepare a privilege log Discussion While a first blush reading of the Order would seem to indicate that the Special Master solely would prepare the privilege log this likely would create appellate issues later in the civil action A strict reading would preclude Messieurs Farmer and Edwards not only from seeing the documents but from having any hand in asserting the privilege that is theirs to assert Such a strict interpretation would permit them only to argue the privileges asserted by the Master Because they could not see the documents the master alone would decide which documents and what privilege Your Special Master is not aware of any case law or rule that would support such an interpretation and felt it prudent to bring this to the courts attention The address and last four digits of the taxpayer identification number of the Debtor Rothstein Rosenfeldt Adler P.A is NW 16th Street Suite The content of this motion was written by the Special Master However the Trustees counsel was asked to format and file this motion for the Special Master who is not on this Courts Electronic Filing System Submission of this motion by Trustees counsel does mean that the Trustee takes a position on the issues raised herein EXHIBITG Case Doc Filed Page of Suggestion That the Order appointing Special Master be clarified to insure that Messieurs Farmer and Edwards have the opportunity to review the documents and themselves make the decision regarding whether to assert a privilege Since your Special Master would also have the documents any concerns of loss or tampering should be alleviated Does Paragraph of the order envision that the job of the Special Master end with the preparation of the Privilege Log Discussion Once the privilege log is prepared the next step would be line item review of each privilege and the context in which it asserted as well as the opposing reasons why it should not exist or why it should be abrogated A strict reading of the Order would terminate the function of the Special Master upon completion of the privilege log and would leave the Bankruptcy Court with the task of sorting out the arguments and conducting hearings relative to the privileges Since this is in the context of a state court civil action involving matters arguably outside the interest of the Bankruptcy Court it might be more efficient for the arguments to be made to the Special Master with the Special Master then including in his report recommendations to the Bankruptcy judge regarding disposition Suggestion That the Order appointing Special Master be clarified to encompass conducting a hearing regarding privileges asserted by Messieurs Farmer and Edwards The Report of the Special Master would include the arguments from both sides regarding any privileges asserted and the recommended disposition of these claims Your Special Master has met with attorneys Lichtman Sanchez Farmer and Edwards separately and together Not all attorneys are in agreement with either the Request for Clarification or the suggestions of the Special Master outlined above which is the reason for requesting this hearing Case Doc Filed Page of I HEREBY CERTIFY that I am admitted to the Bar of the United States District Court for the Southern District of Florida and that I am in compliance with the additional qualifications to practice in this court set forth in Local Rule A CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was served via Regular U.S Mail postage prepaid fax email and/or overnight delivery as indicated upon all parties on the attached Service List this 20th day of September Dated September Respectfully submitted BERGER SINGERMAN P.A Attorneys for the Chapter Trustee East Las Olas Boulevard Suite Fort Lauderdale FL Telephone Main Facsimile By Isl Charles Lichtman Charles Lichtman clichtman bergersingerman.com Florida Bar No Case Doc Filed Page of MASTER SERVICE LIST CASE NO Marianella Morales Esquire Authorized Agent For Joining Creditors A venida Francisco de Miranda Torre Provincial A Piso Caracas Venezuela VIA CM/ECF and EMAIL John Genovese Esq Robert Elgidely Esq Theresa M.B Van Vliet Esq Genovese Joblove Battista PA Bank Of America Tower at International Place S.E 2nd Street Suite Miami Florida VIA CM/ECF and EMAIL Kendall Coffey Esq Coffey Burlington Office in the Grove Penthouse South Bayshore Drive Miami Florida kcoffey coffeyburlington.com VIA CM/ECF and EMAIL The Honorable Herbert Stettin One Biscayne Tower Suite Two South Biscayne Boulevard Miami Florida VIA U.S MAIL and EMAIL John Bianco Esq John Mulli Esquire Tripp Scott Southeast Sixth Street Fifteenth Floor Fort Lauderdale Fl gb trippscott.com VIA CM/ECF and EMAIL Alison Lehr Esq Grisel Alonso Esq Assistant United States Attorney N.E 4th Street 7th Floor Miami Florida Alison.Lehr usdoj.gov Grisel.alonso usdoj.gov VIA CM/ECF and EMAIL Jeffrey Sonn Esq Sonn Erez PLC Broward Financial Center Broward Boulevard Suite Fort Lauderdale Florida sonn sonnerez.com VIA CM/ECF and EMAIL Office of the US Trustee Southwest First A venue Suite Miami Florida VIA CM/ECF and EMAIL Thomas Tew Esq Tew-Cardenas LLP Four Seasons Tower 15th Floor Brickell Avenue Miami Florida tt tewlaw.com VIA CM/ECF and EMAIL Conrad Scherer LLP South Federal Highway Fort Lauderdale FL bs conradscherer.com Si ver conradscherer.com VIA CM/ECF and EMAIL Case Doc Filed Page of MASTER SERVICE LIST CASE NO Michael Seese Esq Hinshaw Culbertson LLP Broward Blvd Ste Ft Lauderdale Florida mseese hinshawlaw.com VIA CM/ECF and EMAIL Intemal Revenue Service Centralized Insolvency Operations P.O Box Philadelphia PA Via U.S Mail Intemal Revenue Service Special Procedures Insolvency SW 6th Court Plantation FL Via U.S Mail Special Asst U.S Attorney P.O Box Stop SW 1st Avenue Miami FI Via U.S Mail United Healthcare Dept CH Palatine IL Via US Mail Special Asst U.S Attorney IRS District Counsel Pine Island Rd Ste Plantation FL Via U.S Mail The Honorable Eric Holder Jr Attorney General of the U.S Pennsylvania A venue NW Room Washington DC Via U.S Mail Honorable Jeffrey Sloman Acting U.S Attorney NE 4th Street