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U0 U0 UF UF UFAGA UA UA UAL UL UL UL UL UL UL U7 U7 U7 U7 U7 U7 U7 2EH GTU U/U OUoU UV G1 CTX TUV 1G 7A UA UAL X7 U7 U7 U77XL UL UL ULLYX KTX 8Y GJ A UMAT UD 7M GVW GF10 MWA LL MPM M?M 4M XY qr qr qr NEeD 10Cy qYY E2 GH l1 Pd h3V g?KIq V5kL O65S d_xKKU vV 5H p1 Z6 CTX U0 U1 CTX U0 U1 A0 1D qr qr 10Cy YY K??Kl 1B AMwv 1K F1 KV yW Gd T?H CTX CTX I CK M?qr K?SK?PQZ I IRZX 8YCX 10Cy qr CX kv zg S5kB??a iG wA CTX U2 6Y CTX U2 6Y I K,,j j,s 6Y P!p qr 10Cy qr YY G?O 9K mSd X0 9r?yal 1d bY0 XNf??qN D?J 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 Epstein Rothstein et al WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via electronic service through the e-file portal to all parties on the attached service list this October Tonja Haddad Coleman Tonja Haddad Coleman Esq Florida Bar No Tonja Haddad PA SE Street Suite Fort Lauderdale Florida facsimile Attorneys for Epstein SERVICE LIST CASE NO Jack Scarola Esq jsx searcylaw.com mep searcylaw.com Searcy Denney Scarola et al Palm Beach Lakes Blvd West Palm Beach FL Jack Goldberger Esq jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss PA Australian Ave South Suite West Palm Beach FL Marc Nurik Esq East Broward Blvd Suite Fort Lauderdale FL Bradley Edwards Esq brad pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehnnan Andrews Avenue Suite Fort Lauderdale Florida Fred Haddad Esq Dee FredHaddadLaw.com Financial Plaza Suite Fort Lauderdale FL Chester Brewer Jr Esq wcblaw a ao I com wcbcg aol.com Chester Brewer Jr P.A One Clearlake Centre Suite Australian Avenue South West Palm Beach FL cant Epstein Rothstein et al Tonja Haddad Coleman Esquire Tonja tonjahaddad.com efiling tonjahaddad.com Law Offices of Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Attorneys for Jeffrey Epstein Epstein Rothstein et al Summary Form THE FLORIDA BAR Daily News Summary An electronic digest of media coverage of interest to leaders of The Florida Bar compiled each workday by the Public Information and Bar Services Department Distributed to Board of Governors section and committee chairs staff members Florida Supreme Court justices and selected other persons For fax/photocopies of full-text articles contact the Public Information Bar Services Department at or e-mail pubinfo tlabar.org Please visit our Web site for links to full text of articles Nov Legal Profession ON HER TOES Florida Trend http://w.floridatrend.com Nov Pagel of Not only is Pamela Marsh the first woman to be appointed U.S Attorney for Floridas Northern District shes also the districts first U.S Attorney whos a former ballerina Marsh says shes honored that President Barack Obama picked her to lead the U.S Attorneys Northern District office but she says being a woman has less impact on her approach to her job than her ballet experience Dancing professionally for ballet companies in Seattle and Fort Worth in the mid she says helped her become a more dogged prosecutor Marsh manages the districts assistant U.S attorneys and helps them focus on the departments priorities including healthcare fraud drug trafficking and Internet crimes against children STAYING ATOP THE PILE Pensacola News Journal/Pensacola Business Journal http://w.pnj.com Oct The mountain of lawsuits piling up as a result of the BP oil spill could become the largest and most expensive collection of tort damage cases in American legal history Billions of dollars in damages are at stake as thousands of individuals and business owners sue BP Transocean and Halliburton Pensacola attorney Brian Barr is one of four lawyers chosen from a national pool by U.S District Judge Carl Barbier to guide the damage suits all consolidated in his court to trial Barrs job as a member of the Plaintiffs Steering Committees four-person executive council will be to coordinate litigation procedures for hundreds of other lawyers representing individual plaintiffs Judiciary JU OGE TURNER PLEASE Summary Form Lawyer Ethics/Legal Discipline SCOTT ROTHSTEIN SCANDAL ONE YEAR LATER Sun-Sentinel http://w.sun sentinel.com Oct Page of Fallout from the largest fraud in South Florida history continues after the dark secret behind Scott Rothsteins success was revealed a year ago this week The Ponzi schemer now sits in prison with limited contact from the outside world While Rothsteins name has been wiped from buildings and billboards the path of financial destruction left in his wake remains With the one year anniversary of the scandal questions still loom The Florida Bar has investigated complaints against RRA attorneys and all but four attorneys have been cleared by the Bar of any wrongdoing Rothstein was disbarred Civil Justice Issues JUDGE IDLE FORECLOSURE SUITS GONE IN HOURS The Bradenton Herald http://w.bradenton.com Oct The foreclosure case was filed in March Within a month all of the parties were served with copies of the suit Then nothing The court case sat idle for the next years seemingly forgotten among the thousands of foreclosures clogging the legal system That was until Thursday when 12th Circuit Court Judge Paul Logan dismissed it for inactivity In the span of hours he threw out foreclosure cases because they had been inactive for at least months The purge was part of an effort to reduce the backlog of open foreclosure cases estimated at in Manatee County alone The target A 62-percent reduction or nearly cases before July JOE FRANCIS NOT THE ISSUE IN THIS CASE Walton Sun/Panama City News Herald column http://w.waltonsun.com Oct The column by News Herald editor Mike Caza las states There is a reason media companies and newspapers particularly fight so hard to protect the rights provided by the First Amendment And whether the proceedings against Girls Gone Wild founder Joe Francis in federal civil court should remain open to the public and the media is a much bigger issue than the case itself Now we have the current case the one that had Freedom Communications First Amendment and public records attorney John Bussian giving oral arguments before the 11th Circuit Court of Appeals in Atlanta last week In that case four women sued Francis saying they were under when they were filmed in various stages of undress They are now in their early-to-mid-20s But as this case moves near trial attorneys for the plaintiffs have become desperate in their attempts to protect the womens identities Freedom Communications fought that under the basic premise that courtrooms are open forums and it is not the governments job to tell the media what to report TOBACCO MISTRIAL SPLIT JURY CANT AGREE ON SMOKERS ADDICTION Daytona Beach News-Journal Oct The case to decide the first of more than local cigarette smokers lawsuits against the tobacco industry ended in a mistrial Friday Oct after a jury deliberated for more than hours but could not break a deadlock Seventh Circuit Judge Robert Rouse Jr told the three men and three women on the jury of Koballa R.J Reynolds Tobacco Co that it was the second time in years a verdict could not be reached in his courtroom Stella Koballa of Daytona Beach smoked for more than years beginning in when she was a teenager Koballas attorneys said she suffered lung cancer and chronic obstructive pulmonary disease as a result of her long addiction to cigarettes Jurors who asked not to be identified said they couldnt agree on the meaning of the word addiction Criminal Justice Issues POST-CONVICTION HEARING FOR TAJ MAHAL OWENS CENTERS ON FAIR TRIAL http nsf/0/a3ftbd43b Summary Form Page of Florida Today http://w.floridatoday.com Oct Three years ago Taj Mahal Owens was sent away to prison for years after a jury found him guilty of attempted second-degree murder and shooting into an occupied motor vehicle In Owens waited at a street corner in Melbourne and then shot into a vehicle occupied by his former girlfriend Anntwinnett Dixon and Edmund Cochrane according to law enforcement authorities On Friday Oct attorneys representing Owens at a post-conviction relief hearing granted by Judge George Maxwell said the two public defenders representing Owens at the time failed to interview two potential alibi witnesses and did not provide Owens proper advice regarding a plea offer The two public defenders Christopher Beres and Terry Locy who no longer work for that office were subpoenaed to appear in court Friday Beres said the state offered Owens a plea deal of years but he advised his client to reject it in part because he believed Cochrane was not going to show up as a witness Cochrane turned up at the trial and testified identifying Owens as the shooter SHERIFF MORGAN WILL LIMIT HIS HELLOS Pensacola News Journal http://w.pnj.com Oct Escambia County Sheriff David Morgan agreed Friday Oct to a judges request to stop greeting jury pools who assemble in the courthouse Monday mornings for jury duty Meanwhile at least two defense attorneys said Friday they are filing motions for retrials for their convicted clients claiming Morgan could have unduly influenced jury members Public Defender James Owens and a group of criminal defense attorneys complained in letters to Chief Judge Terry Terrell on Thursday Oct that Morgans talks with jurors may unfairly sway them to law enforcements side in criminal cases For the past several months Morgan has appeared before citizens summoned to the M.C Blanchard Judicial Building on Monday mornings to thank them for their public service Before that as prospective jurors board a trolley for the ride from a parking lot near the Pensacola Civic Center to the state or federal courthouse Morgan greets them hands them a business card and thanks them for their service Morgan agreed to discontinue his greetings to jury assemblies but Terrell declined to stop Morgan from going to the trolley stop because the parking lot is a public place BABY SHANNONS MOTHER RELEASED AFTER FELONY CHARGE DROPPl;D Northwest Florida Daily News http://w.nwfdailynews.com Oct The case that made national headlines last year when Baby Shannon went missing came to a quiet end Friday for the babys mother as she pleaded no contest to a misdemeanor charge and was released from jail Crystina Mercer who was jailed for providing false information to law enforcement was given credit for time served Shannon Dedrick disappeared from her home Oct The ensuing five-day search for Baby Shannon was the largest operation in the history of the Washington County Sheriffs Office The child was located Nov in a latched wooden box under the bed of her baby sitter Susan Baker Baker was convicted Oct after a weeklong trial on charges of aggravated child abuse interference with custody and providing false information to law enforcement Because the state maintains Baker stole the baby Mercers call after Shannon disappearance was legitimate authorities said Since Baker stole the baby Mercer didnt interfere with custody Other MONEY WOES CAN BE EARLY CLUE OF ALZHEIMERS The Gainesville Sun http://w.gainesville.com Oct The article is by The New York Times One day it all came crashing down The homeowners association called asking for their fees To Mrs Packets surprise her husband had simply stopped paying them Then she learned he had stopped writing checks to his creditors too It turned out that Mr Packel was developing Alzheimers disease and had forgotten how to handle money New research shows that one of the first signs of impending dementia is an inability to understand money and credit contracts and agreements It is not just families who are affected financial advisers and lawyers say they are finding themselves in a bind when their clients minds seem to be slipping For lawyers the main question is at what point a client lacks the nsf/0/a3ffbd43b Summary Form Page of capacity to execute a will or other document and who decides when that point has been reached The Florida Bar Version A year after Rothstein many questions unanswered South Florida Business Journal Page I of From the South Florida Business Journal in html SUBSCRIBER CONTENT Oct EDT A year after Rothstein many questions unanswered Paul Brinkmann Its been a year since South Florida learned that Scott Rothstein was a Ponzi schemer and not just an eccentric flashy attorney Rothsteins victims are just starting to recover Charities still have gaping holes in their budgets and law firms are still pecking over the carcass of his former law firm Rothstein Rosenfeldt Adler in bankruptcy court The Florida Bar found no cause to investigate former RRA attorneys and only three cases remain open Federal authorities moved relatively quickly to indict Rothstein on Dec after a period during which he helped them bring down reputed mafia members However federal prosecutors have only indicted two people related to the scheme Rothstein and his firms