Case Document Entered on FLSD Docket Page of Jane Doe No.2 Epstein Case No Epsteins Emergency Motion for Order for the Preservation of Evidence Incorporated Memorandum of Law Page of protect themselves from potential criminal or bar related violations Epstein seeks only to preserve the status quo as to the relief sought Relevant to this motion Epstein is currently the named Defendant in three civil actions one of which is filed in federal court Jane Doe Epstein Case No 08-CIV U.S.D.C S.D Fla and two of which have been fil in state court in the th Judicial Circuit Court Palm Beach County State of Florida L.M Esptein Case No AB E.W Epstein Case No AB hereinafter civil actions In each of these civil actions each of the Plaintiffs is represented by Bradley Edwards William Berger and the RRA law firm NE 2d Street Hallendale Beach Florida Attorneys Russell Alder and Peter Feaman have also appeared for the Plaintiffs Based upon recent and ongoing media reports statements of law enforcement personnel FBI and others and statements of attorneys for investors as more fully detailed below herein RRA and Scott Rothstein and possibly other attorneys and/or members illegally and unethically solicited investors to invest monies in and/or to buy a financial interest in the potential outcome or settlement of pending or prospective lawsuits or settled lawsuits and operated a Ponzi scheme Based upon media reports and statements by persons with knowledge of this investment scam RRA by and through its attorneys and members would seek monies from investors in exchange for a promise of a financial interest in a structured settlement or outcome of potential or pending legal actions or to purchase an interest therein Case Document Entered on FLSD Docket Page of Jane Doe No.2 Epstein Case No Epsteins Emergency Motion for Order for the Preservation of Evidence Incorporated Memorandum of Law Page of9 As part of this scheme RRA by and through its attorneys and members may have unethically and illegally A Sold an interest in non-settled personal injury lawsuits which are non assignable and non-transferable or sold a non-existent structured settlements including those cases involving Epstein Reached agreements to share attorneys fees with non-lawyers Used investor money to pay plaintiffs up front money such that plaintiffs would refuse to settle Conducted searches wiretaps or other activities in violation of state or federal laws and Bar rules Any such actions by RRA through its attorneys and members would be a violation of various Florida Bar Rules prohibiting the improper sharing of fees or costs and various conflict of issues rules to name a few This of course raises many questions such as how can any RRA attorney in these civil actions represent its clients interests and give unbiased legal counsel when an outside investor has been promised a financial interest in the outcome of the action if a plaintiff is receiving payments from investment monies while her action is ongoing this clearly would impact the plaintiffs decision of whether or not to settle the current litigation are the Plaintiffs motivated to in essence commit perjury or shade their testimony to gain the greatest return on the investment In essence if RRA was counseling its Plaintiffs to either knowingly or unknowingly participate in an improper and unethical investment scheme and the client was a participant her case may be subject to dismissal Case Document Entered on FLSD Docket Page of Jane Doe No.2 Epstein Case No Epsteins Emergency Motion for Order for the Preservation of Evidence Incorporated Memorandum of Law Page of9 Miami attorney and developer Alan Sakowitz was quoted in a recent article as saying that he had met with Rothstein as a potential investor in August of but became suspicious He stated I was convinced it was all a Ponzi scheme and I notified the FBI in detail how Scotty was hiding behind a legitimate law firm to peddle fake investments Attorney Sakowitz was also quoted as saying Rothstein had sophisticated eavesdropping equipment and former law enforcement officers who would sift through a potential defendants garbage Respected Ft Lauderdale attorney William Scherer represents multiple Rothstein related investors He indicated in an article that RRA/Rothstein had used the Epstein Ploy as a showpiece as bait Thats the way he raised all the money He would used legitimate cases as bait for luring investors into fictional cases All the cases he allegedly structured were fictional I dont believe there was a real one in there Relevant to Epstein and these three civil actions the evidence as detailed below herein is required to be preserved to ensure that any and all evidence of a improper or illegal payments to the three Plaintiffs the specific details of the investment scheme who what when how much all written agreements between investors Rothstein RRA and any Plaintiff investigator billings and services and any other evidence relevant to the investment scheme which