Electronically Filed AM Bnullcy From Michele Dargan Sent Jul To Bradley Edwards Cc Bee Subject Re Epstein Brad We have no way of getting the members or the banned members lists However I spoke to Donald Trump today nothing like getting it from the horses mouth Anyway he said Epstein is not a member and would not confirm or deny that he ever was a member He would not comment at all which is very rare for him on whether or not Epstein got booted from the club or if he had recruited girls from Mar-A-Lago Sorry I couldnt be more help I really thought that he would say something He usually does comment for all of our stories Thats why this was quite unusual If you get any info please pass it on like if any info comes out during depos of anything related to Epstein getting booted from the club or about him recruiting girls from there You know I will run with it Michele On AM Bradley Edwards wrote Hi Michele I was wondering if you were able to get a members list at the Maralago and even more importantly if you were able to get a list of banned members from the Maralago Rumor has it that he was banned for having sex with and attempting to have sex with minors at the club and we already know of certain minors that he took from the club to his house I will take a deposition of someone there if we need to do that to get the true information on this but there are so many depositions to take in this case and we are setting them right now around the country that I would like to avoid this one ifwe could get the info another way Thanks Bradley Edwards Partner file:I//Cj/Doc:uments 20ond 20Set1ing.,ffriol/Dask1opE on/eOocs/eMeil/Bradley _l!dwanlsOl 70l2"eMoi1ContcnLhlm I of2 IO I PMJ I Bradley_ EdwnrdsOl 7032"cMoilContcnt.htm Rothstein Rosenfeldt Adler Attorneys at Law Las Olas City Centre East Las Olas Boulevard Suite Fort Lauderdale FL facsimile bedwards rra-law.com Michele Dargan staff writer Palm Beach Daily News phone fax lilc://,qt ocum1:11tno20ond 20Settings/TrinlJDeskto on/cDoc1h:Mail/Orodlq _EdwordsO I 7D32"eMailContent.hlm or I PM I I i i Bradley _EtlwardsO 17129-cMailCoolent.hlm From Michele Dargan Sent Jul To Bradley Edwards Cc Bee Subject Re Epstein Brad I didnt get your e-mail until I got in this morning Friday so it was too late you did mean it took place this morning right Anything interesting On PM Bradley Edwards wrote Michele I forgot to tell you that I have a hearing in Hafeles courtroom lB I think at on our motion to add punitive damages Should be some interesting things said for you Things that have not been said before Bradley Edwards Partner Rothstein Rosenfeldt Adler Attorneys at Law Las Olas City Centre East Las Olas Boulevard Suite Fort Lauderdale FL facsimile bedwards rra-law.com From Michele Dargan mailto:mdargan pbdaiJynews.com Sent Wednesday July I PM To Bradley Edwards Subject Re Epstein _Brad We have no way of getting the members or the banned members lists nle-J//CVl ocumenuo/o20und 20Sct1inpfTrinl/OcskloJYE onler acslcMail/8radlcy_F..dlWfflsO 17129"oMailConlel11.htm I of IO:S4 PM Ouullcy _EdwardsOI 7129"1:MailCulel.hlm However spoke to Donald Trump today nothing like getting it from the horses mouth Anyway he said Epstein is not a member and would not confim1 or deny that he ever was a member He would not comment at all which is very rare for him on whether or not Epstein got booted from the club or if he had recruited girls from Mar-A-Lago Sorry I couldnt be more help I really thought that he would say something He usually does comment for all of our stories Thats why this was quite unusual If you get any info please pass it on like if any info comes out during depos of anything related to Epstein getting booted from the club or about him recruiting girls from there You know I will run with it Michele On AM Bradley Edwards wrote Hi Michele I was wondering if you were able to get a members list at the Maralago and even more importantly if you were able to get a list of banned members from the Maralago Rumor has it that he was banned for having sex with and attempting to have sex with minors at the club and we already know of certain minors that he took from the club to bis house I will take a deposition of someone there if we need to do that to get the true infonnation on this but there are so many depositions to take in this case and we are setting them right now around the country that I would