COO Debra Villegas Rude awakening Like a fairy tale gone bad Rothsteins rags-to-riches story proved to be an illusion noteworthy even by South Florida standards For four years Rothstein grinned and glad-handed his way onto billboards and society pages He threw money around like candy at a parade He got a former judge an ex-mayor and a felonious former sheriff to work for him But quicker than his meteoric rise Rothstein was suddenly gone one day to Morocco The money was gone too in a billion Ponzi scheme That was Oct He returned to Florida on Nov For a month Rothstein was seen in various spots around town apparently oblivious promising to pay people back The story trickled out about how lurid Rothstein was including allegations of blackmailing in.htrnl print A year after Rothstein many questions unanswered South Florida Business Journal Page of people to invest in his phony lawsuit settlements Finally on Dec Rothstein was handcuffed and charged At the time Daniel Auer IRS special agent in charge promised We will continue to move foiward with this investigation wherever it leads and we will bring to justice those who defrauded the American public and members of our community out of their hard-earned money A year later the government has taken its time in fulfilling that promise Rothstein told the South Florida Sun-Sentinel in November that Fort Lauderdale was a town full of thieves Federal investigation Rothstein was sentenced to years in prison on June Authorities charged Villegas on April she pleaded guilty and was sentenced Oct to years Their sentencing judges U.S District Judges James I Cohn and William Ziech noted that Rothstein and Villegas would have further sentencing reductions if they continue cooperating with authorities John Glies FBI special agent in charge for Miami summed up Villegas crime with these words She chose greed over her integrity Cohn ruled Aug that about victims were entitled to million in restitution although only million to million is available A select list of non-investor clients was made completely whole At the end of October people close to the Rothstein investigations were predicting more arrests were imminent For the first year the government apparently wanted to move slowly said William Scherer an attorney representing investors in a million lawsuit It has seemed like five years worth of news in one year Bankruptcy case Rothsteins law partner Stuart Rosenfeldt tried to put the firm into a state court receivership the day after Halloween But several Rothstein victims soon petitioned for a bankruptcy court filing In bankruptcy court attorneys for trustee Herbert Stettin have sued dozens of people to recover money in civil claims 10/22/rothstein.html print A year after Rothstein many questions unanswered South Florida Business Journal Page of Rothsteins biggest feeder George Levin agreed to settle claims against him by turning in assets valued at up to million Auto dealership owner Ed Morse another Rothstein chum settled for million Stettin and attorneys in the RRA bankruptcy including Miami-based Berger Singerman often clashed with federal authorities over the firms assets Cohn has granted the bankruptcy estate custody of RRAs former bank accounts but federal authorities marshaled other assets including boats and houses Investor lawsuit The Rothstein investor lawsuit could be the largest such lawsuit in Broward County history at pages with more than two dozen plaintiffs and two dozen defendants The big targets are TD Bank and Gibraltar Private Bank Trust banks that handled Rothsteins money but have denied knowing it was dirty The investor lawsuit handled by Scherer is just starting to schedule depositions of key witnesses TD Banks attorneys have sought more time to depose witnesses and ask questions of the plaintiffs So far Judge Jeffrey Streitfeld has declined to put limits on depositions On Oct the federal Office of Thrift Supervision slapped Gibraltar with a cease and desist order for weak money laundering controls The bank has declined to comment on whether the order is related to the Rothstein scandal but is operating under restrictions on how it accepts deposits and compensates officers Florida Bar takes little action The Florida Bar has taken relatively little action in response to one of the biggest crises in its history Last November Rothstein agreed to disbarment on consent Bar President Jesse Diner issued a statement at the time saying the Rothstein scandal was a terribly unfortunate and tragic situation but it is also a rare circumstance in the legal profession At the time Diner said the Bar would continue to investigate any violations of its rules by other attorneys who may have been involved in this case The Bar originally opened investigations into former RRA attorneys At the end of June it announced that of those cases were closed When asked by the Business Journa/for an update on Oct the Bar said only three of those cases remain open Rosenfeldt Russell Adler and Steven Lippman Rosenfeldt is also fighting a million claim in the bankruptcy case Where is Rothstein 10/22/rothstein.html print A year after Rothstein many questions unanswered South Florida Business Journal Page of Few people know where Rothstein is except that he is supposed to be in federal prison His name does not come up in a public website search for prisoners names because he is still cooperating with federal investigators Rothstein professed remorse in court but that had little effect on his sentence In a June letter to Cohn Rothstein wrote I do not really possess the words to adequately explain the magnitude of what I have done why I did it and the overwhelming remorse and self-loathing I feel about myself and the intense harm and pain I have inflicted upon innocent people Whether South Floridians have changed their reaction to Rothstein-type personalities in business remains to be seen I think people are being more careful with flamboyant personalities particularly charities and investors Scherer said We saw that Rothstein could buy political good will and stature But there have always been frauds and there will always be pbrinkmann bizjournals.com I 10/22/rothstein.html print Page of3 Home I News I Broward I Palm Beach I Sports I Entertainment I Travel I Lii Opiniou I Video Home Collections Florida Bar Ads By Google Shocking Language Video If you dont know Spanish and you want to you should dick here to see thls short video Watch Video AclChOtOHP Florida Bar looking at forme1 from Rothsteins firm January I By Amy Sherman and Jay Weaver The Miami I The Florida Bar is investigating at least former senior le firm headed by Scott Rothstein who was disbarred before using the firm to run a billion investment racket The Bar confirmed to The Miami Herald on Wednesday th the former firm Rothstein Rosenfeldt Adler lied about and whether they stole any of it Ads By Google Local Breast Cancer Walk Making Strides Breast Cancer Walk Help SavE MakingStridesWalk org Related Articles State Bar Investigates From Rothstein Firm November Scott Rothstein scandal One year later November Judge Warns Of distressing News In Scott Rothstein Law November Were Rothsteins Associates Blinded By His Star Power November Find More Stories About Florida Bar Page of3 Rothstein is scheduled to plead guilty Jan to federal rs charges stemming from his massive Ponzi scheme which funds Several of Rothsteins former partners have said they wer law firm to sell bogus legal settlements to wealthy investo1 without mentioning names have said that some of the la culpability The Florida Bar board of governors and its president Jes Rothstein in early November when word of the scandal bn pursue the probe into the other lawyers The Bar takes this issue very seriously Diner a Fort Lat actively investigating and will pursue remedies against an investigation didnt stop with Scott Rothstein This is a terrible thing that has happened to the legal prof the profession and the public to fully investigate this thing Diner said that Bar investigators will first determine wheth made any false representations to the Bar when they certi annually certify such accounts which are used to hold clie memberships He also said Bar investigators will determine whether any misappropriated money from client trust accounts as Re admitted doing when he agreed to be disbarred voluntarill Diner said the Bar which plays the role of a regulatory pre punishment ranging from a public reprimand to suspensio According to the federal criminal charges Rothstein raide firm held at Toronto Dominion Bank in Broward County The Bar initially disclosed in November that it was investi fall name partners Stuart Rosenfeldt and Russell Adler a general counsel David Boden Ads By Google Anidjar Levine Law Firm So Florida Lawyers Specializing in Personal Injury Casi southfl orida injurylaw com/Lawyers Dell Latitude TM Laptop Dont Forget to Shop Scalable Dell Latitude TM Laptops w.dell.com/Latitude But additional attorneys have received letters from the Bai investigation said Howard Greitzer a Fort Lauderdale am Meanwhile Rothstein appeared in federal court Wednesd who worked at his firm has no conflicts of interest in repre his upcoming guilty plea cannot be appealed http Index by Keyword Terms of Service Page of3 Prosecutors have said that Nurik Is not under criminal invE 1rRi Privacy Policy I Criminal Defense Lawyer Please note tt1e green-line linked article text tlas been applied commercially without any involvement from our newsroom ectilors reporters or any ott1er editorial stafL Aggressive Criminal Defense Free Consultation w.palmbeachcountydefense.com Featured Articles must-see places to visit in Florida MORE Use your own i PhoI Walmarts Straight unlimited plan Low white blood cell count not always a sign of Lif medical problem mi Fort Lauderdale accepting Section applications Ta How to recognize and treat a spider bite Ar DE This Just In I Sun Sentinel Blogs I former Scott Rothstein attorneys cleared by The Flor Page I of SunSentinel.com iid,c Home Broward County Palm Beach County Weather Sports Business Entertainment Consumer Cla Lifestyle Kim Rothstein wants some of her bling back I Main I Scott Rothstein partner Stuart Rosenfeldt testifies under oath former Scott Rothstein attorneys cleared by The Florida Bar By Peter Franceschina Sun Sentinel Posted by Admin at PM The Florida Bar has cleared former attorneys who worked at the Rothstein Rosenfeldt Adler law firm of any wrongdoing during the time Ponzi schemer Scott Rothstein was running a massive billion fraud scheme The Bar recently sent out letters notifying the cleared attorneys that a grievance committee found no probable cause of any wrongdoing Fourteen other attorneys including name partners Stuart Rosenfeldt and Russell Adler remain under investigation according to Bar spokeswoman Karen Kirksey The cases involving those attorneys have not yet been heard by the grievance committee The Bar is investigating whether any of the firms top lawyers were involved in any trust account irregularities at the firm Rothstein ran his fraud scheme using the now-bankrupt firms trust accounts Bankruptcy records show hundreds of millions of dollars flowing in and out of those accounts According to the Bar the cleared lawyers are Steven Abrams Shawn Birken Harold Bofshever Robert Buschel Sara Coen-Giovanelli Mark Fistos Scott A Goldstein Julio Gonzalez Jr Frank Herrera Steven Jaffe Christina Kitterman Seth Michael Lehrman Arthur Neiwirth Steven Osber florida/blog/2010/07 former _scott_rothstein_ atto This Just In I Sun Sentinel Blogs I former Scott Rothstein attorneys cleared by The Flor Page of John Michael Ross Adam Steinberg Richard Storfer Osvaldo Torres Matthew Weissing Johnny Williams Jr Tami Wolfe Blandin Wright The attorneys who have not yet had their cases heard according to the Bar are Russell Adler William Berger David Boden Gary Farmer Jr Denis A Kleinfeld Carl Linder Steven Lippman Marc Nurik Michael A Pancier Carlos Reyes Stuart A Rosenfeldt Grant Smith Barry Stone Les Stracher The Sun Sentinel obtained a copy of a Bar letter sent last week to one of the cleared attorneys It is titled Notice of no probable cause and letter of advice to accused The letter says the attorney held himself out as a partner at Rosthstein Rosenfeldt Adler when only Rothstein and Rosenfeldt held equity in the firm they were percent partners but the Bar acknowledged that the practice is customary around the country The Bar apparently heard the cases first involving attorneys who were considered partners and those who have not had their cases heard yet were considered shareholders It appears the Bar is also looking at whether some of the RRA attorneys were involved in campaign finance