has been estimated to be in the range of million according to media reports is not destroyed by RRA and Bradley Edwards Stuart Rosenfeldt Herbert Stettin as Court Appointed Receiver in each of their capacities as Records Custodian employees agents associates partners or other representative for RRA Case Document Entered on FLSD Docket Page of Jane Doe No.2 Epstein Case No Epsteins Emergency Motion for Order for the Preservation of Evidence Incorporated Memorandum of Law Page of Defendant has previously served Subpoenas Duces Tecum for Deposition dated November upon Bradley Edwards Esq Rothstein Rosenfeldt Adler PA Stuart Rosenfeldt Esq as Records Custodian For RRA and Herbert Stettin as the Court Appointed Receiver for RRA The Subpoenas which were filed in the state court action of Epstein referenced above are attached as Composite Exhibit A Epstein believes RRA and the persons identified herein exercise sole custody and control over all the items identified in the subpoenas The items identified are directly relevant to the impact of the described investment scheme on the civil actions in which Esptein is named as a Defendant Defendant seeks an Order preserving the items specifically identified in the attached Subpoenas Composite Exhibit A and as well any investigators firm employed or third party billings and services documents and directing Bradley Edwards Esq Rothstein Rosenfeldt Adler PA Stuart Rosenfeldt Esq as Records Custodian For RRA and Herbert Stettin as Court Appointed Receiver as receiver for RRA to neither destroy tamper with or alter any evidence relevant to the investment scheme described above herein A proposed order is attached as Exhibit When there is a good faith belief that evidence may be lost or destroyed the Court has the authority to enter an order preserving such evidence See AT Mobility LLC Dynamic Cellular Corp WL S.D Fla May Tracfone Wireless Inc King Trading Inc WL at N.D Tex Mar finding a legitimate concern for the continuing existence and maintenance of the integrity of the evidence in question absent an order preserving the evidence This Case Document Entered on FLSD Docket Page of Jane Doe No.2 Epstein Case No Epsteins Emergency Motion for Order for the Preservation of Evidence Incorporated Memorandum of Law Page of9 evidence most of which is in the sole custody dominion and control of the persons and entity identified herein is critical and indispensable to Epsteins ability to fully defend the actions brought against him and to evaluate and analyze whether the Plaintiffs and their attorney have been acting in good faith and in truthful manner when it comes to discovery and attempts to resolve the actions and also whether unethical illegal or fraudulent conduct has occurred which would preclude Plaintiffs from pursuing their claims or whether Plaintiffs and their attorneys irresolvable conflicts Epsteins concerns outweigh any potential harm to the Plaintiffs from the entry of an order preserving the evidence There is no burden to the Plaintiffs as it the lawyers law firm and receiver identified herein that possess and control the items identified in the subpoenas WHEREFORE Epstein respectfully requests this Court enter an Order to preserve all evidence relevant to the investment scheme as described herein and to further prohibit the persons and RRA from tampering destroying or altering any such evidence and to grant any additional relief the Court deems just and proper Rule A Certification of Pre-Filing Conference Counsel for Defendant in good faith conferred with Plaintiffs counsel Bradley Edwards by telephone and Mr Edwards does not oppose the entry of an order Counsel for Defendant wrote and enclosed copies of this motion and proposed agreed orders to Kendall Coffey Esq counsel for Stuart A Rosenfeldt individually and Rothstein Rosenfeldt Adler P.A Coffey Burlington South Bayshore Drive Penthouse Miami Florida and Paul Singerman Esq counsel for Herbert Case Document Entered on FLSD Docket Page of Jane Doe No.2 Epstein Case No Epsteins Emergency Motion for Order for the Preservation of Evidence Incorporated Memorandum of Law Page of Stettin Esq as Court Appointed Receiver Berger Singerman South Biscayne Blvd Suite Miami FL At the time this motion is being filed the undersigned has not received a response from Mr Coffey or Mr Singerm By s/Robert Critton ROBERT CRITTON JR Florida Bar No rcrit bclclaw.com Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed 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 identified on the following Service List in the manner specified by CM/ECF on this 12th day of November A true copy was served by fax and U.S Mail to Kendall Coffey Esq counsel for Stuart A Rosenfeldt individually and Rothstein Rosenfeldt Adler P.A Coffey Burlington South Bayshore Drive Penthouse Miami Florida and Paul Singerman Esq counsel for Herbert Stettin Esq as Court Appointed Receiver Berger Singerman South Biscayne Blvd Suite Miami FL Respectfully submitted By s/Robert