like to avoid this one ifwe could get the info another way Thanks Bradley Edwards Partner Rothstein Rosenfeldt Adletj Attorneys at Law Las Olas City Centre East Las OJas Boulevard Suite Fort Lauderdale FL facsimile bedwards rra-law.com lilc:II/Cj/Documanta 2lnd 20Sc:nillg3flrlalf0csl-10plB on/cDocsleMmil/8rodlcy _l:dwonlsO l7129"eMailContcnl htm of I l/61ZOIO IO:S4 eMJ I I l:n,,ilq fulwarcbOl 7129"cMailC01cnl.hl1 Michele Dargan staff writer Palm Beach Daily News phone fax lile:/CJ Docunien al420Dnd 20Scll inp/f rial/Deaklup.e on/COocsleMa iVOrad 1ey _EdwardsO I 29"1:M11ilCon1ent.hlm orJ I I IO I I PM I I I Brudlr:y From Bradley Edwards Sent Jul To Michele Dargan Cc Bee Subject RE Epstein Thank you We have our answer then All the pieces are public record Complaint filed by Josephsberg regarding Epstein being at the club with Ghislaine Maxwell and taking a year old home with him a newspaper article that indicated he was banned for similar conduct dont remember who published it but read it a few months back and a no comment from Trump Hes banned Dont worry we will get the official word We are setting many depositions soon and certain people that will be set will know that information I will keep you informed Good work Ill be in touch Bradley Edwards Partner Rothstein Rosenfeldt Adler Attorneys at Law Las Olas City Centre East Las Olas Boulevard Suite Fort Lauderdale FL facsimile bedwards rra-law.com Frnm Michele Dargan mailto:mdargan pbdailynews.comJ Sent Wednesday July PM To Bradley Edwards Subject Re Epstein Brad filc://fCI/Doa1mct ls 20Sc11ings Trial/Dakt on/cOocs/eMail/Bradley _EdwardS020726 IMai1Conlw.hlm I or I IMOI JO PM I I I I Bmdlcy _Edwords020n6"cMailC01cn1.htm We have no way of getting the members or the banned members lists However I spoke to Donald Trmhp today nothing like getting it from the horses mouth Anyway he said Epstein is not a men ber and would not confinn or deny that he ever was a member He woutd;_ ot comment atal_l which is very rare for him oil whether or not Epstein got booted from the club or ifhe had recruited girls frorilMar-A-Lago Sorry couldnt _be more help I lly tho 1ght that he would say something He usually does comment for all of our stories Thats why this was quite unusual If you get any in pl sit on Jike if any info comes out during depos of anything related to Epstein getting booted from the club or abo hi1 recruiting girls from there You kriow I will run with itl Michele On BradleyJ Edwards wrote Hi Michele I was wonder if you ere able to get a members list at the Maralago and even more importan if yoll ere le tc,:get list fbanned n1embers from the Maralago in1 has it that he was banned for having sex vith,and attempting to have sex with minors at the club and we already now of certain minors that.he took from the club to his house I wil,l take a deposition of someone there ifwe need.to do that to get the triie information on this but the are so many.depositions to.fake in this case and we are setting them right now around the country that iwould like to avoid this one ifwe could get the info another way Thanks Bradley Edwards Partner Rothstein Rosenfeldt Adler Attorneys at Law Las Olas City Centre East Las Olas Boulevard Suite Fort Lauderdale FL facsimiJe bedwards rra-Jaw.com r.J CVoocwncnis 20lind 20Scllinp/Trial/Dt:sktoplE onleDocs/eMail/Bnidley Echwrds020 Mlli1Contanl him ofl IO I PM I i i I i __ Michele Dargan staff writer Palm Beach Daily News phone fax Olc:/I/CJII ocurnenll of I JO PM I i UrJ-Jloy_ lwurds0207l2 Moi1Cantenlhlm From Bradley I Edwards Sent Jul To Michele Dargan Cc Bee Subject RE Epstein Michele I forgot to tell you that have a hearing in Hafeles courtroom I think at on our motion to add punitive damages Should be some interesting things said for you Things that have not been said before Bradley Edwards Partner Rothstein Rosenfeldt Adlerf Attorneys at Law Las Olas City Centre East Las Olas Boulevard Suite Fort Lauderdale FL facsimile bedwards rra-law.com From Michele Dargan mailto:mdargan pbdailynews.com Sent Wednesday July PM To Bradley Edwards Subject Re Epstein Brad We have no way of getting the members or the baoned members lists However I spoke to Donald Trump today nothing like getting it from the horses mouth lile:/C Documcn 20and 20S"1ingsffriaVDcsktop,1l I of I PMl Brodloy _Ed wards0207l2"eMoilC01c11t.hhn Anyway he said Epstein is not a member and would