violations Federal prosecutes alleged in their criminal charges against Rothstein that employees of the firm violated state and federal election law by being reimbursed for political contributions The Bar also became aware of allegations that lawyers at RRA may have engaged in actions that constituted violations of campaign finance law the letter says It was alleged that lawyers at RRA were instructed to make political campaign contributions that were then reimbursed to the lawyer from funds at RRA The lawyer who received the clearance letter denied having knowledge of any trust account irregularities before the news accounts of Mr Rothstein fleeing the United States and thereafter being prosecuted criminally You denied that you were ever reimbursed for making campaign contributions or that you were ever asked to do so according to the letter The letter goes on to caution the attorney about proper trust account procedures and to observe standards of professional conduct POSTED IN Scott Rothstein Discuss this entry Permalink I Share i _florida/blog/2010/07 _former_ scott _rothstein _atto This Just In I Sun Sentinel Blogs former Scott Rothstein attorneys cleared by The Flor Page of I COMMENTS Aw come on isnt looking the other way a crime Posted by im no lawyer I July PM Is anyone but me tired and disgusted at haveing to look at this crooks smiling face every time the Sun-Sentinel runs a story on him Posted by Robert I July PM Free Russell Posted by docdecay I July PM What about the suspicious employess that worked there I heard that Andrew Barnett was involved in this fiasco along with others Posted by Steven I July PM What about the suspicious employess that worked there I heard that Andrew Barnett was involved in this fiasco along with others Posted by Steven I July PM Some damn fine lawyers and former judges are still in the soup it looks like My guess The ones that didnt just hold themselves out as partners but were actually partners are still being investigated for Trust accounting violations Too bad But they were supposed to keep track of the accounts Non-delegable duty Im afraid It an int fair given the custom of letting the major sharholders do all the accounting Practice will change as a result Posted by Wait-A-Minute I July PM And how many of these newly FL Bar cleansed attorneys laundered RRA money for political contributions to Charlie Crist John McCain et al Need a pie Doesnt he have a mug 225shot you could use I think the smug Im a Rock Star before shot is best Posted by And What About July PM Posted by Cheese I July PM What a joke the Bar is you saps Its a country club for lawyers Do you really think theyre going to revoke somebodys membership in the club for committing a crime Theyre slapping each other on the back laughing at the farce they just pulled off Posted by andrew learmonth I July PM Not sure what all the fuss is about per cent of the firm had no clue about any wrongdoing and there was no reason to believe so Posted by ron huckster I July AM http florida/blog/2010/07 former scott rothstein atto This Just In I Sun Sentinel Blogs I former Scott Rothstein attorneys cleared by The Flor Page of Shawn Birken Judge Birkens son That clears up the mystery why an incompetent like Judge Birkens wife Barbara McCarthy was appointed to the benh by Charlie Posted by Stan I July AM What about Pedro Dijols Posted by Greg I July AM The bar giving press releases involving attorneys under investigation is their attempt to look like the knight riding in on his big horse to save the poor public from thse cretins leave it to a group headed by Jesse Diner to be full of itself Posted by klalo I July AM lsnt not getting back to clients about their case make clients wonder if the attorney they believe in are really innocent or guilty Posted by ULL YI July PM The Florida Bar is a criminal enterprise And no one can reign them in so the best thing to do is ignore them until they go away Posted by Durnl founded I July AM Nice So I wonder how much the Fla Bar was paid to clear these names You cant tell me that they knew NOTHING about a major scheme that was happening in their very office Unbelieveable I POST A COMMENT Name Email Address URL Remember personal info Comments you may use rffML tags for styl!3 To Ip keep spam off our site please enter the letter in the field below Posted by Not surprised July AM http florida/blog/2010/07 _former_ scott _rothstein atto This Just In I Sun Sentinel Blogs I former Scott Rothstein attorneys cleared by The Flor Page of florida/blog/2010/07 _former_ scott_rothstein_ atto FAX Rothstein Rcsenfek1t Adler Attorneys at Law July Via Facsmlle ROTHSTEIN ROSBNFELT ADLE Adam Horowitz Esquire Stuart Mermelsteill Esquire Isidro Manuel Garcia Esquire Jeffrey Mate Herman Esquire Katherine Earthen Ezell Esquire Robert Josefsberg BsquiTe Jack Hill Esquire Dear Counsel lg Bradley Ed,:i.--ards Direct Dial bedv.rSrds rra law.com We have recently received Notice for Depositions from Adam Horowitz for several witnesses and the lever from Jack Hill indicating an intent to take others We intend to Cross-Notice each deposition Additionally we intend to set the following other individuals for video deposition I Donald Trump West Palm Beach Olen Dubin West Palm Beach Ghislain Maxwell New or Sara Keller New York Leslie Wexner Ohio Bill Clinton D.C Paula-Heil New York Jean Luc Bruhel New York 1t EXHlBIT DepononJiltfk.i,J,_ D:ne-Rptr e.Jft E20l!Oo1 Repry To us Olai City Cantre East Ota Boulevard uite Fort Lauderdale Aorida Telep none Fax 80CA RATON FOKT LAUDERDALE lAIAMI NaW YORI CITY TAUAHASSEE WASHINGTON D.C WEST ALM BEACH EXHIBITM FAX July Page 2of ROTHSTEIN ROSBNFBLT ADLE We will choose dates that have not already been occupied by other depositions already set in this case If you would like to be included in the scheduling of these depositions please provide me with your scheduling secretaries names and 225mail addresses any of you do JlQt need to be consulted regarding the scheduling of these depositions please advise me of that as wells Very truly yours ROTHSTEIN ROSENFELDT ADLER Bradley Edwards Esquire Partner Fort the Pinn BJE/rngl UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV MARRA/JOHNSON JANE DOE Plaintiff VS JEFFREY EPSTElN Defendant NOTICE OF TAKING VIDEO DEPOSITION PLEASE TAKE NOTICE that the Plaintiff JANE DOE will take the deposition of Leslie Wexler on Friday August at a.m at McGinnis Associates North High Street Suite Worthington OH The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day to day weekends and holidays excepted until completed I HEREBY CERTIFY that a true and correct copy of the foregoing has been served by U.S Mail and email transmission this z_f day of July to all those on the attached Service List EXHIBITN cc US Legal Support Court Reporters ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Olas Blvd Suite Fort Lauderdale Florida Tel Fax Email bedwards rra-law.com By BRAD EDWARDS ESQ Florida Bar No WE HEREBY CERTIFY that a copy of the foregoing was mailed this,1Sth day of July to Via regular mail and fax to Robert Critton Jr Esquire Flagler Drive Suite West Palm Beach Florida fax rcrit bclclaw.com Via email to Jack Patrick Hill jph searcylaw.com Isidro Manuel Garcia isidrogarcia bellsouth.net Katherine Warthen Ezell Kezell podhurst.com Michael James Pike Mpik:e bclclaw.com Paul Cassell cassellp law.utah.edu Richard Horace Willits lawyerwillits aol.com Robert Josefsberg rj osefsbert podhurst.com Stuart Mermelstein ssm t;usexabuseattomey.com Adam Horowitz ahorowitz sexabuseattomey.com ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Olas Blvd Suite Fort Lauderdale Florida Telephone Telecopier By Bradley Edwards Florida Bar No bedwardsf rra law com William Berger Florida Bar No wberger rra-law.com AO Rev Subpoenll to Testify 11ta Deposition or to Produce Documents in a Civil Action UNITED STATES DISTRICT COURT for the Southern District of Florida JANE DOE Plaintiff JEFFREY EPSTEIN Defendant Civil Action No 08-80893CIV-MARRA/JOHNSO If the action is pending in another district stale where SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION To Leslie Wexler One Whitebam Road New Albany Ohio Testimony YOU ARE COMMANDED to appear at the time date and place set forth beow to testify at a deposition to be taken in this civil action If you are an organization that is not a party in this case you must designate one or more officers directors or managing agents or designate other persons who consent to testify on your behalf about the following matters or those set forth in an attachment Place McGinnis Associates Date and Time North High Street Suite am The deposition will be recorded by this method Production You or your representatives must also bring with you to the deposition the following documents electronically stored information or objects and permit their inspection copying testing or sampling of the material The provisions of Fed Civ relating to your protection as a person subject to a subpoena and Rule and relating to your duty to respond to this subpoena and the potential consequences of not doing so are attached CLERK OF COURT OR a Signature of Clerk or Deputy Clerk Attorneys signature The name address e-mail and telephone number of the attorney representing 1mme of party who issues or requests this subpoena are Brad Edwards Esq ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Olas Blvd Suite Fort Lauderdale Florida bedwards rra-law.com 7Sf AO Rev Subpoena Testify at a Deposition orto Produce Documents in II Civil Action Page Civil Action No MARRA/JOHNSO PROOF OF SERVICE This section should not be.filed with the court unless required by Fed Civ This subpoena for name of individual and title if any was received by me on date I personally served the subpoena on the individual at place on date or I left the subpoena at the individuals residence or usual place of abode with name a person of suitable age and discretion who resides there on daJe and mailed a copy to the individuals last known address or I served the subpoena on name of individuaQ who is designated by law to accept service of process on behalf of name of organization on date or I returned the subpoena unexecuted because Other specify Unless the subpoena was issued on behalf of the United States or one of its officers or agents I have also tendered to the witness fees for one days attendance and the mileage allowed by law in the amount of My fees are for travel and for services for a total of I declare under penalty of perjury that this information is true Date Server signature Printed name and title Servers address Additional information regarding attempted service etc or UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV MARRA/JOHNSON JANE DOE Plaintiff vs JEFFREY EPSTEIN Defendant NOTICE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plaintiff JANE DOE will take the deposition of Ghislane Noelle Maxwell on Monday August at a.m at Esquire Court Reporters One Penn Plaza Suite New York NY The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day to day weekends and holidays excepted until completed I HEREBY CERTIFY that a true and correct copy of the foregoing has been served by U.S Mail and email transmission this day of July to all those on the attached Service List cc US Legal Support Court Reporters ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Olas Blvd Suite Fort Lauderdale Florida Tel Fax Email bedwards rra-law.com By BRADE F1artda Bar No AO Rl!v Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action UNITED STATES DISTRICT COURT for the Southern District of Florida JANE DOE Plaintiff JEFFREY EPSTEIN Defendant Civil Action No 80893CIV-MARRA/JOHNSO If the action is pending in another district state when SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION To GHISLANE NOELLE MAXWELL LLC NEW YORK fl Testimony YOU ARE COMMANDED to appear at the time date and place set forth below to testify at a deposition to be taken in this civil action If you are an organization that is not a party in this case you must designate one or more officers directors or managing agents or designate other persons who consent to testify on your behalf about the following matters or those set forth in an attachment Place Esquire Court Reporters Date and Time One Penn Plaza Suite York NY am The deposition will be recorded by this method Production You or your representatives must also bring with you to the deposition the following documents electronically stored information or objects and pennit their inspection copying testing or sampling of the material The provisions of Fed Civ relating to your protection as a person subject to a subpoena and Rule and relating to your duty to respond to this subpoena