Miami FI Via U.S Mail Daniel Mink Ovadia Levy c/o Renato Watches Inc NW 14th Street Sunrise Florida Via U.S Mail William George Salim Jr Moskowitz Mandell Salim Corporate Dr Ste Fort Lauderdale Florida wsalim mmsslaw.com VIA CM/ECF and EMAIL USI Attn Anthony Gruppo West Cypress Creek Road Suite Fort Lauderdale FL Anthony.gruppo usi.biz VIA EMAIL Marc Nurik Esq I East Broward Blvd Suite Fort Lauderdale FL marc nuriklaw.com VIA EMAIL BAST AMRON LLP SunTrust International Center One Southeast Third A venue Suite Miami Florida bamron bastamron.com bast bastamron.com VIA CM/ECF and EMAIL Case Doc Filed Page of MASTER SERVICE LIST CASE NO Mark Bloom Esq John Hutton Esq Greenberg Traurig LLP Brickell Avenue Miami FL bloomm gtlaw.com huttonj gtlaw.com VIA CM/ECF and EMAIL Robert Critton Esq Burman Critton Luttier Coleman Banyan Blvd Suite West Palm Beach FL rcrit bclclaw.com VIA CM/ECF and EMAIL Roth Scholl Attn Jeffrey Roth Esq Attorneys For Creditor Blue Capital Us East Coast Properties LP South Dixie Highway Coral Gables Fl jeff rothandscholl.com VIA CM/ECF and EMAIL Rogers Morris Ziegler LLP East Broward Blvd Suite Fort Lauderdale FL mtbooth rmzlaw.com VIA CM/ECF and EMAIL Arthur Neiwirth Esq One Broward Blvd Suite Ft Lauderdale FL aneiwi1th gpwblaw.com VIA CM/ECF and EMAIL The Florida Bar Adria Quintela Esq Alan Anthony Pascal Esq Lake Shore Plaza II Concord Terrace Suite Sunrise FL aguintel flabar.org apascal flabar.org VIA CM/ECF and EMAIL Micheal Moskowitz Esq Corporate Drive Suite Ft Lauderdale FL mmoskowitz mmsslaw.com VIA CM/ECF and EMAIL Francis Carter Esq Katz Barron Squitero Faust Bayshore Drive 7th Floor Miami Florida flc katzbarron.com VIA CM/ECF and EMAIL Bradley Shraiberg Esq NW Executive Drive Suite Boca Raton Florida bshraiberg sfl-pa.com VIA CM/ECF and EMAIL Henry Wulf Esq CARLTON FIELDS P.A Okeechobee Blvd Suite West Palm Beach Florida E-Mail hwulf carltonfields.com VIA CM/ECF and EMAIL EMESS Capital LLC c/o Bruce A Katzen Esq Biscayne Blvd th Floor Miami Florida E-Mail bkatzen klugerkaplan.com jberman klugerkaplan.com VIA CM/ECF and EMAIL Case Doc Filed Page of MASTER SERVICE LIST CASE NO Ira Sochet Trustee Revocable Intervivos Trust of Ira Sochet c/o Phil Hudson Esq South Biscayne Blvd Suite Miami Florida E-Mail pmhudson arnstein.com VIA CM/ECF and EMAIL Coquina Investments c/o Patricia A Redmond Esq West Flagler Street Suite Miami Florida E-Mail predmond stearnsweaver.com VIA CM/ECF and EMAIL Michael I Goldberg Esq Las Olas Centre Suite East Las Olas Blvd Fort Lauderdale FL E-Mail Michael.goldberg akerman.com Eyal berger akerman.com VIA CM/ECF and EMAIL LMB Funding Group c/o Robert Furr Esq Glades Road Suite Boca Raton Florida E-Mail rfurr furrcohen.com VIA CM/ECF and EMAIL Lawrence A Gordich Esq Melissa Alagna Esq SEGALL/GORDICH P.A Brickell Avenue Suite Miami Florida Email lag segallgordich.com Email mma segallgordich.com VIA CM/ECF and EMAIL Broward County Attn Hollie Hawn Esq Government Center South Andrews Avenue Fort Lauderdale FL E-Mail hhawn broward.org VIA CM/ECF and EMAIL Steven Solomon Esq Gray Robinson P.A Brickell Ave Suite Miami Florida E-Mail steven.solomon gray robinson.com VIA CM/ECF and EMAIL Peter Valori Esq DAMIAN ALO RI LLP Brickell Avenue Suite Miami FL E-mail pvalori dvllp.com VIA CM/ECF and EMAIL Canon Financial Services Inc Gaither Drive Mount Laurel NJ Via US Mail CIT Technology Financing Services I LLC Centurion Parkway North Jacksonville FL Via US Mail Gibraltar Private Bank Trust Company Alhambra Circle Suite Coral Gables FL Via US Mail Inter-Tel Leasing Inc West Loop North Houston TX Via US Mail Florida Department of Revenue Calhoun Street Room Carlton Building Tallahassee FL Via US Mail Case Doc Filed Page of MASTER SERVICE LIST CASE NO Leon County Tax Collector Calhoun Street Suite Tallahassee FL Via US Mail Miami-Dade County Tax Collectors West Flagler Street 14th Floor Miami FL Via US Mail Palm Beach County Tax Collector P.O Box West Palm Beach FL Via US Mail THE LAW OFFICES OF GEOFFREY ITTLEMAN P.A North Andrews Avenue Fort Lauderdale Florida Via US Mail Carpenter Berger PL Andrew Ave suite Fort Lauderdale FL Via US Mail Frank McGinn Esq Bartlett Hackett Feinberg P.C Federal Street th Floor Boston MA ffm bostonbusinesslaw.com VIA CM/ECF and EMAIL Darol Carr Esq Nesbit Street Punta Gorda FL dcarr farr.com VIA CM/ECF and EMAIL Jane A Bee Esq Blank Rome LLP North th Street Philadelphia PA bee blankrome.com VIA EMAIL Roderick Coleman Esq South Dixie Highway Suite Boca Raton FL rfc colemanattorneys.com VIA CM/ECF and EMAIL Mark Haltzman Esq Lamm Rubenstone LLC Horizon Blvd Suite Trevose PA mhaltzman Iammrubenstone.com VIA CM/ECF and EMAIL Robert Busche Esq S.E Third Ave Suite Fort Lauderdale FL buschel bglaw-pa.com VIA CM/ECF and EMAIL Berkowitz Dick Pollack Brant Certified Public Accountants Consultants LLP Biscayne Boulevard Sixth Floor Miami FL Attn Richard Pollack Via Email and U.S Mail MELAND RUSSIN BUDWICK P.A Wachovia Financial Center South Biscayne Boulevard Miami Florida Attn James Moon Esq moon melandrussin.com Attn Peter Russin Esq prussin melandrussin.com Attn Michael Budwick Esq mbudwick melandrussin.com VIA CM/ECF and EMAIL Gary Blake Esq Palmetto Park Rd Suite Boca Raton FL gblake lglaw.net VIA CM/ECF and EMAIL Case Doc Filed Page of MASTER SERVICE LIST CASE NO Melinda Thornton Esq Assistant County Attorney County Attorneys Office Stephen Clark Center N.W First Street Miami Fl Email cao.bkc miamidade.gov VIA CM/ECF and EMAIL SLATKIN REYNOLDS P.A Attorneys for Russell Adler and Katie Adler One East Broward Boulevard Suite Fort Lauderdale Florida Telephone Facsimile jslatkin slatkinreynolds.com VIA CM/ECF and EMAIL ASSOULINE BERLOWE P.A East Sheridan Street Ste Dania Beach FL Attn Eric Assouline Esq ena assoulineberlowe.com VIA CM/ECF and EMAIL Steven Reisman Esq CURTIS Case Doc Filed Page of MASTER SERVICE LIST Heather Ries Esq Fox Rothschild LLP Lakeview Ave Suite West Palm Beach Fl hries foxrothschild.com VIA CM/ECF and EMAIL CASE NO Case Doc Filed Page of INRE UNITED ST A TES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION w.flsb.uscourts.gov ROTHSTEIN ROSENFELDT ADLER P.A CASE NO CHAPTER Debtor I MOTION FOR PROTECTIVE ORDER TO EXCLUDE THE PRODUCTION FROM TRUSTEE Case Doc Filed Page of such production consists entirely of documents and ESI which are subject to proper claims of attorney-client communications privilege and/or attorney work product IL Background EDWARDS was legal counsel for several young females that were molested by EPSTEIN and is currently legal counsel for additional females who were molested by EPSTEIN EDWARDS filed lawsuits against EPSTEIN on behalf of three females LM EW and Jane Doe who were molested by EPSTEIN numerous times when they were as young as and years old Each of those lawsuits was originally filed in August or September of while EDWARDS was a sole practitioner In or about March or April of EDWARDS was hired to work at RRA and as such he took his cases which included cases against EPSTEIN to RRA with him In November RRA collapsed when it was discovered that the firms president Scott Rothstein was running a Ponzi scheme and otherwise engaging in criminal activity EDWARDS and the vast majority of RRA attorneys and employees were unaware of Rothstein criminal activity EPSTEIN in an effort to exploit Rothsteins criminal activity filed a lawsuit against EDWARDS ROTHSTEIN and LM alleging that there was a conspiracy to fabricate cases against him including the case filed on behalf of LM Notwithstanding the foregoing EPSTEIN has settled all suits filed by EDWARDS to date paying significant sums to resolve said cases Prior to settling these cases EPSTEIN was deposed in the underlying litigation filed by the child victims and in this case and in all depositions he has asserted his 5th Amendment privilege against self-incrimination Despite all the foregoing EPSTEIN has filed his frivolous claims against EDWARDS and his client Case Doc Filed Page of EPSTEIN served a deposition duces tecum on Herbert Stettin trustee for RRA requesting documents and information that are clearly protected by attorney-client and work product privilege and/or which are the private property of EDWARDS or his clients or request information that is not reasonably calculated to lead to the discovery of admissible evidence Epstein is attempting to use his lawsuit against EDWARDS as a vehicle to pierce the attorney-client and work product privileges and gain access to privileged information related to civil actions against him Epstein served Requests for Production on EDWARDS that discovery requested 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 and responses were provided where there was no objection The Trustee for RRA is merely the custodian of these records and stands in the shoes of the former RRA attorneys and clients on issues such as this in other words the Trustee EDWARDS LM and all other current and former clients are essentially one and the same for purposes of attorney-client and work product issues Therefore EPSTEIN cannot request discovery from the RRA Trustee to circumvent any privilege already claimed by EDWARDS or his clients or to obtain information to which he is not entitled under the Rules EPSTEIN set a hearing on his Motion to Compel production of these materials before Judge Crow the Court in which this case is pending Prior to Judge Crow hearing that Motion an agreement was reached amongst the parties including Trustee that the materials responsive to the requests would be turned over by the Trustee to EDWARDS and that EDWARDS would then file a privilege log or make other appropriate objections Case Doc Filed Page of EPSTEINs counsel said he would prepare the Agreed Order to that effect but failed to do so EPSTEIN has now argued his entitlement to these documents before this Bankruptcy Court EDWARDS counsel understands that a Special Master Judge Robert Carney has been appointed and delegated certain duties to monitor Electronically Stored Information to assist in the preparation of a privilege log The discovery Epstein is seeking should not be allowed as it is not discoverable because it is irrelevant and/or clearly protected by privilege The discovery requested also contains information that is the private property of EDWARDS or his clients An objection and Amended Motion for Protective Order D.E was lodged on behalf of LM invoking certain privileges and the objections on behalf of EDWARDS and his current clients should also be recognized by this Court EDWARDS adopts and incorporates by reference herein the Amended Motion for Protective Order filed by LM but also asserts his own attorney-client and work product privileges as he is a named Defendant in EPSTEINs frivolous lawsuit While objections on behalf of EDWARDS have already been made before Judge Crow who is presiding over this case this Court should be aware of EPSTEINs attempt to backdoor his way into obtaining information to which he is not entitled I Memorandum of Law A Discovery Issues Related to the State Court Issued Subpoena Are Not Properly Before the Bankruptcy Court Case Doc Filed Page of Despite Epsteins stated position to the contrary neither U.S.C or confer jurisdiction on this honorable Court to adjudicate a discovery matter arising purely under state law claims filed in state court which are not before the Bankruptcy Court Epstein seeks to perform an end run around the Circuit Courts proper exercise of its jurisdiction to adjudicate matters pending before it including subpoenas issued from that court Moreover the honorable Circuit Court has already ruled on a motion for protective order on the subject state court issued subpoena duces tecum Accordingly for reasons of comity this honorable Court should deny Epsteins motion to compel The Discovery Sought is Privileged and/or Attorney Work Product and Beyond the Permissible Scope of Discovery Privileges are invoked by the client who possesses the privilege or by the attorney on behalf of the client i Scope of Permissible Discovery Rule excludes privileged matters from the scope of permissible discovery Epstein seeks the production of