not confirm or deny that he ever was a member He would not comment at all which is very rare for him on whether or not Epstein got booted from the club or if he had recruited girls from Mar-A-Lago Sorry I couldnt be more help I really thought that he would say something He usually does comment for all of our stories Thats why this was quite unusual If you get any info please pass it on like if any info comes out during depos of anything related to Epstein getting booted from the club or about him recruiting girls from there You know I will run with itl Michele On AM Bradley Edwards wrote Hi Michele I was wondering if you were able to get a members list at the Maralago and even more importantly if you were able to get a list of banned members from the Maralago Rumor has it that he was banned for having sex with and attempting to have sex with minors at the club and we already know of certain minors that he took from the club to his house I will take a deposition of someone there if we need to do that to get the true information on this but there are so many depositions to take in this case and we are setting them right now around the country that I would like to avoid this one ifwe could get the info another way Thanks Bradley Edwards Partner Rothstein Rosenfeldt Adlerf Attorneys at Law Las Olas City Centre East Las O1as Boulevard Suite Fort Lauderdale FL facsimile bedwards rra-law.com Michele Dargan staff writer lile:I/ICJll ocument 20and 20Seuins,,1Trial1Dcslc1op/E 011/c0oc:skM1il/Bradley _Edwards020732"aMoilC01cnLhlm of PM i I I I Palm Beach Daily News phone fax lileJ//CVDoeul!ICIICS 20mld 20ScUinp/Triul/Ocsl.lOplE orl I PM UNCTED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV-80119-MARRNJOHNSON JANE DOE NO Plaintiff vs JEFFREY EPSTEIN Defendant Related ases I ORDER This cause is before the Court upon Plaintiff Jane Does Motion for Injunction Restraining Fraudulent Transfer of Assets Appointment ofa Receiver to Take Charge of Property of Epstein und to Post a Million Bond to Secure Potential Judgment DE Defendant Jeffrey EpsteinJiled.a response in opposition to the m_otion DE and Plaintiff filed a reply DE The motion is now fully briefed and ripe for review __ Plaintiffs motion argues that Defendant is fraudulentlytransfening his assets with the specific intent to defeat anyjudgment that might be entered against him in this and other similar cases Pia.inti ff therefore seeks an order enjoining Defendant from fraudulent transfers of his assets appointing a receiver to take charge of Defendants property and requiring Defendant to post a million dollar bond against any potential judgment in this case EXHIBITU I i."l The reliefsought by Plaintiff is injunctive and essentially,amounts to a prejudgment writ of attachment Rosen Cascade Intern Inc F.3d vacating district courts preliminary injunction freezing defendants assets No relief of this.character has been thought justified in the long history of equity jurisprudence De Beers Consol Mines Ltd United States Preliminary injunctive relieffreezing a defendants assets in order to establish a fund with which to satisfy a_ potential judgment for money damages is simply not an appropriate exercise of a federal district courts authority Rosen F.3d at Indeed it is entirely settled by a long and unbroken line of Florida cases that in an action at law for moneydamages there is simply no judicial authority for an order requiring the deposit of the amount in controversy into the registry of the court or indeed for any restr_aint upon the use of a defendants unrestricted assets prior to the entry of judgment Id at quoting Konover Realty Assoc Ltd Mladen So.2d Fla 3d DCA In Florida an injunction cannot be entered to prevent a party from using or dispo ing of his assets prior to the conclusion of a legal action Briceno Bryden Investments Ltd So.2d Fla 3d See also SME Racks Inc Sistemas Mecanicos Para Electronica S.A Fed.Appx lh Cir affinning districts courts denial of preliminary injunction to freeze 267defendants assets Proctor Eason,651 So.2d Fla 2d DCA Defendant not required to deposit funds in court registry prior to final judgment where Plaintiff failed to show unavailability of an adequate remedy at law and the likelihood of irreparable harm two elements essential to entry of an injunction Lawhon Mason So.2d Fla 2d DCA quashing trial court order requiring defendant to