Critton ROBERT CRITTON JR Florida Bar No rcrit bclclaw.com MICHAEL PIKE ESQ Florida Bar mpike bclclaw.com BURMAN CRITTON LUTTIER COLEMAN Banyan Boulevard Suite West Palm Beach FL Phone Fax Counsel for Defendant Jeffrey Epstein Case Document Entered on FLSD Docket Page of Jane Doe No.2 Epstein Case No Epsteins Emergency Motion for Order for the Preservation of Evidence Incorporated Memorandum of Law Page of Certificate of Service Jane Doe No Jeffrey Epstein Case No 08-CV-80119-MARRA/JOHNSON Stuart Mermelstein Esq Adam Horowitz Esq Mermelstein Horowitz P.A Biscayne Boulevard Suite Miami FL Fax ssm sexabuseattorney.com ahorowitz sexabuseattorney.com Counsel for Plaintiffs In related Cases Nos Richard Horace Willits Esq Richard Willits P.A th Avenue North Suite Lake Worth FL Fax Counsel for Plaintiff in Related Case No reelrhw hotmail.com Jack Scarola Esq Jack Hill Esq Brad Edwards Esq Rothstein Rosenfeldt Adler East Las Olas Boulevard Suite Fort Lauderdale FL Phone Fax bedwards rra-law.com Counsel for Plaintiff in Related Case No Paul Cassell Esq Pro Hae Vice South Room Salt Lake City UT Fax cassellp law.utah.edu Co-counsel for Plaintiff Jane Doe Isidro Garcia Esq Garcia Law Firm P.A Datura Street Suite West Palm Beach FL isid rogarcia bellsouth.net Counsel for Plaintiff in Related Case No Searcy Denney Scarola Shipley P.A Barnhart Palm Beach Lakes Boulevard West Palm Beach FL Fax jsx searcylaw.com jph searcylaw.com Counsel for Plaintiff C.M.A Robert Josefsberg Esq Katherine Ezell Esq Podhurst Orseck P.A West Flagler Street Suite Miami FL Fax rjosefsberg podhurst.com Case Document Entered on FLSD Docket Page of Jane Doe No.2 Epstein Case No Epsteins Emergency Motion for Order for the Preservation of Evidence Incorporated Memorandum of Law Page of9 Bruce Reinhart Esq Bruce Reinhart P.A Australian Avenue Suite West Palm Beach FL Fax ecf brucereinhartlaw.com Counsel for Defendant Sarah Kellen Theodore Leopold Esq Spencer Kuvin Esq Leopold Kuvin P.A PGA Blvd Suite Palm Beach Gardens FL Fax skuvin leopoldkuvin.com Counsel for Plaintiff in Related Case No kezell podhurst.com Counsel for Plaintiffs in Related Cases Nos and Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Fax jagesg bellsouth.net Counsel for Defendant Jeffrey Epstein Case Document Entered on FLSD Docket Page of L.M Plaintiff JEFFREY EPSTEIN Defendant __ IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO AD SUBPOENA DUCES TECUM FOR DEPOSITION THE STATE OF FLORIDA TO Stuart Rosenfeldt Esq as Records Custodian For Rothstein Rosenfeldt Adler P.A Las Olas Blvd Suite Ft Lauderdale FL YOU ARE COMMANDED to appear at Prose Court Reporting NE rd Avenue Suite Ft Lauderdale FL on November p.m bring with you the following See attached Exhibit A If you fail to appear you may be in contempt of court You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by the attorney or the Court you shall respond to this subpoena as directed DATED this th day of November ROBERTO Attorneys Defendant Jeffrey Epstein Burman Cri on Luttier Coleman Flagler Drive Suite West Palm Beach FL ROBERT CRITTON JR ESQ For the Co rt Cov foc,i/e EXHIBIT_fi Case Document Entered on FLSD Docket Page of EXHIBIT A RECORDS CUSTODIAN DEFINITIONS AND INSTRUCTIONS A Document means any written or graphic matter or other means of preserving thought or expression and all tangible things from which information can be processed or transcribed including the originals and all non-identical copies whether different from the original by reason of any notation made on such copy or otherwise including but not limited to correspondence memoranda notes messages letters purchase orders telegrams teletype telefax bulletins e-mails electronic data meetings reports or other communications interoffice and intra-office telephone calls diaries chronological data minutes books reports charts ledgers invoices worksheets receipts returns trade information regarding fabric carpets samples etc computer printouts prospectuses financial statements schedules affidavits contracts cancelled checks transcripts statistics surveys magazine or newspaper articles releases and any and all drafts alterations and modifications changes and amendments of any of the foregoing graphs or aural records or representations of any kind including without limitation photographs charts graphs microfiche microfilm video tape recordings motion pictures and electronic mechanical or electric recordings or representations of any kind including without limitation tapes cassettes discs and recordings and including the file and file cover The term Document also means any and all computer records data files directories electronic mail and information of whatever kind whether printed out or stored on or retrievable from floppy diskette compact diskette magnetic tape optical or magnetic-optical disk computer memory hard drive zip drive jaz drive orb drive microdisk external memory stick software or any other fixed or removable storage media including without limitation