documents from clients privileged case files and investigative files These documents are beyond the scope of discovery permitted by Rule ii Protective Orders Rule states that a court may protect a party or person from whom discovery is sought based on good cause shown A party or any person from whom discovery is sought may move for a protective order in the court where the action is pending or as an alternative on matters relating to a deposition in the court for the district where the deposition will be taken The motion must include a certification that the movant has in good faith conferred or attempted to confer with other affected parties in an effort to resolve the dispute without court action The court may for good cause issue an order to protect a party or person from annoyance Case Doc Filed Page of embarrassment oppression or undue burden or expense including one or more of the following A forbidding the disclosure or discovery specifying terms including time and place for the disclosure or discovery prescribing a discovery method other than the one selected by the party seeking discovery forbidding inquiry into certain matters or limiting the scope of disclosure or discovery to certain matters designating the persons who may be present while the discovery is conducted requiring that a deposition be sealed and opened only on court order requiring that a trade secret or other confidential research development or commercial information not be revealed or be revealed only in a specified way and requiring that the parties simultaneously file specified documents or information in sealed envelopes to be opened as the court directs Fed.R.Civ.P Epstein seeks the production from the Trustee of privileged confidential and attorney work product materials The requested documents relating to the bona fide cases of clients are not relevant or calculated to lead to the discovery of admissible evidence in the instant bankruptcy action or any adversary proceeding presently before this Court Therefore the requested documents are beyond the scope of permissible discovery The requested materials are not discoverable under the Florida Rules of Civil Procedure the Federal Rules of Civil Procedure the Bankruptcy Rules of Civil Procedure or any other possibly applicable system of rules Moreover the document production methodology established by order of this Court was not intended to be a conduit of privileged and work product of RRAs former clients to the clients litigation adversaries Epsteins counsel distorts and misrepresents the purpose of the document production methodology by arguing that it was created to facilitate such improper Case Doc Filed Page of discovery Epsteins counsel further attempts to skirt the issue of privilege by failing to meaningfully identify the nature of the requested materials other than describing emails and documents other than emails The materials requested by Epstein essentially case files client files and investigative files are patently and obviously privileged Epsteins counsel offers no argument cognizable under any set of possibly applicable rules to demonstrate entitlement to these privileged and work product materials WHEREFORE based on the foregoing Epstein is not permitted to obtain production of documents and ESI from the Trustee which comprise the privileged confidential or attorney work product portions of case files or investigative files and Movant requests that the Court deny Epsteins motion to compel grant the foregoing motion for protective order and enter a protective order excluding the production of any documents or ESI by the Trustee which relate to any cases or matter of Edwardss clients and granting any other relief the Court deems appropriate I HEREBY CERTIFY that pursuant to L.R Movants counsel has contacted Epsteins counsel in a good faith attempt to resolve the matter without a hearing and I further certify that a true and correct copy of the foregoing was served on electronically to the examinee the debtor the attorney for the debtor the trustee all CM/ECF subscribers and by email or U.S Mail on those parties listed on the attached service list this th day of September I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule A Case Doc Filed Page of Seth Lehrman Seth Lehrman seth pathtojustice.com Florida Bar No FARMER JAFFE WEISSING EDWARDS FISTOS LEHRMAN P.L North Andrews Avenue Suite Fort Lauderdale FL fax Jack Scarola Florida Bar No Searcy Denney Scarola Barnhart Shipley Palm Beach Lakes Blvd West Palm Beach FL fax Attorney for Bradley Edwards in the matter of Epstein Edwards et al Case No Case Doc Filed Page of MASTER SERVICE LIST CASE NO Marianella Morales Esquire Authorized Agent For Joining Creditors A venida Francisco de Miranda Torre Provincial A Piso Caracas Venezuela VIA CM/ECF and EMAIL John Genovese Esq Robert Elgidely Esq Theresa M.B Van Vliet Esq Genovese Joblove Battista PA Bank Of America Tower at International Place S.E 2nd Street Suite Miami Florida VIA CM/ECF and EMAIL Kendall Coffey Esq Coffey Burlington Office in the Grove Penthouse South Bayshore Drive Miami Florida kcoffey coffeyburlington.com VIA CM/ECF and EMAIL The Honorable Herbert Stettin One Biscayne Tower Suite Two South Biscayne Boulevard Miami Florida VIA U.S MAIL and EMAIL John Bianco Esq John Mulli Esquire Tripp Scott Southeast Sixth Street Fifteenth Floor Fort Lauderdale Fl gb tri ppscott com VIA CM/ECF and EMAIL Alison Lehr Esq Grisel Alonso Esq Assistant United States Attorney N.E 4th Street 7th Floor Miami Florida Alison.Lehr usdoj.gov Grisel.alonso usdoj.gov VIA CM/ECF and EMAIL Jeffrey Sonn Esq Sonn Erez PLC Broward Financial Center Broward Boulevard Suite Fort Lauderdale Florida jsonn sonnerez.com VIA CM/ECF and EMAIL Office of the US Trustee Southwest First A venue Suite Miami Florida VIA CM/ECF and EMAIL Thomas Tew Esq Tew-Cardenas LLP Four Seasons Tower 15th Floor Brickell A venue Miami Florida tt tewlaw.com VIA CM/ECF and EMAIL Conrad Scherer LLP South Federal Highway Fort Lauderdale FL bs conradscherer.com JS i ver conradscherer.com