give plaintiffs ten days notice prior to the transfer of any assets in.excess of Additionally as the Eleventh Circuit explained in Rosen In actions at law plaintiffs in Flqrida possess an adequate exclusive prejudgment remedy for the sequestration of assets under the attachment statute Fla.Stat.Aim West providecI 260that they can satisfy the.enumerated statutory 267grounds for relief Accordingly,Jhe use of injunctive relief as a slibstjtute for the remedy of prejudgment attachme.nt with its attendan siifeguards is improper F.3d at emphasis added Here Plaintiff did not move to am.end her complaint to allege a claim under the Florida Uniform Fraudulent Transfers Act FUFTA Fla Stat IOI et seg Rather she filed the present motion for injunctive relief Even if she had moved to amend her complaint it is certainly not clear that she could meet the required statutory elements Plaintiffs motion is premised on the contention that Defendant is frauduleQtly transferring his assets However Plaintiffs motion is entirely devoid of evidence of Defendants alleged fraudulent transfers The Court declines to conclude that Defendant is fraudulently transferring assets based upon the adverse inferences relied upon by Plaintiff Plaintiffs supplemental filing regarding the titles of approximately five of Defendants vehicles is clearly de minimis particularly in light of Plaintiffs repeated characterization of Defendant as a billionaire Based upon the foregoing it is hereby ORDERED AND ADJUDGED that Fraudulent transfer claims under Florida law arise under the Florida Uniform Fraudulent Transfers Act FUFTA Fla.Stat et seq FUFTA as setforth inFlorida Statute provides the substantive requirements that must be pied to state a valid fi:a dulent transfer claim Nationsbank N.A Coastal Utilities Inc So.2d Fla Dist Ct App The plaintiff must show that I there was a creditor to be defrauded a debtor intending fraud and a conveyance of property which could have been applicable to the payment of the debt due Id i I _J _r Plaintiff Jane Does Motion for leave to Provide Recently obtained Deposition Testimony and Affidavit DE in is GRANTED Plaintiff Jane Does Motion for lnj nction Restraining Fraudulent Transfer of Assets App intment ofa Receiver to Take Charge of Property of Epstein and to Post a Million Bond to Secure Potential Judgment DE in is DENIED DONE AND ORDERED in Chambers at West Palm Beach Palm Beach County Florida this 5h day of November Copies to all counsel of record cara HAimes Qmdley fmmk Slrat gy Wednesday July PM I think our best bet is liJ go after those dose Ix Epstein EXHIBITV i _l IN THE CIRCUIT COURT OF THE 17TH JUDICIAL CIRCUIT IN AND EOR BROWARD COUNTY FLORIDA CASE NO RAZORBACK FUNDING LLC et al Plaintiffs vs SCOTT ROTHSTEIN et al Defendants DAY AFTERNOON SESSION DEPOSITION OF SCOTT ROTHSTEIN DATE TAKEN Monday December p.m TIME PLACE N.E Fourth it eet Miami FL Taken on Behalf of Razorback Examination of the witness taken before Terri Wright United Reporting Inc Southeast Third Avenue Fort Lauderdale Florida United Reporting Inc EXHlBITW Page Page funds that were supposed to be held in trust A It was simply what Frank and I had the whole reason it stayed in Mr Preve and I discussed from time to time the fact that anything we could do to add additional levels of security for the investors was good So it stayed in the package unless someone said they didnt want it Now the Epstein settlements were used by you based on actual cases with Jeffrey Epstein A Yes on that Palm Beach person A Yes Do you recall that A Yes And do you recall that my clients were investors who invested in that I do That would be Discala and Von Allmen and other people of the Razorback group A I do Do you recall when they came to your office and you brought down boxes for Michael Legamaro to review A The boxes were actually already in my office Well theres some testimony that you called and asked Ken Jenne and Fistas to bring them down and they United Reporting Inc Page brought down boxes for you at a show as to show these are the real cases A I believe that a substantial number of the boxes were already in my office And there were additional boxes and I did have people bring them to me I dont remember who brought them to me but yes And do you recall Mr Legamaro what he did with respect to his review of those boxes of th oases A I recall bringing the boxes in the