and the potential consequences of not doing so are attached Date I CLERKOFCOURT OR Signature of Clerk or Deputy Clerk Attorneys signature The name address e-mail and telephone number of the attorney representing name of party who issues or requests this subpoena are Brad Edwards Esq ROTHSTEIN ROSENFELDT ADLER Attomeys for Plaintiff East Las Olas Blvd Suite Fort Lauderdale Florida bedwards rra-law.com AO Re,v Subpoen11 to Testify at a Depoaitio11 or to Produce Documents in II Civil Action Page Civil Action No 08-80893CIV-MARRA/JOHNSO PROOF OF SERVICE This secnon should not be filed with tlie court unless required by Fed Civ This subpoena for name of individual and title if any was received by me on date I personally served the subpoena on the individual at place on date or I left the subpoena at the individuals residence or usual place of abode with name a person of suitable age and discretion who resides there date and mailed a copy to the individuals last known address or I served the subpoena on name of individual who is designated by law to accept service of process on behalf of name of organization on date or I returned the subpoena unexecuted because Other specify Unless the subpoena was issued on behalf of the United States or one of its officers or agents I have also tendered to the witness fees for one days attendance and the mileage allowed by law in the amount of My fees are for travel and for services for a total of I declare under penalty of perjury that this information is true Date Servers signature Printed name and title Server address Additional information regarding attempted service etc or UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV MARRA/JOHNSON JANE DOE Plaintiff VS JEFFREY EPSTEIN Defendant NOTICE OFT AK.ING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plaintiff JANE DOE will take the deposition of Glenn Russell Dubin on Tuesday August at a.m at Esquire Court Reporters One Penn _Plaza Suite New York NY The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day to day weekends and holidays excepted until completed I HEREBY CERTIFY that a true and correct copy of the foregoing has been served by U.S Mail and email transmission this day of July to all those on the attached Service List cc US Legal Support Court Reporters ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Olas Blvd Suite Fort Lauderdale Florida Tel Fax Email bedwards rra-law.com BRADEDWARD5,ESQ Florida Bar No AO BSA Rev Subpoem1 to Testify flt a Deposition or to Produce Documents in a Civil Action UNITED STATES DISTRICT COURT for the Southern District of Florida JANE DOE Plainltff JEFFREY EPSTEIN Defendant Civil Action No B089JCIV-MARRA/JOHNSO lfthe action is pending in another district state where SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CML ACTION To Glenn Russell Dubin 5th Avenue Unit New York NY fl Testimony YOU ARE COMMANDED to appear at the time date and place set forth below to testify at a deposition to be taken in this civil action If you are an organization that is not a party in this case you must designate one or more officers directors or managing agents or designate other persons who consent to testify on your behalf about the following matters or those set forth in an attachment Place Esquire Court porters Date and Time One Penn Plaza Suite 4715,NewYork NY am The deposition will be recorded by this method Production You or your representatives must also bring with you to the deposition the following documents electronically stored information or objects and permit their inspection copying testing or sampling of the material The provisions of Fed Civ relating to your protection as a person subject to a subpoena and Rule and relating to your duty to respond to this subpoena and the potential consequences of not doing so are attached Date ldf CLERK OF COURT OR Signature of Clerk or Deputy Clerk Attorney signature The name address e-mail and telephone number of the attorney representing name of pa1ty who 1ssues or requests this subpoena are Brad Edwards Esq ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Olas Blvd Suite Fort Lauderdale Florida bedwards rra-law.com AO Rev Subpoena to Testify at a Deposition or to Produce Doi;urnentll in a Civil Action Page Civil Action No 08-80893CIV-MARRNJOHNSO PROOF OF SERVICE This section should not be filed wit tlie court unless required by Fed Civ This subpoena for name af individual and title if any was received by me on doJe I personally served the subpoena on the individual at place on date or I left the subpoena at the individuals residence or usual place of abode with name a person of suitable age and discretion who resides there on date and mailed a copy to the individuals last known address or I served the subpoena on name of indiv dualj who is designated by law to accept service of process on behalf of name of organization on date or I returned the subpoena unexecuted because CJ Other specify Un1ess the subpoena was issued on behalf of the United States or one of its officers or agents I have also tendered to the witness fees for one days attendance and the mileage allowed by law in the amount of My fees are for travel and for services for a total of I declare under penalty of perjury that this information is true Date Servers signature Printed name arid title Servers address Additional information regarding attempted service etc or UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-80893C!V-MARRA/JOHNSON JANE DOE Plaintiff VS JEFFREY EPSTEIN Defendant Re NOCE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plaintiff JANE DOE will take the deposition of Donald Trump on August at a.m at Esquire Court Reporters One Penn Plaza Suite New York NY The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day to day weekends and holidays excepted until completed I HEREBY CERTIFY that a true and correct copy of the foregoing has been served by U.S Mail and email transmission this L.fa:ta.y of August to all those on the attached Service List cc Esquire Court Reports ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Olas Blvd Suite Fort Lauderdale Florida Tel Fax Email bedwards rra-law.com BRAD EDWARDS ESQ Florida Bar No Robert Critton Jr Esq BURM.AN CRITION UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV MARRNJOHNSON JANE DOE Plaintiff vs JEFFREY EPSTEIN Defendant NOTICE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plaintiff JANE DOE will take the depositibr.t of Nadia Marcinkova on Thursday September at a.m at Jl Esquire Court Reporters One Penn Plaza Suite New York NY The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day to day weekends and holidays excepted until completed i I HEREBY CERTlFY that a true and correct copy of the foregoing has been served by U.S Mail and email transmission this day of August to an those on the attached Service List cc Esquire Court Reporters ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Olas Blvd Suite Fort Lauderdale Florida Tel Fax Email bedwards rra-law.com By BRAD EDWARDS ESQ Florida Bar No AO Rev Subp!Cl to Testify at a Deposition or to Produce Documents in a Civil Action UNITED STATES DISTRICT COURT JANE DOE Plaintiff JEFFREY EPSTEIN Defendant for the Southern District of Florida Civil Action No 08-90893CIV-MARRA/JOHNSO Iflhe action is pending in another district slate where SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CML ACTION To Nadia Marcinkova 66th Street New York NY I Testimony YOU ARE COMMANDED to appear at the time date and place set forth below to testify at a deposition to be taken in this civil action If you are an organization that is not a party in this case you must designate one or more officers directors or managing agents or designate other persons who consent to testify on your behalf about the following matters or those set forth in an attachment Place Esquire Court Reporters One Penn Plaza Suite New York NY Date and Time am The deposition will be recorded by this method Production You or your representatives must also bring with you to the deposition the fa I lowing documents electronica1ly stored information or objects and permit their inspection copying testing or sampling of the material The provisions of Fed Civ relating to your protection as a person subject to a subpoena and Rule and relating to your duty to respond to this subpoena and the potential consequences of not doing so are attached Date CLERK OF COURT OR Signature of Clerk or Deputy Clerk A lorney signature The name address e-mail and telephone number of the attorney representing name of party who issues or requests this subpoena are Brad Edwards Esq Rothstein Rosenfeldt Adler Las Olas Blvd Suite Fort Lauderdale Florida Bedwards rra..Jaw.com AO Subpoena to Testify at a Deposition or to Produco Documents in a Civil Action Page Civil Action No 08-90893CIV-MARRA/JOHNSO PROOF OF SERVICE This sectwn should not be filed with the court unless required by Fed Civ This subpoena for name of individual and title if a/TY was received by me on date a I personally served the subpoena on the individual at place on date left the subpoena at the individuals residence or usual place of abode with name or a person of suitable age and discretion who resides there on date and mailed a copy to the individuals last known address or I served the subpoena on name of individual who is designated by law to accept service of process on behalf of name of organization on date or I returned the subpoena unexecuted because Other specify Unless the subpoena was issued on behalf of the United States or one of its officers or agents I have also tendered to the witness fees for one days attendance and the mileage allowed by law in the amount of My fees are for travel and for services for a total of I declare under penalty of perjury that this infonnation is true Date Servers signature Prinled name and liile Server address Additional information regarding attempted service etc or AO Rev Suhpoena to Testify al a Deposition Of to Produce Documents in II Civil Action Page Federal Rule of Civil Procedure and Effective Protecting a Person Subject to a Subpoena Avoiding Undue Burikn or Expense Sanctions A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena The issuing court must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorneys fees on a party or attorney who fails to comply Command to Produce Materials or Pmnit Inspection A Appearance Not Required A person commanded to produce documents electronically stored infonnation or tangible things or to permit the inspection of premises need not appear in person at the place of production or inspection unless also commanded to appear for a deposition hearing or trial Objections A person commanded to produce documents or tangible things or to pennit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting copyillg testillg or SBmpling any or all of the materials or to inspecting the premises or to producing electronically stored information in the form or forms requested The objection must be served before the earlier of the time specified for compliance or days after the subpoena is served If an objection is made the following rules apply i At any time on notice to the commanded person the serving party may move the issuing court for an order compelling production or inspection ii These acts may be required only as directed in the order and the order must protect a person who is neither a party nor a partys officer from significant expense resulting from compliance Quashing or Modifying a Subpoena A When Required On timely motion the issuing court must quash or modify a subpoena that i fails to allow a reasonable time to comply ii requires a person who is neither a party nor a partys officer to travel more than I miles from where that person resides is employed or regularly transacts business in person except that subject to Rule 4S i the person may be commanded to attend a trial by traveling from any such place within the state where the trial is held i requires disclosure of privileged or other protected matter if no exception or waiver applies or iv subjects a person to undue burden When Permitted To protect a person subject to or affected by a subpoena the issuing court may on motion quash or modify the subpoena if it requires i disclosing a trade secret or other confidential research development or commercial infonnation ii disclosing an unretained experts opinion or infunnation that does not describe specific occurrences in dispute and results from the experts study that was not requested by a party or i a person who is neither a party nor a partys officer to incur substantial expense to travel more than miles to attend trial Specifying Conditions an Alternative In the circumstances