all back-up copies Case Document Entered on FLSD Docket Page of 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 L.M Jeffrey Epstein Palm Beach County Case E.W E.W Jeffrey Epstein Palm Beach County Case Jane Doe/S.R 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 REQUESTED ITEMS For the time period from January to present any and all docwnents reflecting communication 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 RRA and/or its clients or the financing of any litigation between Jeffrey Epstein and RRA and/or its clients including but not limited to a Representations that litigation with Jeffrey Epstein has been settled Soliciting or receiving money in return for settlement funds alleged paid or to be paid on behalf of 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 Case Document Entered on FLSD Docket Page of Communication between third party investors or potential investors and the plaintiffs or their attorneys involved in litigation against Jeffrey Epstein Payments made by RRA to or on behalf of any plaintiff Any and all fee agreements that exist or have existed between the following a Any Plaintiff and Bradley Edwards or any entity with which he was associated Any Plaintiff and the law firm RRA All documents reflecting the sale purchase or investment by any person or entity company corporation LLC etc in the prospective settlement or resolution of any plaintiffs case against Jeffrey Epstein All emails data correspondence memos or similar documents exchanged between Bradley Edwards and Scott Rothstein and/or any attorney or representative of RRA and any investor or third party person or entity in any plaintiffs case where the investor provided financing to include money and/or any other consideration to Bradley Edwards any plaintiff or RRA with regard to the settlement or potential settlement of any plaintiffs case against Jeffrey Epstein All agreements or documents of any nature which were entered into by an investor relating to any plaintiffs case with 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 investment packages or information settlement agreements and any other documents made available to any investor by Bradley Edwards RRA Scott Rothstein or any of Scott Rothsteins entity to solicit investors for or in any plaintiffs case The names and addresses of all individuals or entities who invested in any aspect of any plaintiffs case against Jeffrey Epstein All assignments or agreements between any investor person or entity and any plaintiff and/or her attorneys regarding any plaintiffs case cause of action against Jeffrey Epstein Case Document Entered on FLSD Docket Page of All documents evidencing payment of any bill or costs in each plaintiffs case against Jeffrey Epstein and the source for said payments of any costs All press releases tapes of interviews transcripts of interviews generated by Bradley Edwards or any existing or fom1er RRA attorney regarding any plaintiffs case against Jeffrey Epstein Case Document Entered on FLSD Docket Page of L.M Plaintiff JEFFREY EPSTEIN Defendant IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO AD SUBPOENA DUCES TECUM FOR DEPOSITION THE STATE OF FLORIDA TO Herbert Stettin as receiver for Rothstein Rosenfeldt Adler PA Hammock Drive Coral Gables FL YOU ARE COMMANDED to appear at Prose Court Reporting NE rd Avenue Suite Ft Lauderdale FL on November p.m bring with you the following See attached Exhibit A If you fail to appear you may be in contempt of court You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by the attorney or the Court you shall respond to this subpoena as directed DATED this day of November ROBERT ITTON JR Attorneys for efendant Jeffrey Epstein Burman Critton Luttier Coleman Flagler Drive Suite West Palm Beach FL ROBERT CRITTON JR ESQ For the urt Case Document Entered on FLSD Docket Page of EXHIBIT A RECORDS CUSTODIAN DEFINITIONS AND INSTRUCTIONS A Document means any written or graphic matter or other means of preserving thought or expression and all tangible things from which information can be processed or transcribed including the originals and all non-identical copies whether different from the original by reason of any notation made on such copy or otherwise including but not limited to correspondence memoranda notes messages letters purchase orders telegrams teletype telefax bulletins e-mails electronic data meetings reports or other communications interoffice and intra-office telephone calls diaries chronological data minutes books reports charts ledgers invoices worksheets receipts returns trade information regarding fabric carpets samples etc computer printouts prospectuses financial statements schedules affidavits contracts cancelled checks transcripts statistics surveys magazine or newspaper articles releases and any and all drafts alterations and modifications changes and amendments of any of the foregoing graphs or aural records or representations of any kind including without limitation photographs