VIA CM/ECF and EMAIL Case Doc Filed Page of Michael Seese Esq Hinshaw Culbertson LLP I Broward Blvd Ste Ft Lauderdale Florida I mseese hinshawlaw.com VIA CM/ECF and EMAIL Internal Revenue Service Centralized Insolvency Operations P.O Box Philadelphia PA Via U.S Mail Internal Revenue Service Special Procedures Insolvency SW 6th Court Plantation FL Via U.S Mail Special Asst U.S Attorney P.O Box Stop SW 1st Avenue Miami Fl Via U.S Mail United Healthcare Dept CH I I Palatine IL Via US Mail Special Asst U.S Attorney IRS District Counsel Pine Island Rd Ste Plantation FL Via U.S Mail The Honorable Eric Holder Jr Attorney General of the U.S Pennsylvania A venue NW Room Washington DC Via U.S Mail Honorable Jeffrey Sloman Acting U.S Attorney NE 4th Street Miami Fl Via U.S Mail Daniel Mink Ovadia Levy c/o Renato Watches Inc NW 14th Street Sunrise Florida Via U.S Mail William George Salim Jr Moskowitz Mandell Salim Corporate Dr Ste Fort Lauderdale Florida wsalim mmsslaw.com VIA CM/ECF and EMAIL USI Attn Anthony Gruppo West Cypress Creek Road Suite Fort Lauderdale FL Anthony.gruppo usi.biz VIA EMAIL Marc Nurik Esq East Broward Blvd Suite Fort Lauderdale FL marc nuriklaw.com VIA EMAIL BAST AMRON LLP SunTrust International Center One Southeast Third A venue Suite Miami Florida bamron bastamron.com jbast bastamron.com VIA CM/ECF and EMAIL Case Doc Filed Page of Mark Bloom Esq John Hutton Esq Greenberg Traurig LLP Brickell A venue Miami FL bloomm gtlaw.com huttonj gtlaw.com VIA CM/ECF and EMAIL Robert Critton Esq Burman Critton Luttier Coleman Banyan Blvd Suite West Palm Beach FL rcrit bclclaw.com VIA CM/ECF and EMAIL Roth Scholl Attn Jeffrey Roth Esq Attorneys For Creditor Blue Capital Us East Coast Properties L.P South Dixie Highway Coral Gables Fl jeff rothandscholl.com VIA CM/ECF and EMAIL Rogers Morris Ziegler LLP East Broward Blvd Suite Fort Lauderdale FL fbooth rmzlaw.com VIA CM/ECF and EMAIL Arthur Neiwirth Esq One Broward Blvd Suite Ft Lauderdale FL aneiwirth qpwblaw.com VIA CM/ECF and EMAIL The Florida Bar Adria Quintela Esq Alan Anthony Pascal Esq Lake Shore Plaza II Concord Terrace Suite Sunrise FL aquintel flabar.org apascal flabar.org VIA CM/ECF and EMAIL Micheal Moskowitz Esq Corporate Drive Suite Ft Lauderdale FL mmoskowitz mmsslaw.com VIA CM/ECF and EMAIL Francis Carter Esq Katz Barron Squitero Faust Bayshore Drive 7th Floor Miami Florida fl katzbarron.com VIA CM/ECF and EMAIL Bradley Shraiberg Esq NW Executive Drive Suite Boca Raton Florida bshraiberg sfl-pa.com VIA CM/ECF and EMAIL Henry Wulf Esq CARLTON FIELDS P.A Okeechobee Blvd Suite West Palm Beach Florida E-Mail hwulf carltonfields.com VIA CM/ECF and EMAIL EMESS Capital LLC c/o Bruce A Katzen Esq Biscayne Blvd 17th Floor Miami Florida E-Mail bkatzen klugerkaplan.com jberman klugerkaplan.com VIA CM/ECF and EMAIL Case Doc Filed Page of Ira Sochet Trustee Revocable Intervivos Trust of Ira Sochet c/o Phil Hudson Esq South Biscayne Blvd Suite Miami Florida E-Mail pmhudson amstein.com VIA CM/ECF and EMAIL Coquina Investments c/o Patricia A Redmond Esq West Flagler Street Suite Miami Florida E-Mail predmond steamsweaver.com VIA CM/ECF and EMAIL Michael I Goldberg Esq Las Olas Centre Suite East Las Olas Blvd Fort Lauderdale FL E-Mail Michael.goldberg akerman.com Eyal.berger akerman.com VIA CM/ECF and EMAIL LMB Funding Group c/o Robert Furr Esq Glades Road Suite Boca Raton Florida E-Mail rfurr furrcohen.com VIA CM/ECF and EMAIL Lawrence A Gordich Esq Melissa Alagna Esq SEGALL/GORDICH P.A Brickell Avenue Suite Miami Florida Email lag segallgordich.com Email mma segallgordich.com VIA CM/ECF and EMAIL Broward County Attn Hollie Hawn Esq Government Center South Andrews A venue Fort Lauderdale FL E-Mail hhawn broward.org VIA CM/ECF and EMAIL Steven Solomon Esq Gray Robinson P.A Brickell Ave Suite Miami Florida E-Mail steven.solomon gray-robinson com VIA CM/ECF and EMAIL Peter Valori Esq DAMIAN ALO RI LLP Brickell A venue Suite Miami FL E-mail pvalori dvllp.com VIA CM/ECF and EMAIL Canon Financial Services Inc Gaither Drive Mount Laurel NJ Via US Mail CIT Technology Financing Services I LLC Centurion Parkway North Jacksonville FL Via US Mail Gibraltar Private Bank Trust Company Alhambra Circle Suite Coral Gables FL Via US Mail Inter-Tel Leasing Inc West Loop North Houston TX Via US Mail Florida Department of Revenue Calhoun Street Room Carlton Building Tallahassee FL Via US Mail Case Doc Filed Page of Leon County Tax Collector Calhoun Street Suite Tallahassee FL Via US Mail Miami-Dade County Tax Collectors West Flagler Street 14th Floor Miami FL Via US Mail Palm Beach County Tax Collector P.O Box West Palm Beach FL Via US Mail THE LAW OFFICES OF GEOFFREY ITTLEMAN P.A North Andrews Avenue Fort Lauderdale Florida Via US Mail Carpenter Berger PL Andrew Ave suite Fort Lauderdale FL Via US Mail Frank McGinn Esq Bartlett Hackett Feinberg P.C Federal Street 9th Floor Boston MA ffm boston businesslaw com VIA CM/ECF and EMAIL Daro Carr Esq Nesbit Street Punta Gorda FL dcarr farr.com VIA CM/ECF and EMAIL Jane A Bee Esq Blank Rome LLP North 18th Street Philadelphia PA bee blankrome.com VIA EMAIL Roderick Coleman Esq South Dixie Highway Suite Boca Raton FL rfc colemanattomeys.com VIA CM/ECF and EMAIL Mark Haltzman Esq Lamm Rubenstone LLC Horizon Blvd Suite Trevose PA mhaltzrnan lammrubenstone.com VIA CM/ECF and EMAIL Robert Busche Esq S.E Third Ave Suite Fort Lauderdale FL buschel bglaw-pa.com VIA CM/ECF and EMAIL Berkowitz Dick Pollack Brant Certified Public Accountants Consultants LLP Biscayne Boulevard Sixth Floor Miami FL Attn Richard Pollack Via Email and U.S Mail MELAND RUSSIN BUDWICK P.A Wachovia Financial Center South Biscayne Boulevard Miami Florida Attn James Moon Esq jmoon melandrussin.com Attn Peter Russin Esq prussin melandrussin.com Attn Michael Budwick Esq mbudwick melandrussin.com VIA CM/ECF and EMAIL Gary Blake Esq Palmetto Park Rd Suite Boca Raton FL gb lake lglaw.net VIA CM/ECF and EMAIL Case Doc Filed Page of Melinda Thornton Esq Assistant County Attorney County Attorneys Office Stephen Clark Center N.W First Street Miami