described in Rule the court may instead of quashing or modifying a subpoena order appearance or production under specified conditions the serving party i shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship and ii ensures that the subpoenaed person will be reasonably compensated Duties in Responding to a Subpoena Jroducing Documents or ElectronJca/ly Stored Information These procedures apply to producing documents or electronically stored information A DocumenJs A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand Form for Producing Electronically Stored lnfm 267mation Not Specified If a subpoena does not specify a form for producing electronically stored infonnation the person responding must produce it in a fom1 or forms in which it is ordinarily maintained or in a reasonably usable form or fonns Electronically Stored Information Produced in Only One Form The person responding need not produce the same electronically stored information in more than one fonn Inaccessible Electronically Slored Information The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost On motion to compel discovery or for a protective order the person responding must sbow that the information is not reasonably accessible because of undue burden or cost If that showing is made the court may nonetheless order discovery from such sources if the requesting party shows good cause considering the Ii mitations of Ruic The c.ourt may specify conditions for the discovery Claiming Privilege or Protection A Information Withheld A person withholding subpoenaed infonnation under a claim that it is privileged or subject to protection as trial-preparation material must i expressly make the claim and ii describe the nature of the withheld documents communications or tangible things in a manner that without revealing information itself privileged or protecte I wil I enable the parties to assess the claim tformation Produced If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial preparation material the person making the claim may notify any party thm received the infunnation of the claim and tbe basis for it After being notified a party must promptly return sequester or destroy the specified information and any copies it has must not use or disclose the information until the claim is resolved must take reasonable steps to retrieve lhe information if the party disclosed it before being notified and may promptly present the information to the court under seal for a detennination of the claim The person who produced the information must preserve the information until the claim is resolved Contempt The issuing court may hold in contempt a person who having bec:n served fails without adequate excuse to obey the subpoena A nonpartys failure to obey must be excused iftbe subpoena purports to require the nonparty to attend or produce ai a place outside the limits of Rule A ii UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV MARRA/JOHNSON JANE DOE Plaintiff vs JEFFREY EPSTEIN Defendant NOTICE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plaintiff JANE DOE will take the deposltion Mark Epstein on Monday September at a.m at Esquire Court Reporters One Penn Plaza Suite New York NY The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day to day weekends and holidays excepted until completed I HEREBY CERTIFY that a true and correct copy of the foregoing has been served by U.S Mail and email transmission this day of August to all those on the attached Service List cc Esquire Court Reporters ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Olas Blvd Suite Fort Lauderdale Florida Tel Fax Email bedwards rra-law.com By BRAD EDWARDS ESQ Florida Bar No AO Rev Subpoena to Testify at a Deposition or to Produce Documents in a Civil Action UNITED STATES DISTRICT COURT JANE DOE Plaintiff JEFFREY EPSTEIN Defendant for the Southern District of Florida Civil Action No 08-90893CIV-MARRA/JOHNSO If the action is pending in another district state where SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION To MarK Epstein 66th Street New York NY fl Testimony YOU ARE COMMANDED to appear at the time date and place set forth below to testify at a deposition to be taken in this civil action If you are an organization that is not a party in this case you must designate one or more officers directors or managing agents or designate other persons who consent to testify on your behalf about the following matters or those set forth in an attachment Place Esquire Court Reporters One Penn Plaza Suite New York NY Date and Time am The deposition will be recorded by this method Production You or your representatives must also bring with you to the deposition the following documents electronically stored infonnation or objects and permit their inspection copying testing or sampling of the material The provisions of Fed Civ relating to your protection as a person subject to a subpoena and Rule and relating to your duty to respond to this subpoena and the potential consequences of not doing so are attached Date CLERKOFCOURT OR Signature of Clerk or Deputy Clerk Attorney signature The name address e-mail and telephone number of the attorney representing name of party who issues or requests this subpoena are Brad Edwards Esq Rothstein Rosenfeldt Adler Las Dias Blvd Suite Fort Lauderdale Florida Bedwards rra-law.com AO SSA Rev Subpoena to Testify at a Deposilion or to l"rodu Documents in a Civil Action Page Civil Action No 08-90893CIV-MARRNJOHNSO PROOF OF SERVICE This section should not be filed with the court unless require by etl Civ This subpoena for name of individual and title if any was received by me on date I personally served the subpoena on the individual at place on date or a I left the subpoena at the individuals residence or usual place of abode with name a person of suitable age and discretion who resides there on date and mailed a copy to the individuals last known address or served the subpoena on name of individual who is designated by law to accept service of process on behalf of name of organization on date or I returned the subpoena unexecuted because Other specify Unless the subpoena was issued on behalf of the United States or one ofits officers or agents I have also tendered to the witness fees for one days attendance and the mileage allowed by law in the amount of My fees are for travel and for services for a total of I declare under penalty of perjury that this information is true Date Servers signature Printed name and fille Servers address Additional information regarding attempted service etc or AO Rev Subpoena to Testify al a Deposition or lo Produce Documents in a Cb1il Action Page Federal Rule of CMI Procedure and Effective Protecting a Person Subject to a Subpoena I Avoiding Undue Burden or Expense Sanction A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena The issuing court must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorneys foes on a party or attorney who fails to comply Command to Produce Materials or Permit Inspection A Appearance Not Required A person commanded to produce documents electronically stored information or tangible things or to permit the inspection of premises need not appear in person at the place of production or inspection unless also commanded to appear for a deposition hearing or trial Objections A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting copying testing or sampling any or all of the materials or to inspecting the premises or to producing electronically stored information in the form or forms requested The objection must be served before the earlier of the time specified for compliance or days after the subpoena is served If an objection is made the following rules apply i At any time on notice to the commanded person the serving party may move the issuing court for an order compelling production or inspection ii These acts may be required only as directed in the order and the order must protect a person who is neither a party nor a partys officer from significant expense resulting from compliance Quashing or Modifying a Subpoena A When Required On timely motion the issuing court must quash or modify a subpoma that i fails to allow a reasonable time to comply ii requires a person who is neither a party nor a partys officer to travel more than miles from where that person resides is employed or regularly transacts business in person except that subject to Rule i the person may be commanded to attend a trial by traveling from any such place within the state where the trial is held i requires disclosure of privileged or other protected matter if no exception or waiver applies or iv subjects a person to undue burden When Permitted To protect a person subject to or affected by a subpoena the issuing court may on motion quash or modify the subpoena if it requires i disclosing a trade secret or other confidential research development or commercial infonnation ii disclosing an unretained experts opinion or information that does not describe specific occurrences in dispute 11nd results from the experts study that was not requested by a party or i a person who is neither a party nor a partys officer to incur substantial expense to travel more th11n miles to attend trial Specifying Conditions as an Alternative In the circumstances described in Rule the court may instead of quashing or modifying a subpoena order appeur110ce or production under specified conditions if the serving party i shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship and ii ensures that the subpoenaed person will be reasonably compensated Duties in Responding toll Subpoena Producing Documents or Electronically Stored lnformaJlon These procedures apply to producing documents or e!ectronicaHy stored information A Documents A person responding to a subpoena lo produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand Form for Producing Electronically Stored I,iformation Not Specified 1f a subpoena does not specify a form for producing electronically stored information the person responding must produce it in a fonn or forms in which it is ordinarily maintained or in a reasonably usable form or forms Electronically Stored lnformafion Produced in Only One Form The person responding need not produce the same electronically stored infonnation in more than one fonn Inaccessible Electronically Stored lnf ormation The person responding need not provide discovery of eleclronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost On motion to compel discovery or for a protective order the person responding must show that the information is not reasonably accessible because of undue burden or cost If that showing is made the court may nonetheless order discovery from such sources if the requesting party shows good cause considering the limitations of Rule The court may specify conditions for the discovery Oaiming Privilege vr Protection A Information Withh2ld A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must i ex.pressly make the claim and ii describe the nature of the withheld documents communications or tangible things in a manner that without revealing information itself privileged or protected will enable the parties to assess tbc claim Information Produced If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial preparation material the person making the claim may notify any party that received the information of the claim and the basis for il After being notified a party must promptly return sequester or destroy the specified information and any copies it has must not use or disclose the information until the claim is resolved must talce reasonable steps to retrieve the information if the party disclosed it before being notified and may promptly present the information to the court under seal for a determination of the claim The person who produced the information must preserve the information until the claim is resolved Contempt The issuing court may hold in contempt a person who having been served fails without adequate excuse to obey the subpoena A nonpartys failure to obey must be excused if the subpoena purports to require the nonparty to attend or produce at a place outside the limits ofRule A ii UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV MARRA/JOHNSON JANE DOE Plaintiff vs JEFFREY EPSTEIN Defendant NOTICE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plaintiff JANE DOE will take the deposition of Jean Luc Bruhel on Tuesday September at a.m at Esquire Court Reporters One Penn Plaza Suite New York NY The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day to day weekends and holidays excepted until completed I HEREBY CERTIFY that a true and correct copy of the foregoing has been served by U.S