Case Document Entered on FLSD Docket Page of On November The Honorable Jeffrey Streitfeld presiding over the Receivership Action a removed Rothstein as the Chief Executive Officer and appointed Stettin as the Receiver for RRA Promptly thereafter Stettin assumed stewardship of RRA and since then has handled a very broad set of problems virtually of which have been on an emergency basis including this matter On November Rosenfeldt as the sole officer and director of RRA executed a resolution appointing Stettin as the CRO of RRA and delegated to Stettin all operational and managerial control over RRA This effectively removed Rosenfeldt from all managerial roles at RRA and Stettin as CRO is now the only executive of RRA As it pertains to this matter since his appointment in accordance with his duties as Receiver and as CRO Stettin has moved quickly and carefully to secure all assets and records of RRA In the midst of doing so however the Department of Justice executed search warrants on the offices of RRA removing among things in excess of forty boxes of documents It is believed the Department of Justice also sequestered about thirteen boxes of documents related to this case This action occurred before Stettin could complete his inventory and accounting of the vastly disorganized office and record keeping systems of RRA Stettin assures both the Defendant as well as this Court that he understands fully e-ogravity of document and __ has_and_intends_to continue to fully comply with his fiduciary duties both as Receiver and now as CRO of an alleged bankruptcy debtor In fact security at the firms computer system and its documents is one of his foremost present concerns and tasks The Bankruptcy Code U.S.C et seq requires that a debtor in possession behave and function with the same types of responsibilities as a trustee U.S.C Case Document Entered on FLSD Docket Page of RRA is currently an alleged debtor in possession and Stettin is executing on the fiduciary duties that are imposed upon him as the executive of RRA In light of the foregoing Stettin has no objection to the entry of an order that is consistent with his fiduciary obligations Notwithstanding to the extent the Defendant wishes for Stettin to produce documents or sit for a deposition on November Stettin respectfully requests that this Court extend that date for at least days so that he may attend to the continuing critical pressing needs of stabilizing RRA and resolving the outstanding issues that occur when a law firm of employees suddenly implodes overnight WHEREFORE Herbert Stettin respectfully requests that any order entered conform with his statutorily imposed duties any deposition of Stettin be postponed for at least days and granting such other relief as the Court deems just and proper Dated November Respectfully submitted BERGER SINGERMAN P.A Proposed Attorneys for Alleged Debtor East Broward Boulevard th Floor Telephone Facsimile By Charles Lichtman Charles Lichtman clichtman bergersingerman.com Direct Dial lorida_BarNo Isaac Marcushamer imarcushamer bergersingerman.com Florida Bar No Case Document Entered on FLSD Docket 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 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 Fax Garcia Law Firm P.A Counsel for Plaintiff in Related Case No Datura Street Suite West Palm Beach FL reelrhw hotmail.com Jack Scarola Esq isidrogarcia beffsouth.net Jack Hill Esq Counsel for Plaintiff in Related Case No Searcy Denney Scarola Barnhart Shipley P.A 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 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 Robert Cr 261ton Jr Esq Michael ike Esq 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 Burman Critton Luttier Coleman BaNYAN Boulevard Suite West Palm Beach Florida Tel Fax Counsel for Defendant Jeffrey Epstein
5,078 characters