charts graphs microfiche microfilm video tape recordings motion pictures and electronic mechanical or electric recordings or representations of any kind including without limitation tapes cassettes discs and recordings and including the file and file cover The term Document also means any and all computer records data files directories electronic mail and information of whatever kind whether printed out or stored on or retrievable from floppy diskette compact diskette magnetic tape optical or magnetic-optical disk computer memory hard drive zip drive jaz drive orb drive microdisk external memory stick software or any other fixed or removable storage media including without limitation all back-up copies Case Document Entered on FLSD Docket Page of 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 L.M Jeffrey Epstein Palm Beach County Case E.W E.W Jeffrey Epstein Palm Beach County Case Jane Doe/S.R 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 REQUESTED ITEMS For the time period from January to present any and all documents reflecting communication 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 RRA and/or its clients or the financing of any litigation between Jeffrey Epstein and RRA and/or its clients including but not limited to a Representations that litigation with Jeffrey Epstein has been settled Soliciting or receiving money in return for settlement funds alleged paid or to be paid on behalf of 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 Case Document Entered on FLSD Docket Page of Communication between third party investors or potential investors and the plaintiffs or their attorneys involved in litigation against Jeffrey Epstein Payments made by RRA to or on behalf of any plaintiff Any and all fee agreements that exist or have existed between the following a Any Plaintiff and Bradley Edwards or any entity with which he was associated Any Plaintiff and the law firm RRA All documents reflecting the sale purchase or investment by any person or entity company corporation LLC etc in the prospective settlement or resolution of any plaintiffs case against Jeffrey Epstein All emails data correspondence memos or similar documents exchanged between Bradley Edwards and Scott Rothstein and/or any attorney or representative of RRA and any investor or third party person or entity in any plaintiffs case where the investor provided financing to include money and/or any other consideration to Bradley Edwards any plaintiff or RRA with regard to the settlement or potential settlement of any plaintiffs case against Jeffrey Epstein All agreements or documents of any nature which were entered into by an investor relating to any plaintiffs case with 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 investment packages or information settlement agreements and any other documents made available to any investor by Bradley Edwards RRA Scott Rothstein or any of Scott Rothsteins entity to solicit investors for or in any plaintiffs case The names and addresses of all individuals or entities who invested in any aspect of any plaintiffs case against Jeffrey Epstein All assignments or agreements between any investor person or entity and any plaintiff and/or her attorneys regarding any plaintiffs case cause of action against Jeffrey Epstein Case Document Entered on FLSD Docket Page of All documents evidencing payment of any bill or costs in each plaintiffs case against Jeffrey Epstein and the source for said payments of any costs All press releases tapes of interviews transcripts of interviews generated by Bradley Edwards or any existing or former RRA attorney regarding any plaintiffs case against Jeffrey Epstein Case Document Entered on FLSD Docket Page of L.M Plaintiff JEFFREY EPSTEIN Defendant IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO AD SUBPOENA DUCES TECUM FOR DEPOSITION THE STATE OF FLORIDA TO Bradley Edwards Esq NE nd Street Hallandale Beach FL or Rothstein Rosenfeldt Adler PA NE nd Street Hallendale Beach FL YOU ARE COMMANDED to appear at Prose Court Reporting NE rd Avenue Suite Ft Lauderdale FL on November a.m bring with you the following See attached Exhibit A If you fail to appear you may be in contempt of court You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by the attorney or the Court you shall respond to this subpoena as directed DATED this day of November ITTON JR Attorneys Defendant Jeffrey Epstein Burman Critton Luttier Coleman Flagler Drive Suite West Palm Beach FL ROBERT CRITTON JR ESQ For the ourt Case Document Entered on FLSD Docket Page of EXHIBIT A DEFINITIONS AND INSTRUCTIONS A Document means any written or graphic matter or other means of preserving thought or expression and all tangible things from which information can be processed or transcribed including the originals and all non-identical copies whether different from the original by reason of any notation made on such copy or otherwise including but not limited to correspondence memoranda notes messages letters