Mail and email transmission this ay of August to all those on the attached SeJVice List cc Esquire Court Reporters ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Olas Blvd Suite Fort Lauderdale Florida Tel Fax Email bedwards rra-law.com By BRAD EDWARDS ESQ Florida Bar No AO Rev Subpoena to Te:itify at a Deposition or to Produce Documents in a Civil Action UNITED STATES DISTRICT COURT JANE DOE Plaintiff JEFFREY EPSTEIN Defendant for the Southern District of Florida Civil Action No 08-90893CIV-MARRA/JOHNSO ff the action is pending in another district state where SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION To Jean Luc Bruhel 66th Street New York NY if Testimony YOU ARE COMMANDED to appear at the time date and place set forth below to testify at a deposition to be taken in this civil action If you aTe an organization that is not a party in this case you must designate one or more officers directors or managing agents or designate other persons who consent to testify on youT behalf about the folJowing matters or those set forth in an attachment Place Esquire Court Reporters One Penn Plaza Suite New York NY Date and Time am The deposition will be recorded by this method Production You or your representatives must also bring with you to the deposition the following documents electronically stored information or objects and pennit their inspection copying testing or sampJing of the material The provisions of Fed Civ relating to your protection as a person subject to a subpoena and Rule and relating to your duty to respond to this subpoena and the potential consequences of not doing so are attached Date CLERK OF COURT OR Signature of Cleric or Deputy Clerk Attorneys signarure The name address e-mail and telephone number of the attorney representing name of party who issues or requests this subpoena are Brad Edwards Esq Rothstein Rosenfeldt Adler Las Olas Blvd Suite Fort Lauderdale Florida Bedwards rra-law.com AO BSA Rev Subpoena to Testify at a Deposition or to Produce Docwnenls in a Civil Action Page Civil Action No 225MARRNJOHNSO PROOF OF SERVICE This section should not be filed with the court unless required by Fed Civ This subpoena for name of individual and title if any was received by me on date I personally served the subpoena on the individual at place on date or I left the subpoena at the individuals residence or usual place of abode with name a person of suitable age and discretion who resides there date and mailed a copy to the individuals last known address or I served the subpoena on name of individual who is designated by law to accept service of process on behalf of of organization on date I returned the subpoena unexecuted because Other specifY or Unless the subpoena was issued on behalf of the United States or one of its officers or agents I have also tendered to the witness fees for one days attendance and the mileage allowed by law in the amowit of My fees are for travel and for services for a total of I declare under penalty of perjury that this information is true Date nzer signature Printed n41e and title Servers address Additional information regarding attempted service etc or AO SSA Rev Subpoena to Testify at a Deposition orto Produce Documents in a Civil Action Page Federal Rule of Civil Procedure and Effective Pflltecting a Person Subject to a Subpoena Avoiding Undue Burde,i or Expense Sanctions A party or attorney responsible for issuing and servmg a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena The issuing court must enforce this duty and impose an appropriate sanction which may include lost earnings and reasonable attorneys fees on a party or attorney who fails to comply Command to Produce Materials or Permit lnspeetlon A Appearance Not Required A person commanded to produce documents electronically stored information or tangible things or to permit the inspection of premises need not appear in person at the place of production or inspection unless also commanded to appear for a deposition hearing or trial Objections A person commended to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection lo inspecting copying testing or sampling any or all of the materials or to inspecting the premises or to producing electronically stored information in the form or forms requested The objection must be served before the earlier of the time specified for compliance or days after the subpoena is served lfan objection is made the following rules apply i At any time on notice to the commanded person the serving party may move the issuing urt for an order compelling production or inspection ll These acts may be required only as directed in the order and the order must protect a person who is neither a party nor a partys officer from signific1t11t expense resulting ftom compliance Quashing or Modifying a Subpoena A Wlten Required On timely motion the issuing court must quash or modify a subpoena that i fails lo allow a reasonable lime to comply ii requires a person who is neither a party nor a partys officer to travel more than miles from where that person ides is employed or regularly transacts business in person except that subject to Rule BXi the person may be commanded to attend a trial by traveling from any such place within the state where the trial is held ill requires disclosure of privileged or other protected matter if no exception or waiver applies or Iv subjects a person to undue burden When Permitted To protect a person subject to or affected by a subpoena the issuing court may on motion quash or modify the subpoena ifit requires i disclosing a trade secret or other confidential research development or comincrcial information ii disclosing an unretained experts opinion or information that does not descnbe specific occurrences in dispute and results from the experts study that was not requested by a party or i a person who is neither a party nor a partys officer to incur substantial expense to travel more than miles to attend trial Specifying Conditions as an Allen,ative In the circumstances described in Rule the court may instead of quashing or modifying a subpoena order appearance or production under specified conditions if the serving party i shows a subatantial need for the testimony or material that cannot be otherwise met without undue hardship and ii ensures that the subpoenaed person will be reasonably compensated Duties in Responding to a Subpoena Producing Documents or Ele,tronu:aUy Stored Information These procedures apply to producing documents or electronically stored infonnation A Documents A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand Form for Producing Electronically Stored lnformaJion Not Specified If a subpoena does not specify a fonn for producing electronically stored information the person responding must produce it a fonn or forms in which it is ordinarily maintained or in a reasonably usable fonn or forms Electronically Stored Information Produced in Only One Fonn The person responding need not produce the same electronically stored information in more than one form Inacces ible Electrcinicolly Stored Information The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost On motion to compel discovery or for a protective order the person responding must show that the information is not reasonably accessible because of undue burden or cost If that showing is made the court may nonetb.eless order discovery from such sources if the requesting party shows good cause considering the imitations of Rule X2 The court may specify conditions for the discovery Clalmmg Privilege or Protection A Information Withheld A person withholding subpoenaed information under a claim that it is privileged or subject to protection as trial-preparation material must expressly make the claim and ii describe the nature of the withheld documents co:mmunicatious or tangible things in a manner that without revealing information itself privileged or protected will enable the parties to assess the claim Information Produced If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial preparation material the person making the claim may notify any party that received the infonnation of the claim and the basis for it After being notified a party must promptly return sequester or destroy the specified infonnation and any copies it has must not use or disclose the information until the claim is resolved must take reasonable steps to retrieve the information if the party disclosed it before being notified and may promptly present the information to the court under seal for a determination of the claim The person who produced the information must preserve the infonnation until the claim is resolved Contempt The issuing court may hold in contempt a person who having been served fails without adequate excuse to obey the subpoena A nonpartys failure to obey mus be excused if the subpoena purports to require the nonparty to attend or produce at a place outside the limits of Rule A ii UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV MARRA/JOHNSON JANE DOE Plaintiff vs JEFFREY EPSTEIN Defendant Re NOTICE OFT AKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plaintiff JANE DOE wl take the deposition of Ghislane Noelle Maxwell on Wednesday September at a.m at EsQuire Court Reporters One Penn Plaza Suite New York NY The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day to day weekends and holidays excepted until completed I HEREBY CERTIFY that a true and correct copy of the foregoing has been served by U.S Mail and email transmission this of August to all those on the attached Service List cc Esquire Court Reporters ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Oles Blvd Suite Fort Lauderdale Florida Tel Fax Email bedwards rra-law.com Robert Critton Jr Esq BURMAN CRITTON BT AL North Flagler Drive Suite West Palm Beach FL Jay Howell Assoc Cesery Boulevard Suite Jacksonville FL Jack Alan Goldberger Esq Atterbury Goldberger et al Australian Ave South Suite West Palm each FL Paul Cassell Esq South Room Salt Lake Girty UT Service List Jack Alan Goldberger Esq Atterbury Goldberger Weiss P.A Austrailian Avenue South Suite West Palm Beach I UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO MARRA/JOHNSON JANE DOE Plaintiff vs JEFFREY EPSTEIN Defendant Re-NOTICE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plaintiff JANE DOE will take the deposition of Donald Trump on September at oo a.m at Esquire Court Reporters One Penn Plaza Suite New York NY The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure I and shall continue day to day weekends and holidays excepted until completed I HEREBY CERTIFY that a true and correct copy of the foregoing has been served by U.S Mail and email transmission this day of August to all those on the attached Service List oY cc Esquire Court Reports ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Olas Blvd Suite Fort Lauderdale Florida Tel Fax Email bedwards rra-law.com By BRAD EDWARDS ESQ Florida Bar No UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CfV MARRNJOHNSON JANE DOE Plaintiff VS JEFFREY EPSTEIN Defendant Re NOTICE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plaintiff JANE DOE will take the deposition of Sarah Kellen on October at a.m at Esquire Court Reporters One Penn Plaza Suite New York NY The deposition shall be.conducted pursuant to the Federal Rules of Civil Procedure and shall continue day to day weekends and holidays excepted until completed I HEREBY CERTIFY that a true and correct copy of the foregoing has been served by U.S Mail and email transmission this day of September to all those on the attached Service List cc Esquire Court Reporters ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Olas Blvd Suite Fort Lauderdale Florida Tel Fax Email bedwards rra-law.com Sl-4 A By BRAD EDWARDS ESQ Florida Bar No Robert Critton Jr Esq BURMAN CRITTON UNITED.STATESDrSTRICT COURT SOUTHERN D_ISTRICT OF FLORIDA CASE-NO 08-CIV MARRA/JOHNSON JAN"EDOE 267-Plain iff vs JEFFREY E:PSTEIN Defendant I Re NOTICE OF TAKINGVIDEOTAPED DEPOSITION PLEASE-TAKE NOTICE that the Plaintiff JANE DOE wiH take the 267deposition of Nadia Marcink-ova on October at a at Esqtd;e Court Reporters One Penn Plaza Suit New-York/ftJY ep.0 1tion sha;II be conductedJ Ul Uant the Federal Ru es of C1viLProced re and shall continue day day weekends and 267holidays excepted until completed I 267HERE.BY CERTIF.Ythaf atrue a correct copy of the foregoing ha been served by il em ilttansmission this day of eptember to all those on the attached Service List cc squire Court Reporters ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff Eastlas Olas Blvd Suite Fort uderdale Florida Tel Fax Eriiail bed 267com I Yl t_ teJ By BRAD EDWARDS ESQ Florida Bar No UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO 08-CIV MARRA/JOHNSON JANE DOE Plaintiff VS JEFFREY EPSTEIN Defendant __ Re NOTICE OF TAKING VIDEOTAPl:D DEPOSITION PLEASE TAKE NOTICE that the Plaintiff JANE DOE will take the deposition of Ghislane Noelle Maxwell on October at a.m at Esquire Court Reporters One Penn Plaza Suite New York NY The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day to day weekends and holidays excepted until completed I HEREBY CERTIFY that a true and correct copy of the foregoing has been served by U.S Maii and email transmission this ay of October to all those on the attached Service List cc Esquire Court Reporters ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff East Las Olas Blvd Suite Fort Lauderdale Florida Tel Fax Email bedwards rra-law.com By BRAD EDWARDS ESQ Florida Bar No CASE NO 08-CV-80119-MARRA/JOHNSON CERTIFICATE OF SERVICE SERVICE LIST Jane Doe Jeffrey Epstein United States District Court Southern District of Florida Jack Alan Goldberger Esq Jgoldberger agwpa.com Robert Critton Esq rcritton bclclaw.com Isidro Manual Garcia isidrogarcia bellsouth.net Jack Patrick Hill iph searcylaw.com Katherine Warthen Ezelt KEzell oodhurst.com Michf.lel James Pike MPike bclclaw.com Paul Cassell cassellp bclclaw.com Richard Horace Willits lawyerswillits aol.com Robert Josefsberg rjosefsberg godhurst.com Adam Horowitz ahorowitt sexabuseattomey.com Stuart Mermelstein ssm sexabuseattomey.com William Berger wberger rra-law.com AO IA Re Sullpoa lO Tgjfy ltl Dtlorto Produoll Ina CMI Action UNITED STATES DISTRICT COURT for the Southern District of New York Jana Doe Pkl/nttf Jeffrey Epstein Civil Action No CIV--MARRA lftllo action ispcndlns In lotbcrdwrii:t,lta where Southern Di trl.ct of Florida SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCI DOCUMENTS IN A CIVIL ACTION To Ghlsland No811e Maxwell East65 LLI New York NY sf Testimony YOU ARE COMMANDED to appear at the time date and place set forth below to testify at a deposition to be taken in this civil action If you are nn organmtion that is not a party in this you must designate one or more officers directors or managing ag or designate o1ber persons who consent to testify on your behalf about 1be foUowing matters or those set forth in an attachment Place EaqUlre Court Reporters One Penn Plata Suite New York NY Date and Time am The deposition will be reoorded by this method fl Production You or your representatives must also bring with you to the deposition the following documents electronically stored infonnation or objeot.s and pennlt their inspection copying testing or sampling of the material See Schedule A attached The provisions of Fed Civ 4S relating to your protection as a person subject to a subpoena and Rule 4S and relating to your duty to respond to this subpoena end the potential consequences of not doing so arc Dttached Date CLERK OF COURT jniiliirio"Clirk or1Npidy 1:li"ff The name uddress o-mall and telephone number of the attorney represe ng 11WM of party who issues or requests this subpoena are Brad Edwards Esq Rothstein ROS8flfeldt Adler Las Oles Blvd Suite Fort Lauderdale Florida Bedwards rra-law.com AO A Rff Wot Subpolm ta tt a Oepo,!don or to Produce OOllfflfflls Ina CMI M1kin Pqe Civil Action No CIV-MARRA PROOF OF SERVICE Thia Reflor should not be fllul wltl the court unless required by Fed Chi This subpoena for nonu Qjlndi,ldwl and tl ii any was received by me on dou I personally served the subpoena on the individual at p/Qt on dais ot __ __ tJ I left the subpoena at the individuals residence or usual place of abode with l!Rllfe a person of suitable age and discretion who resides there on and mailed a copy to the individuals last known address or ti I served the subpoena on name of lndMdilill who is designated by law to accept service of process on behalf of of ortJQn/z lon on dcm or I returned the subpoena unexecuted because ti Other lpcic fj Unless the subpoena was issued on behalf of the United States or one of its officers or agents I have also tendered to the witness fees for one days attendance and the mileage allowed by la.w ln the amount of My fees mo fur travel and for erviccs for a total of or I declare under penalty of perjury that this infonnation is true Date Servers ignatun Additional infonnation regarding attempted service etc AOIIA Rev OIID9 Sttbpocoa toTeal 225nDepost iQil o,IO Pn14ute tiln1Chil Acllon Papl Federal Rale oretvn Procedure and Etrec:thci l"rotecdag a PelIOD SUbject to a Subpoena Avt ldln VrllR BIUdt!ta or l!Jq,Mu Sm,ctton A party or ltOmey responsfblo for muina llnd serving a subpoena must tall:11 reuoflable stepS to avoid Imposing undue burden or c:;tpcnso on a person subjeot to lhc aubpocna The lmiing cowi must onforco tb1s dufy and lmpo80 an sanction which may liduck lost earolnp tld rcuonable attorneys fees oo a party or attorney who fails to comply COltONIIUI to Materillb or Pmnlt lnsped/M A App 253artllIOI Not 253qiund A 253son commeruled to produce documents clectronic:ally stored Information or tangible things or permit tho Inspection ofprcmlaes not appear In porson at the pltwc of production or Inspection 1less also OOflDded to appear fur a depos.itlon hearing or trial ObJecttoM A person commanded to produco dowmcnta or tangible things or to permit Inspection may servo on aw pcty or aitomoy dcsJgnak:d In lbc subpoena I written objection to lnspcctlng copying testing sampling any or all oflhe materials or to Inspecting Uto RlhliBaa-or to prodl.J11ing elcaronlcally stored information ill tho fonn or forms ldqlleaited Tho objection must be served before the earlier of tho time specified for compliance or days a tho subpoena Ja smcd If an objection ls made tho following rules apply I At my time on notil:8 to the wmmandcd pefSO!l tho serving party may move lhc Issuing court for order oompelling pioducdon or l.nspcction These acts may be required only as direacd in tho onicr tho order must protect a person who Is noithcr a party nor a partys officar from significant reswting ttom compliance a,,aw or Madffilltg a A Whan qvhd On timc:ly motion the issuing t:Ourt must qulh or modify a subpoeaa that i fails fQ allow a reasonablo time to comply requires a person who is nc.lther a party nor a party offlcor to era,cl moro than miles orn where that pcnon tC9kles is employed or iqularly tralciB business In ptlrllOll excq,t that subject to Ruic 4S lii tho person ba commanded to attend a trial by travoliog ftom Ill auch placo within tho state where the trial ls he.Id Ill requires disdosurc of prlvllcs or other protected mattcl if no exception or widVCI applies or Iv JUbjects I pc:non undue burden JYlr,n hrmitt,d To protoct a person subject to or affccted by a subpoena the Issuing collt nay on mudon quash or modify 1ha subpOClla It It iequlres i disclosing a 11adc aocrat or other ronfidcntlal re:,carch development ur commercial 267Information Ol disclosing.1 unroqmed.expcrtsoplnion or information that docs not describe spcclfio IIClUffClCD In dispute and results om Ole e:xperts study Chit wa not reque.,tcd by a party 267-clil apoisoiiwlwi ipiftyffiira pAnys offlCtl?m ill.cut substandal to 1ravcl moni tban JOO miles to aucnd trial Sp,cifying Condhtons as a,i Ab1 Zrfw In the olrcumataRCC describad in Rulo 4S the court may inskad or quashing or modifying a JUbpoona order appearanc:c or production under speoUlcd condlons if tho serving party I ahows a subslantial hCed for the tc:stllJIOII or material that cannot bo olbcrwise without unduo hardship snd ll eDSURS dl tho aubpocroaed person wDI be rcuonably compensated utiQ In Re1porntl to a Subpoena I ProdJ4clng Doc11ments or BltldroltlcallJ SJorwl llf/omallon Thcso procedutu apply to producing documonts or oloc:ttonically stored Information A Docwnffl A person responding to a wbpo a to produce documents must produce them as they are kept In the ordinl COUl1C of business or must orpniui ld label lhom to 273respond to the categories In the dom nd Form for Producing Eler:tronicaiJy Stored 1/orltUltlon Not ec llet If a aubpoena does not specliy a fonn for producing eled:ronk:ally stulCd lnfocmatlo11 te pman rcsporuling mmt produce It In a fonn or forms in which It Is ordinarily main1aincd or In a fClfOnably usable form or forms Elsctnmtca/Jy Stond tlormaliOII Productd in Only Form The pmoo rosptJnding need not pro the same clccimnlcolly stored infonnation In more than ono form lmCCUJibk Efeelrot1fca/Jy Stor Jlfformation The person R!lpOnding need not provide discovery of clectronlcall stored 267lnronoation from sources tbr.t the pers,on Identifies as act reosoaably accessible bcc:alde of undue burden or cost On rnotwn to compel di3COVCT or for a protective order pClOTI responding must show that the lnfotmation is not rcasooably Ible because of undYD bunlcn or cost If that showing Is made the court mny nonetheless ordar dlacoYCJy ftom such sources iflhc requesting pl1y shows good cause considering the limilal!ons ofRulc bX2 The court m11y Oeify conditions for the dlscov Claunlng Prl,lhp Prwtdlon A ln/ormallon Withheld A penon withholding subpoenaed lnfonnatfon under a claim that It Is prl vllagcd or subject to protecUon as trlaj..pcoparatlon material must I cxprtl3Sly make Ibo olelm end descrlba the naturo of the wlthhdd documents cammunlcatlom or langiblc things In a lGJ hat without nwcallng lnfonnatlon itsdf privilegai or protected will enable the parties to mea the claim InormaJion lf infonnatioli produced in lC3J ODSC to a subpoena is subject to a clah:rJ ofprivil gc or ofprotecilon as triat prcparatloo mateti the person making the claim may notify any party that lWllved tha lnfomlition oflhe claim anchhe basis-for it A bolng notified a party must promptly relum 11Cql.lester or dcsttc,y tha spacitled Information 11nd any copies ltbas must not use or disclosc the information until tho him is resolved musl tllke rCll!Onablo Slcps to retrieve tho lnfonnat!on If tha party disclosed lt baforo being notified 1d may promptly pment the lnformatlon to lhe 110urt under cal for a ddcrmlnatfon of the c::lalm The person who productd lhe information must preserve the lnfOJlatlon until the ebdm Is resolved Coat1pt The issuing court may hold ln contempt a person who having been served fails without adequate excuse to obey the nonpartysfaiti.w obeylIIUSl bc rused lflhc subpoena purport to require the nonpqrty to ettend or produce at a place outside tho Hmits of Rulo 3XA fi Schedule A to the Subpoena Duces Tecum of Ghlslane Maxwell A list of ill girls that Defendant Epstein had at his house at El BriUo Way for any reason at any time including guests and masseuses for the entire duration when you worked with or for Jeffrey Epstein A list of I girls that Defendant Epstein had at his house in Manhattan for any reason at any time Including guests and masseuses for the entire duration when you worked with or for Jeffrey Epstein Any and a!I documents that reflect scheduling and/or appointments for Epsteins flights travels accommodation massages or meetings for the entire duration when you worked with or for Jeffrey Epstein A complete list of all girts whom you know to have flown in any of Defendant Epsteins airplanes or jets at anytime during the time you worked with or for Jeffrey Epstein Any and all diaries and/or notes and/or logs that In any way relate to Deiendant Epstein his airplanes his properties his assets and/or his finances AO HA Rn Testily Ill a orlOPmdoce Doclnmls Ina Civil Aciioa UNITED STAIBS DISTRICT COURT fortbe Southern District of New York Civil Action No CN-MARRA Jeffrey Epstein If the action is pending in another district state where Southern District of Florida SUBPOENA TO TESTIFY AT A DEPOSmON OR TO PRODUCE DOCUMENTS IN A CIVIL ACl10N To Ghlsland Noelle Maxwell East New York NY fl Testimony YOU ARE COMM.ANDED to appear at the tinu date and place set forth below to testify at a deposition to be taken in this civil action If you are an organization that is not a party in this case you must designate one or more officers directors or managine agents or designate_ 9ther persons who conseni to 1eStify on your behalf about the folJowing matters or those set forth in an attachment Place Esquire Court Reporters One Penn Plaza Suite New York NY Date and Tiroe am The deposition will be recorded by this method ti Production You or your representatives must also bring with you to the deposition the following docmnents electronically stored infonnation or objects and pennit their inspection copying testing or sampling of the material See Schedule A attached The provisions ofFed Jl Civ relating to your protection as a person subject to a subpoena and Rule and relating to your duty ro respond to this subpoena and the potential consequences of not doing so are attached Date