Fl Email cao.bkc miamidade.gov VIA CM/ECF and EMAIL SLATKIN REYNOLDS P.A Attorneys for Russell Adler and Katie Adler One East Broward Boulevard Suite Fort Lauderdale Florida jslatkin slatkinreynolds.com VIA CM/ECF and EMAIL ASSOULINE BERLOWE P.A East Sheridan Street Ste Dania Beach FL Attn Eric Assouline Esq ena assoulineberlowe.com VIA CM/ECF and EMAIL Steven Reisman Esq CURTIS Case Doc Filed Page of BAN A ORDERED in the Southern District of Florida on Raymond Ray Judge United States Bankruptcy Court INRE UNITED STA TES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION flsb.uscourts.gov ROTHSTEIN ROSENFELDT ADLER P.A CASE NO CHAPTER Debtor AMENDED ORDER RESPECTING PRODUCTION OF DOCUMENTS REGARDING JEFFREY EPSTEIN THIS CAUSE came before the Court for hearing on October upon the Motion to Clarify Order Appointing Special Master D.E which pertains to this Courts Order Respecting Production of Documents Regarding Jeffrey Epstein D.E Order The Court heard argument of all counsel present at the hearing and being otherwise duly advised in the premises DOES HEREBY ORDER I Order is amended solely as follows EXHIBIT I Case Doc Filed Page of a Within two business days following receipt of this order Berger Singerman as counsel for the Trustee Herbert Stettin Trustee shall deliver to Gary Farmer at the Farmer Jaffe Weissing Edwards Fistos Lehrman P.L law firm Farmer Jaffe a copy of the CD produced pursuant to Order to Judge Robert Carney as Special Master and which contains all electronically stored information ESI and other documents in the Trustees possession respecting the subject matter of the subpoena previously served upon the Trustee related to L.M Scott Rothstein Brad Edwards and Jeffrey Epstein Farmer Jaffe shall review all documents contained on the CD and prepare a detailed privilege log within thirty days of receipt of the CD Farmer Jaffe shall serve the privilege log on all parties in interest to these proceedings and file same with the Court Contemporaneous with the service and filing of the privilege log Farmer Jaffe shall provide to a reputable copy service an unredacted copy of the Trustees CD of documents and that copy service shall duplicate and bate stamp all documents on the CD and return all materials to Farmer Jaffe who shall forthwith notify Trustees counsel and the Special Master of the bate stamp range of documents Farmer Jaffe shall then extract from the hard copy duplicated documents solely those documents which it listed on the privilege log and segregate those documents for submission to the Special Master and the Trustees counsel Farmer Jaffe shall furnish copies of the segregated documents to which it asserts a privilege both to the Special Master and the Trustee at Farmer Jaffes cost To the extent that documents on the CD are duplicated and not subject to an assertion of privilege they shall be forthwith provided to counsel for Epstein counsel to the Razorback creditors as well as to any other party who requests such documents all at their own respective cost Case Doc Filed Page of Following service and filing of the privilege log the Special Master shall schedule a hearing to occur at the offices of Berger Singerman where all parties in interest will have the opportunity to provide written submissions respecting the privilege log and to make argument on all issues relevant to the applicability of privilege as to the documents listed on the Farmer Jaffe privilege log That hearing shall be transcribed by a court reporter Following completion of the aforementioned hearing the Special Master shall prepare a report making all appropriate findings and recommendations to the Court which shall be served on all parties in interest and filed with the Court along with the transcript of the Special Masters hearing Any party may file a written objection to the Special Masters report within ten days after service of same If no party files an objection to the report the Court shall approve the report and adopt same into a court order without further notice to the parties If an objection to the report is filed by any party in interest then this Court shall schedule and hold a hearing to resolve with finality the issues of privilege as consistent with the appropriate law and procedures set forth herein Submitted by Charles Lichtman Esq BERGER SINGERMAN P.A East Las Olas Boulevard Suite 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 INRE Case Doc Filed Page of UNITED ST A TES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION w.flsb.uscourts.gov ROTHSTEIN ROSENFELDT ADLER P.A CASE NO CHAPTER Debtor I MOTION FOR RELIEF FROM AMENDED ORDER D.E AND TO COMPEL JEFFREY EPSTEIN TO PAY FOR THE PRODUCTION OF ALL DOCUMENTS IN RESPONSE TO HIS REQUEST Movants LM and Bradley Edwards move this Court for relief from Amended Order D.E related to the production of documents requested by Jeffrey Epstein and to Compel Jeffrey Epstein to Pay for the Production of all Documents which he has requested and in support thereof states as follows Brad Edwards an attorney employed by Farmer Jaffe Weissing Edwards Fistos Lehrman P.L Farmer Jaffe Weissing has represented LM and other women who allege that they were sexually exploited sexually abused and otherwise victims of intentional and despicable conduct of Jeffrey Epstein Epsteins conduct has been the subject of several lawsuits vigorously litigated by Mr Edwards as well as similar lawsuits filed by other well-known attorneys and law firms on behalf of other victims Epstein filed a frivolous lawsuit against Attorney Edwards and his client LM who is one of Epsteins former victims and through this lawsuit has sought voluminous discovery from the Trustee including many documents which are patently subject to claims of privilege and/or attorney work product and/or privacy Epsteins requests were so overbroad that they include the entire legitimate case files and investigative files of Attorney Edwards The Court previously entered Amended Order D.E which crafted a EXHIBIT Case Doc Filed Page of procedure by which the undersigned counsel