purchase orders telegrams teletype telefax bulletins e-mails electronic data meetings reports or other communications interoffice and intra-office telephone calls diaries chronological data minutes books reports charts ledgers invoices worksheets receipts returns trade information regarding fabric carpets samples etc computer printouts prospectuses financial statements schedules affidavits contracts cancelled checks transcripts statistics surveys magazine or newspaper articles releases and any and all drafts alterations and modifications changes and amendments of any of the foregoing graphs or aural records or representations of any kind including without limitation photographs charts graphs microfiche microfilm video tape recordings motion pictures and electronic mechanical or electric recordings or representations of any kind including without limitation tapes cassettes discs and recordings and including the file and file cover The term Document also means any and all computer records data files directories electronic mail and information of whatever kind whether printed out or stored on or retrievable from floppy diskette compact diskette magnetic tape optical or magnetic-optical disk computer memory hard drive zip drive jaz drive orb drive microdisk external memory stick software or any other fixed or removable storage media including without limitation all back-up copies Case Document Entered on FLSD Docket Page of 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 L.M Jeffrey Epstein Palm Beach County Case E.W E.W Jeffrey Epstein Palm Beach County Case Jane Doe/S.R Jane Doe Jeffrey Epstein United States District Court Case 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 REQUESTED ITEMS For the time period from January to present any and all documents reflecting communication 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 RRA and/or its clients or the financing of any litigation between Jeffrey Epstein and RRA and/or its clients including but not limited to a Representations that litigation with Jeffrey Epstein has been settled Soliciting or receiving money in return for settlement funds alleged paid or to be paid on behalf of 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 Case Document Entered on FLSD Docket Page of Communication between third party investors or potential investors and the plaintiffs or their attorneys involved in litigation against Jeffrey Epstein Payments made by RRA to or on behalf of any plaintiff Any and all fee agreements that exist or have existed between the following a Any Plaintiff and Bradley Edwards or any entity with which he was associated Any Plaintiff and the law firm RRA All documents reflecting the sale purchase or investment by any person or entity company corporation LLC etc in the prospective settlement or resolution of any plaintiffs case against Jeffrey Epstein All emails data correspondence memos or similar documents exchanged between Bradley Edwards and Scott Rothstein and/or any attorney or representative of RRA and any investor or third party person or entity in any plaintiffs case where the investor provided financing to include money and/or any other consideration to Bradley Edwards any plaintiff or RRA with regard to the settlement or potential settlement of any plaintiffs case against Jeffrey Epstein All agreements or documents of any nature which were entered into by an investor relating to any plaintiffs case with 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 investment packages information settlement agreements and any other documents made available to any investor by Bradley Edwards RRA Scott Rothstein or any of Scott Rothsteins entity to solicit investors for or in any plaintiffs case The names and addresses of all individuals or entities who invested in any aspect of any plaintiffs case against Jeffrey Epstein All assignments or agreements between any investor person or entity and any plaintiff and/or her attorneys regarding any plaintiffs case cause of action against Jeffrey Epstein Case Document Entered on FLSD Docket Page of All documents evidencing payment of any bill or costs in each plaintiffs case against Jeffrey Epstein and the source for said payments of any costs All press releases tapes of interviews transcripts of interviews generated by Bradley Edwards or any existing or former RRA attorney regarding any plaintiffs case against Jeffrey Epstein Case Document Entered on FLSD Docket Page of LM Plaintiff JEFFREY EPSTEIN Defendant IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO XMB AD SUBPOENA DUCES TECUM FOR DEPOSITION THE STATE OF FLORIDA TO Bradley Edwards Esq NE nd Street Hallendale Beach FL or Rothstein Rosenfeldt Adler PA NE nd Street Hallendale Beach FL YOU ARE COMMANDED to appear at Prose Court Reporting NE rd Avenue Suite Ft Lauderdale FL on November a.m bring with you the following See attached Exhibit A If you fail to appear you may be in contempt of court You are subpoenaed by the attorney whose