only real recollection I have of that meeting was after meeting with them and bringing the boxes in I walked out for a period of time let them go through the boxes came back in answered questions that they had and we went forward You pulled out some kind of a flight manifest do you recall that A Yeah At some point in time I believe it was either Brad Edwards or Russ Adler pointed out to me that one of the pieces of evidence they were using in the actual case was 267the flight manifest And I actually used that to make a fairly big show I found that those most of the time in these cases the more significant our underlying investigation was and the more tantalizing it was the more interested the investors got We had that real piece of eviden and we used it to our advantage to attempt to secure the investor United Reponing Inc manifest A A Page Did Russ help you maJce it more tantalizing that Did he help me Did he help you make it more tantalizing The only way Russ would have helped me make it more tantalizing was by just discussing the size of the case But other than that no he didnt do anything that I recall during that meeting with regard to the actual manifest I did Didnt you add some sensational names to the manifest that werent there to start with A A I did I did Tell us about that There were I said that there were additional manifests if I remember correctly I said there were additional manifests that we had discovered containing Bill Clintons name Prince Andrew all being shown flying with young girls on the plane And do you know whether let me back up lh.e original manifests that were in evidence in the real case didnt.have those names on it A No but its interesting you bring that up because the way I came up with Bill Clinton and Prince Andrew was Mr Adler and Mr Edwards both told me on different occasions that the reason the case when we United Reporting Inc IJ I I I i Page were discussing the actual real case the reason it was becoming so quote unquote tasty because they had information that he had been flying Bill Clintonaround and Prince Andrews around the piece that was missing from the real case was the connection to the young girls The young girls connection to the young girls was fiction it was a lie A Not as far as Mr Epstein is concerned but as far as the other people are concerned yes Do you know whether Ad.1er Mr Adler or Mr Edwards injected any of that into the depositions in the real case in order to assist with the Ponzi A I dont know No no I dont know whether they did that or not I wouldnt think they would When you were asked this morning about Brad Edwards you really hesitated I dont know if you know you did that You were answering yea no maybe so on him you really paused A On the question as whether or not he would have turned us in you mean Whether he was a player or whether he was involved and you didnt quite answer A Just because of the way I knew Brad and socialized with him I did not know that he was at that level There are certain people Barry Stone second he United Reporting Inc i I Page found out about it would have absolutely done what was appropriately supposed to do from an ethical standpoint And then there were people who I would say would never do that And then there are people in_ the middle I believe Brad Edwards is probably in the middle Di.d you have your investigators that be Jenne and Wayne Black and fistas investigate Epstein aif and try to get evidence from Epstein A I didnt know do you have of any knowledge of that A No sir Did you instruct them to file any kind of pleadings in federal court anything like that in order to help you promote the Ponzi A No As far as the Epstein case is concerned Mr Scherer I never asked Mr Adler or Mr Edwards at anyone else associated with that case to do anything for the purpose of furthering the Ponzi other than bring me the boxes That was all my creation Thank you Im going to talk to you about Ted Morse a little bit You said he was one of your best friends he was one of your interci.rcle A Correct United Reporting Inc A A 4A E0 A4 DE a qr?q rq qrCX HhL Kg lg d?a d6U a M3 flW y??S m/y t0 I F/Z V/j 1a qC KS u?v vZ O5 a qr rCX qC 0V I I dc rM?M rM 10Cy n??m?n k?o?h I A I w?!ac qr MCX 10Cy ITy qr M3 Ґ??1rA5R h?H?T3P K?z X?K H?o I Idc rM?M rM 10Cy f헊?f?Tz e?e:Aa I v"x i X5 EO5 5a r?q CX 9r Cy 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