would have a reasonable opportunity to review those documents in the Trustees possession which are responsive to Epsteins request Accordingly the Amended Order directed the Trustee to provide the undersigned counsel with documents and ESI in response to a state court subpoena duces tecum served by Jeffrey Epstein This Amended Order directs the undersigned counsel to prepare and file a privilege log and imposes the expense associated with printing all documents produced by the Trustee on undersigned counsel Prior to receiving the CD from Trustees counsel the undersigned as well as perhaps all parties involved was under the impression that the production consisted of approximately pages of documents In fact it was during or just after the hearing on Special Masters Motion to Clarify Order Appointing Special Master when Trustees counsel realized that the Trustee may be in possession of additional ESI stored in a Fortis file system Consequently the Trustee has now produced to the undersigned counsel two compact discs CDs which contain approximately pages of documents Additionally one of the files produced by Trustee was a corrupt and unworkable file on October IO Movants requested that this corrupted file be resent to their office In addition Movants requested that the files be Bates stamped electronically so that a better record for the privilege log can be created To date Movants still have not received the new disc Once Movants receive all files in a workable format reviewing pages of documents and creating a privilege log will take considerable more attorney time than was anticipated Consequently Movants are requesting an additional days to complete this process Case Doc Filed Page of In accordance with this Courts order undersigned counsel have obtained an estimate of the printing and bates stamping costs associated with printing this page collection of documents requested by Epstein The cost of printing these documents exceeds per page pages Epstein through counsel has previously represented to the Trustee that he is willing to bear the reasonable expense associated with this production and in fact the original Order that contemplated Special Master Carney preparing the Privilege log DE directly stated All legal fees and costs incurred by the Special Master shall be paid by Epstein who has already agreed to pay directly all such fees and costs With approximately pages to print bates stamp review and create a privilege log that can only be done by the attorneys that handled or are handling the Epstein related cases it will take many full days for the attorneys to complete and the attorneys engaging in this exercise should be compensated for their time It is entirely reasonable that Epstein the party seeking this discovery bear the printing expense and other reasonable costs and attorneys fees associated with his discovery request WHEREFORE based on the foregoing LM and Attorney Edwards request that the Court grant this motion for relief from amended order DE and enter an order which compels Epstein to prepay the cost of printing all documents responsive to his request as well as reasonable attorneys fees for this time-consuming task and enlarging the time for the undersigned counsel to file a privilege log by thirty days from the date that Epstein pays the printing costs and granting any other relief the Court deems appropriate I HEREBY CERTIFY that pursuant to L.R Movants counsel has Case Doc Filed Page of contacted Epsteins counsel in a good faith attempt to resolve the matter without a hearing and I further certify that a true and correct copy of the foregoing was served on electronically to the examinee the debtor the attorney for the debtor the trustee all CMIECF subscribers and by email or U.S Mail on those parties listed on the attached service list this 2nd day of November I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule A FARMER JAFFE WEISSING EDWARDS FISTOS LEHRMAN P.L By Isl Seth Lehrman Seth Lehrman FLBN Gary Farmer FLBN Brad Edwards FLBN North Andrews Avenue Suite Fort Lauderdale Florida I Fax seth pathtojustice.com JACK SCAROLA Florida Bar No Searcy Denney Scarola Barnhart Shipley Palm Beach Lakes Blvd West Palm Beach FL fax Case Doc Filed Page of MASTER SERVICE LIST CASE NO Marianella Morales Esquire Authorized Agent For Joining Creditors A venida Francisco de Miranda Torre Provincial A Piso Caracas Venezuela VIA CM/ECF and EMAIL John Genovese Esq Robert Elgidely Esq Theresa M.B Van Vliet Esq Genovese Joblove Battista PA Bank Of America Tower at International Place I S.E 2nd Street Suite Miami Florida VIA CM/ECF and EMAIL Kendall Coffey Esq Coffey Burlington Office in the Grove Penthouse South Bayshore Drive Miami Florida kcoffey coffeybLirlington.com VIA CM/ECF and EMAIL The Honorable Herbert Stettin One Biscayne Tower Suite Two South Biscayne Boulevard Miami Florida VIA U.S MAIL and EMAIL John Bianco Esq John Mulli Esquire Tripp Scott Southeast Sixth Street Fifteenth Floor Fort Lauderdale Fl gb tri ppscott com VIA CM/ECF and EMAIL Alison Lehr Esq Grisel Alonso Esq Assistant United States Attorney N.E 4th Street 7th Floor Miami Florida Alison.Lehr usdoj.gov Grisel.alonso usdoj.gov VIA CM/ECF and EMAIL Jeffrey Sonn Esq Sonn Erez PLC Broward Financial Center Broward Boulevard Suite Fort Lauderdale Florida sonn sonnerez.com VIA CM/ECF and EMAIL Office of the US Trustee Southwest First A venue Suite Miami Florida VIA CM/ECF and EMAIL Thomas Tew Esq Tew-Cardenas LLP Four Seasons Tower 15th Floor Brickell A venue Miami Florida tt tewlaw.com VIA CM/ECF and EMAIL Conrad Scherer LLP South Federal Highway Fort Lauderdale FL bs conradscherer.com JSilver conradscherer.com VIA CM/ECF and EMAIL Case Doc Filed Page of Michael Seese Esq Hinshaw Culbertson LLP IE Broward Blvd Ste Ft Lauderdale Florida mseese hinshawlaw.com VIA CM/ECF and EMAIL Internal Revenue Service Centralized Insolvency Operations P.O Box Philadelphia PA Via U.S Mail Internal Revenue Service Special Procedures Insolvency SW 6th Court Plantation FL Via U.S Mail Special Asst U.S Attorney P.O Box