name appears on this subpoena and unless excused from this subpoena by the attorney or the Court you shall respond to this subpoena as directed DA TED this th day of November ROBERT Attorneys Defendant Jeffrey Epstein Burman Critton Luttier Coleman Flagler Drive Suite West Palm Beach FL ROBERT CRITTON JR ESQ For the ourt Case Document Entered on FLSD Docket Page of EXHIBIT A DEFINITIONS AND INSTRUCTIONS A Document means any written or graphic matter or other means of preserving thought or expression and all tangible things from which information can be processed or transcribed including the originals and all non-identical copies whether different from the original by reason of any notation made on such copy or otherwise including but not limited to correspondence memoranda notes messages letters purchase orders telegrams teletype telefax bulletins e-mails electronic data meetings reports or other communications interoffice and intra-office telephone calls diaries chronological data minutes books reports charts ledgers invoices worksheets receipts returns trade information regarding fabric carpets samples etc computer printouts prospectuses financial statements schedules affidavits contracts cancelled checks transcripts statistics surveys magazine or newspaper articles releases and any and all drafts alterations and modifications changes and amendments of any of the foregoing graphs or aural records or representations of any kind including without limitation photographs charts graphs microfiche microfilm video tape recordings motion pictures and electronic mechanical or electric recordings or representations of any kind including without limitation tapes cassettes discs and recordings and including the file and file cover The term Document also means any and all computer records data files directories electronic mail and information of whatever kind whether printed out or stored on or retrievable from floppy diskette compact diskette magnetic tape optical or magnetic-optical disk computer memory hard drive zip drive jaz drive orb drive microdisk external memory stick software or any other fixed or removable storage media including without limitation all back-up copies Case Document Entered on FLSD Docket Page of 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 L.M Jeffrey Epstein Palm Beach County Case E.W E.W Jeffrey Epstein Palm Beach County Case Jane Doe/S.R 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 REQUESTED ITEMS For the time period from January to present any and all documents reflecting communication between or on behalf ofRRA its employees or agents or clients and any third party regarding a purported settlement of any litigation between Jeffrey Epstein and RRA and/or its clients or the financing of any litigation between Jeffrey Epstein and RRA and/or its clients including but not limited to a Representations that litigation with Jeffrey Epstein has been settled Soliciting or receiving money in return for settlement funds alleged paid or to be paid on behalf of 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 Case Document Entered on FLSD Docket Page of Communication between third party investors or potential investors and the plaintiffs or their attorneys involved in litigation against Jeffrey Epstein Payments made by RRA to or on behalf of any plaintiff Any and all fee agreements that exist or have existed between the following a Any Plaintiff and Bradley Edwards or any entity with which he was associated Any Plaintiff and the law firm RRA All documents reflecting the sale purchase or investment by any person or entity company corporation LLC etc in the prospective settlement or resolution of any plaintiffs case against Jeffrey Epstein All emails data correspondence memos or similar documents exchanged between Bradley Edwards and Scott Rothstein and/or any attorney or representative of RRA and any investor or third party person or entity in any plaintiffs case where the investor provided financing to include money and/or any other consideration to Bradley Edwards any plaintiff or RRA with regard to the settlement or potential settlement of any plaintiffs case against Jeffrey Epstein All agreements or documents of any nature which were entered into by an investor relating to any plaintiffs case with 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 investment packages information settlement agreements and any other documents made available to any investor by Bradley Edwards RRA Scott Rothstein or any of Scott Rothsteins entity to solicit investors for or in any plaintiffs case The names and addresses of all individuals or entities who invested in any aspect of any plaintiffs case against Jeffrey Epstein All assignments or agreements between any investor person or entity and any plaintiff and/or her attorneys regarding any plaintiffs case cause of action against Jeffrey Epstein Case Document Entered on FLSD Docket Page of All documents evidencing payment of any bill or costs in each plaintiffs case against Jeffrey Epstein and the source for said payments of any costs All press releases tapes of interviews transcripts of interviews generated by Bradley Edwards or any existing or former RRA attorney regarding any plaintiffs case against Jeffrey Epstein Case Document Entered on FLSD Docket Page of UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV-80119-MARRA/JOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant I Related cases I ORDER ON DEFENDANT EPSTEINS MOTION FOR ORDER FOR THE PRESERVATION OF EVIDENCE This matter came before the Court on Defendant JEFFREY EPSTEINs Motion for Order for the Preservation of Evidence Incorporated Memorandum of Law dated November It is HEREBY ORDERED and ADJUDGED that Defendants motion is GRANTED Accordingly Bradley Edwards Stuart Rosenfeldt as a partner/shareholder in RRA and Receiver of RRA and Herbert Stettin as Court Appointed Receiver for RRA are HEREBY ordered and directed to immediately preserve and neither tamper with or alter the items of evidence identified in the Subpoenas Duces Tecum For Deposition directed to them and attached as Composite Exhibit A to Defendants motion and also identified below herein absent further order of this Court EXHIBIT Case Document Entered on FLSD Docket Page of Jane Doe No.2 Epstein Case No Order on Epsteins Emergency Motion for Order for the Preservation of Evidence Page of For the time period from January to present any and all documents reflecting communication 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 RRA and/or its clients or the financing of any litigation between Jeffrey Epstein and RRA and/or its clients including but not limited to a Representations that litigation with Jeffrey Epstein has been settled Soliciting or receiving money in return for settlement funds alleged paid or to be paid on behalf of Jeffrey Epstein Soliciting money to help finance ongoing litigation against Jeffrey Epstein Soliciting money to be given to or used on behalf of the plaintiffs in litigation against Jeffrey Epstein Communication between third party investors or potential investors and the plaintiffs or their attorneys involved in litigation against Jeffrey Epstein Payments made by RRA to or on behalf of any plaintiff Any and all fee agreements that exist or have existed between the following a Any Plaintiff and Bradley Edwards or any entity with which he was associated Any Plaintiff and the law firm RRA All documents reflecting the sale purchase or investment by any person or entity company corporation LLC etc in the prospective settlement or resolution of any plaintiffs case against Jeffrey Epstein All emails data correspondence memos or similar documents exchanged between Bradley Edwards and Scott Rothstein and/or any attorney or representative of RRA and any investor or third party person or entity in any plaintiffs case where the investor provided financing to include money and/or any other consideration to Bradley Edwards any plaintiff or RRA with regard to the settlement or potential settlement of any plaintiffs case against Jeffrey Epstein Case Document Entered on FLSD Docket Page of Jane Doe No.2 Epstein Case No Order on Epsteins Emergency Motion for Order for the Preservation of Evidence Page of4 All agreements or documents of any nature which were entered into by an investor relating to any plaintiffs case with 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 investment packages information settlement agreements and any other documents made available to any investor by Bradley Edwards RRA Scott Rothstein or any of Scott Rothsteins entity to solicit investors for or in any plaintiffs case The names and addresses of all individuals or entities who invested in any aspect of any plaintiffs case against Jeffrey Epstein All assignments or agreements between any investor person or entity and any plaintiff and/or her attorneys regarding any plaintiffs case cause of action against Jeffrey Epstein All documents evidencing payment of any bill or costs in each plaintiffs case against Jeffrey Epstein and the source for said payments of any costs All press releases tapes of interviews transcripts of interviews generated by Bradley Edwards or any existing or former RRA attorney regarding any plaintiffs case against Jeffrey Epstein and All investigator RRA employed and third parties billing and invoice records reflecting services rendered/performed relating to any case involving Jeffrey Epstein DONE and ORDERED this __ day of November Case Document Entered on FLSD Docket Page of Jane Doe No.2 Epstein Case No Order on Epsteins Emergency Motion for Order for the Preservation of Evidence Page of Courtesy copies The Honorable Kenneth A Marra Counsel of Record Kendall Coffey Esq Coffey Burlington Office in the Grove Penthouse South Bayshore Drive Miami FL Paul Singerman Esq Berger Singerman South Biscayne Blvd Suite Miami FL Linnea Johnson United States Magistrate Judge
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