Stop SW 1st Avenue Miami Fl Via U.S Mail United Healthcare Dept CH Palatine IL Via US Mail Special Asst U.S Attorney IRS District Counsel Pine Island Rd Ste Plantation FL Via U.S Mail The Honorable Eric Holder Jr Attorney General of the U.S Pennsylvania A venue NW Room Washington DC Via U.S Mail Honorable Jeffrey Sloman Acting U.S Attorney NE 4th Street Miami Fl Via U.S Mail Daniel Mink Ovadia Levy c/o Renato Watches Inc NW 14th Street Sunrise Florida Via U.S Mail William George Salim Jr Moskowitz Mandell Salim Corporate Dr Ste Fort Lauderdale Florida wsalim mmsslaw.com VIA CM/ECF and EMAIL USI Attn Anthony Gruppo West Cypress Creek Road Suite Fort Lauderdale FL Anthony.gruppo usi.biz VIA EMAIL Marc Nurik Esq I East Broward Blvd Suite Fort Lauderdale FL marc nuriklaw.com VIA EMAIL BAST AMRON LLP SunTrust International Center One Southeast Third A venue Suite Miami Florida bamron bastamron.com jbast bastamron.com VIA CM/ECF and EMAIL Case Doc Filed Page of Mark Bloom Esq John Hutton Esq Greenberg Traurig LLP Brickell Avenue Miami FL bloomm gtlaw.com huttonj gtlaw.com VIA CM/ECF and EMAIL Robert Critton Esq Burman Critton Luttier Coleman Banyan Blvd Suite West Palm Beach FL rcrit bclclaw.com VIA CM/ECF and EMAIL Roth Scholl Attn Jeffrey Roth Esq Attorneys For Creditor Blue Capital Us East Coast Properties L.P South Dixie Highway Coral Gables FI eff rothandsch com VIA CM/ECF and EMAIL Rogers Morris Ziegler LLP East Broward Blvd Suite Fort Lauderdale FL tbooth rmzlaw.com VIA CM/ECF and EMAIL Arthur Neiwirth Esq One Broward Blvd Suite Ft Lauderdale FL aneiwirth qpwblaw.com VIA CM/ECF and EMAIL The Florida Bar Adria Quintela Esq Alan Anthony Pascal Esq Lake Shore Plaza II Concord Terrace Suite Sunrise FL aquintel flabar.org apascal flabar.org VIA CM/ECF and EMAIL Micheal Moskowitz Esq Corporate Drive Suite Ft Lauderdale FL mmoskowitz mmsslaw.com VIA CM/ECF and EMAIL Francis Carter Esq Katz Barron Squitero Faust Bayshore Drive 7th Floor Miami Florida fl katzbarron.com VIA CM/ECF and EMAIL Bradley Shraiberg Esq NW Executive Drive Suite Boca Raton Florida bshraiberg sfl-pa.com VIA CM/ECF and EMAIL Henry Wulf Esq CARLTON FIELDS P.A Okeechobee Blvd Suite West Palm Beach Florida E-Mail hwulf carltonfields.com VIA CM/ECF and EMAIL EMESS Capital LLC c/o Bruce A Katzen Esq Biscayne Blvd 17th Floor Miami Florida E-Mail bkatzen klugerkaplan.com jberman klugerkaplan.com VIA CM/ECF and EMAIL Case Doc Filed Page of Ira Sochet Trustee Revocable Intervivos Trust of Ira Sochet c/o Phil Hudson Esq South Biscayne Blvd Suite Miami Florida E-Mail pmhudson arnstein.com VIA CM/ECF and EMAIL Coquina Investments c/o Patricia A Redmond Esq West Flagler Street Suite Miami Florida E-Mail predmond stearnsweaver.com VIA CM/ECF and EMAIL Michael I Goldberg Esq Las Olas Centre Suite East Las Olas Blvd Fort Lauderdale FL E-Mail Michael.goldberg akennan.com Eyal.berger akerman.com VIA CM/ECF and EMAIL LMB Funding Group c/o Robert Furr Esq Glades Road Suite Boca Raton Florida E-Mail rfurr furrcohen.com VIA CM/ECF and EMAIL Lawrence A Gordich Esq Melissa Alagna Esq SEGALL/GORDICH P.A Brickell A venue Suite Miami Florida Email lag segallgordich.com Email mma segallgordich.com VIA CM/ECF and EMAIL Broward County Attn Hollie Hawn Esq Government Center South Andrews A venue Fort Lauderdale FL E-Mail hhawn broward.org VIA CM/ECF and EMAIL Steven Solomon Esq Gray Robinson P.A Brickell Ave Suite Miami Florida E-Mail steven.solomon gray-robinson com VIA CM/ECF and EMAIL Peter Valori Esq DAMIAN ALO RI LLP Brickell A venue Suite Miami FL E-mail pvalori dvllp.com VIA CM/ECF and EMAIL Canon Financial Services Inc Gaither Drive Mount Laurel NJ Via US Mail CIT Technology Financing Services I LLC Centurion Parkway North Jacksonville FL Via US Mail Gibraltar Private Bank Trust Company Alhambra Circle Suite Coral Gables FL Via US Mail Inter-Tel Leasing Inc West Loop North Houston TX Via US Mail Florida Department of Revenue Calhoun Street Room Carlton Building Tallahassee FL Via US Mail Case Doc Filed Page of Leon County Tax Collector Calhoun Street Suite Tallahassee FL Via US Mail Miami-Dade County Tax Collectors West Flagler Street 14th Floor Miami FL Via US Mail Palm Beach County Tax Collector P.O Box West Palm Beach FL Via US Mail THE LAW OFFICES OF GEOFFREY ITTLEMAN P.A North Andrews Avenue Fort Lauderdale Florida Via US Mail Carpenter Berger PL Andrew Ave suite Fort Lauderdale FL Via US Mail Frank McGinn Esq Bartlett Hackett Feinberg P.C Federal Street 9th Floor Boston MA ffm bostonbusinesslaw.com VIA CM/ECF and EMAIL Daro Carr Esq Nesbit Street Punta Gorda FL dcarr farr.com VIA CM/ECF and EMAIL Jane A Bee Esq Blank Rome LLP North 18th Street Philadelphia PA bee blankrome.com VIA EMAIL Roderick Coleman Esq South Dixie Highway Suite Boca Raton FL rfc colemanattomeys.com VIA CM/ECF and EMAIL Mark Haltzman Esq Lamm Rubenstone LLC Horizon Blvd Suite Trevose PA mhaltzman lammrubenstone.com VIA CM/ECF and EMAIL Robert Busche Esq S.E Third Ave Suite Fort Lauderdale FL buschel bglaw-pa.com VIA CM/ECF and EMAIL Berkowitz Dick Pollack Brant Certified Public Accountants Consultants LLP Biscayne Boulevard Sixth Floor Miami FL Attn Richard Pollack Via Email and U.S Mail MELAND RUSSIN BUDWICK P.A Wachovia Financial Center South Biscayne Boulevard Miami Florida Attn James Moon Esq jmoon melandrussin.com Attn Peter Russin Esq prussin melandrussin.com Attn Michael Budwick Esq mbudwick melandrussin.com VIA CM/ECF and EMAIL Gary Blake Esq Palmetto Park Rd Suite Boca Raton FL gblake lglaw.net VIA CM/ECF and EMAIL Case Doc Filed Page of Melinda Thornton Esq Assistant County Attorney County Attorneys Office Stephen Clark Center N.W First Street Miami Fl Email cao.bkc miamidade.gov VIA CM/ECF and EMAIL SLATKIN REYNOLDS P.A Attorneys for Russell Adler and Katie Adler One East Broward Boulevard Suite Fort Lauderdale Florida jslatkin slatkinreynolds.com VIA CM/ECF and EMAIL ASSOULINE BERLOWE P.A East Sheridan Street Ste Dania Beach FL Attn Eric Assouline Esq ena assoulineberlowe.com VIA CM/ECF and EMAIL Steven Reisman Esq CURTIS Case Doc Filed Page of