CLERK OFCOURI Sigiw-e a/Clerk or lJepiit.y cteii Tho name address e-mail and telephone number of the attorney rep who issues or requests this subpoena are Brad Edwards Esq Rothstein Rosenfeldt Adler Las Clas Blvd Suite Fort Lauderdale Florida Bedwards rra-law.com AO SSA Rev Subpoena to Tutify at ti Ooposilion ur to Prod11Cc Docum;nts in ll Civil Aclion UNITED STATES DISTRICT COURT for the Central District of California Jane Doe Plaimijf CjviJ Action No 0S-80893CIV-MARRA/JOHNSO Jeffrey Epstein lf lhe action is pending in another district state where Defendant Southern District of Florida SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION To Michael Freidman Avenida Madero La Quinta CA i Testimony YOU ARE COMMANDED to appear at the time date and place set fo1th below to testify at a deposition to be taken in this civil action lfyou are an organization that is not a party in this case you roust designate one or more officers directors or managing agents or designate other persons who consent to testify on your bebalf about the following matters or those set forth in an attachment Place Farewell Court Reporters Date and Time Spyglass Hllf Dr La Quinta CA The deposition will be recorded by this method Production You or your representatives must also bring with you to the deposition the following documents electronically stored information or objects and permit their inspection copying testing or sampling of the material The provisions ofFed Civ re1ating to your protection as a person subject to a subpoena and Rule jl,5 and relating to your duty to respond to this subpoena and the pptential consequences of not dojng so are attached Date CLERK OF COURT i rr OR Signc,ruNI of Clerk or Deputy Cl r-k The name address e-mail and telephone nwnber of the attorney representing name of party Jane Doe Sa,_ who issues or requests this subpoena are Brad Edwards othstein Rosenfeldt Adler Suite Las Olas Btvd Fort Lauderdale FL edwards RRA-law.com I AO ilA R"v 01/flI S1,bpoem110 leslify llt a De itio ortu Pl"Qdocc Oo,;umcms in aCivH Aciion UNITED STATES DISTRICT COURT Jane Doe Plainriff Jeffrey Epstein Defendant for the Centrnl District of California Civil Action No 08-80893CIV-MARRNJOHNSO Jfthe action is pending iu another district state where Southem-District of Florida SUBPOENA TO TESTIFY AT A DE.POSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION To Rosalie Freidman Avenida Madero La Quinta CA Te.rtimony YOU ARE COMMANDED to appear at the time te and place set forth below to testify at a deposition to be taken in th.is civil action If you are an organization that is not a party in this case you must designate one or iuore officers directors or managing agents or designate other persons who consent to testify on your behalf about the following matters or those set forth in an attachment fPiace I Farewell Court Reporters Spyglass Hill Dr La Quinta CA Date and Time I The deposition will be recorded by this method i Production You or your representatives must also bring with you to the deposition the following documents electronically stored infonnation or objects and permit their inspection copying testing or sampling of the materiul The provisions of Fed Civ relating to your protection as,a person subject to a subpoena and Rule and relating 1o your duty to respond to this subpoena and the P.otential consequences of not doing so are attached Date CLERK OF COURT i;;lr S;gnature of Clerk or Deputy Clerk The name address e-mail and telephone number of the attorney representing name of party Jane Doe who issues or requests this subpoena are Brad Edwards Rothstein Rosen eldt Adler Suite Las Olas Blvd Fort Lauderdate Fl 3456.Bedwards RRA-law.com AO SSA Ol Sobpocna kl Tostlfy Ill a Dccositioo or to OQllCe Doculiltl 1n a Ovit Action UN,ITED STATESDIST CO Doe Pkttnti/f fortne Centtal District of Califonua Civil Action No MARRA/JOHNSO Jeffrey Epstein If Ille action is ptmding l!Olber distnct sta.t where Southern Distdct of Florida Sl1BlOENA T.O TESTIFY AT A OJ.POSITION OR TO ODUCE D9CIJME IN A ciy.IL ACTl To Mictiael 8anka South Beverly Dr:ve Suite Beverly Hills Ca I mnony YOU ARE COMMA.i."I ED to appear at he time anll place 11et forth below to testify at a depositi to be taken in this civil action If you ani au m:ganizatton that-is not a party in this case you must c:lestgna1e one or more officers directors or managing agents or designate otherpetsons Who consent to testify on your behalf aMut the following matters or those forth in an attachm P.ace North Camden Drive 4th floor Beverly HIiis Fl 267na.te and Time The d.epOllition will be recorded by th irt Bu.i_e""pq CJ Production You or your representat.t ves must-also bring with ty9u_ to lhe deposition the fo llowmg documents c.lectronically stored infOlati.qn or objects anCI permit tlleir inspoction copyjng testing or sampling of the matenat The provisions of Feet Civ t"j rel ting ti yohr pri Bk person subject to a subpoena anri Ruic and relating to your duty to tespond to 267ftlh subpoena end tbb tat consequeaces of not doing so are attached Date _c_fj;_ERK_o_;p-_c_o_UR_r oR Stp11m er Uk OI Depi1ty Clruw Atior srg,,arure The name address mail and teli,phOne numbe:r of the attorney repres nting name qf parryj Jane Doe issues or requests thts sutlpoena are Brad Edwards Rothstein Rosenfelljt Adler Suite las Olas Blvd Fon Lauderdalij FL Bedwarcb RRA-law.oom AO SIA Rev Subpoena llfv I Deposition or lro:!llce Docl1:en IR ii Civil Mt1on Page Federal Rule of Civil Procedure 4S ld Effective Protecting I P.ersoo Subject SUbpeena A voJdlng Valhle Buraeu or Expa,uH SlfflctifHfll A party or attorney responsible tor isSuing and Stirvmg a subpoena must ta reasonable stCJJI to IIVQld uniiosmg ww.oo burclen or exDcnse on a i:,ei-!ilOII subject to tne SubJ oena The 1!16uSng court mllSt enforce thls auty aod imoosc an 11pprot1rtate S3.11ction whJcb may lOOluoe 1os1 eammgs ana reasonable attorney fees on a llinY or attomey wllo fails to comply Cl1""1fd ti Pt""1la MaterUlu or Permit J1 253Uon A Appearance Not R.eqrwed A person comman11c to P1od11ce documents electromcally stored informatiQn or ta.,gible tltill or to timnJt Ille inspection of premises neeo not appear at UJc pl4co of promretIon or msi:,ectioo unless also commanded appeal for doposition hearing or 1rtal Obi IIOlIS A pi:rson commanoeo to produ CIOCuments or tangible things or to Cmtit Inspection may serve on tile party or attorney 243tesrgnaled in tile subPoena a wrlucn objecuon to pytng tesbng or iamJ lin,g 11ny or all of the mater1a1S or to Impecting tbe ptemJS to prO IUcmg eJcctromcally slorcd mfotmat1O11 i:n the form or fonns reQuestcd Theobjccuon must be served bef tnc earlier o:lhc time spcoirtcd for wmpliancr or Cla 8ftcr lite sutii,aena ts served If an objection 1s mace the follOWJng rules npply i At my tune on nc,t1co to thC commanded person the crvmg party may move tne 1SSumg court for an oreler compelling productlOll or 1nspecfion lt may be required only as directed in the ord11r ld I.he order mu protect a tiers on who nci Lxtr a PIU1 nor a pa.rt ifficer from significant expense n:-sulling from complhlD.ce l,fasltlngttr,V6difym J.llpoe,u A JJ7ien Reqi,uwl On timely motion tile ill lng cc urt IJlUst quasn or modify a su cm that i fails lo I a rcmonablc bme to co1ply ii reautres a llC:ISOn wl Is neithc a Darty nor a pa:ty officer lo tnn-cl mo than mi:1es from where thal person resides ui employed or regularly cm buSlncss f;m tl i:xcept tha1 subject lD Rule i too person may be commanded to attmd a trial by veHng from any suctt place within the Slate where me tnal is 11eld flii requires discic Ure or prtvilqc:d or other nrotected matter if no ex ept1on or waiver 11pplics or fv subjects a pcrsoo ro undue burdc:.l When Pei,,rmal To lOtt:el a oerson bjcct to or atft:ctcd by a sUbpQena the isswng court may on motion QUflffl or modify the SU!lpoem1 if it requUCS discloSJng I tnul.e met or other eonfidentlaJ re6C1Ch aeveioi:nnent or commercml inforrnatum ff disclosmg an unrelalne ex:pert"S opia1on or mfonnatton Cloes not Cleserlbe speclfio occurrences dispute and reallts from the ex-pert study 1hat was not requested by a party or i a er.wn wllo is neither a aJt nor a mty cfficer to mour sutlS:antU!il expense to uavl more ma.n miles to il nd trill Sl,eci/jllng CoNfitio,u as an Alurnartw.1 ln tile c1rcu!Pllt:uJ cs described in Rule tile ccurt may instead of crwshlng or modifying a sub na otdcT appearance or proauction unoer speclfJed condltlons lf1he serving party i S10ws subs nt1a1 need for inc test mony or materiel that cannot otherIA.!Se met without undue haroshlp and II ensures that tll sutlJ Oenaed person will be reasonably coffJJ Cll8!1tc Dutks in Repondiog to A Subpcen._ I Protltia,rg qeuments ar EferJtro,uea/ly Wed l,iformnllwi Thisse procedures apply to lIXIUCIOg dOCuments or cloctrom ally stored intormntion A Doc1une,in A person rcsl Onding to a subl Da to produce ctoouments must produce them as they 11rc kept Ill tlJC ordiury course of bllsine,s or must orgarllze and laoel thcm to correspond to the categories in tile demand FormfoJ Producmg Ekctroiea/ly Str Jnformallon Not Specified If a wbl oena ioi:s no1 specify a form for producing eltctromcally stored lnformalioo the responding must pr iuce It in a form or forms whicll 1t is ordharily trullnta.Jned or io a reasonably usable form or forms ElectromcalJy Stored Jnformatton Produced In 01rly One Form The person resoonding need not produce tJlc same electron11:11lly stored information mcxe Ill.an one fonn tnacc slbJe Eieetro11 aily Stored J,iformmion The person ros:oonding ncct1 not provide discovery of eiCCUOn stored information from sources I.hat the t1ers0o identifies not ICIL5onably ssible because of undue blrden or cost On motion to compel clistovery or for a protective order tne person n:spooding must show that the 1:1formati-00 is nol reHonably ecsslblc because of undue mmJea or cost lfthat showing 1s macle the court may nonctbel SS order discovery from such sources if the requcsti ng par1y shows gooc;i et1use COO ldering Ille limItaliODS ofRuie The co::r1 may specify conditions for 1he discovery fZ CJiflmil,g Privilege Proltlon A hto mauo,r Wi hheld A person withholding SUbl o:nacd mformatlon under a claim th11t tt pnvileged or subject protection os trllsl 225Prcparauon m1m:n1 must I xpressiy make tl claim iln I Ii descriho tit nature ofthe wjthheld documents communicaucms or tang!bl.11 things ma manner ttiat without revelng lnform11tjcn itself rmvlleJietl or wotec;ted will enable tile pa;IJes to as!ICS:S tbe claun Jriforma froctrsced lfinform11tl on proauccd ln rc:svortte to a su bl fflla is subject ta a clalm of privilege or of profection as trial r,reparatton material ttie person making thi claim nmy notlfy any pa."ty Utat roc 1ved t.hc mfonnation of the lWJ Ille basti for it After being notified a party musi orompdy return or ccstroy tile sooc!tied i11formru:1on 1tnd any copies ti mu,d not use or disclose tile tfoTlJltton untl I the cra1m is resolvea rnust take nllhlc steps to retrieve me mformanoo if the p1u1y disclosed ii before being notifieo and nwy prompUy present tllC mformaoon to tho court under scal for II dc;tonnlfttlOll of the cl1m The person wno produced 1c mfonnanon must preserve the mformat1on un the claim is resolied Contem The 1SSU1ng court may bold in contempt a pet30l1 woo having been scrvecr fajJs without a.oequate cuse to obey me sybpoeu A nonpa,ty 267sfallure to obey must oo excused if the subpoena 265urporls to rcQulre Ille nonpa.rty to a1trnct or oroouce al a iRCt outsick tilt lim11s of Riile A ii AO AA JlAv OJ Sul,DOC1 1tl!Y QI a 0el ll:liti0lI or lo Prodllce Doeurnenls a Civil Act10n Pegn CMl Action No 06-80893CIV-MARRNJOHNSO lOOF OF SERVJCE This mctwn should not be filed with the court unless requrred by fletJ Cfv This subpoena for nan,e c,j frtdivid and Jilk if any wns received by me on dote personally served the subpoena on the individual al piace on do10 left me subpoena at the individuals residern:e or usual place of atiMe with fnmne or a person of suitable age and discretion who resides there on and in ailed a copy to the Individuals as1 known address or served the SUITpoena on of individurd who is designated by law to accept service of process on behalf of nameqforgamzotJOII on du1e returned the subpoena unexecuted becmnc CJ Other JPUfh Unless Ille subpoena was issued on behalf of the Untced States or one ofi1s officers or agents have also tendered to the witness fees for one days attendance arid the mileage allowed by aw in the amount of My fees are for travel and for services for a total of I Leclare under penalty of ix:1j ury that this information Is true Date Ser,u signature Senier add,yJ Additional information regarding attempted servioe etc or Plalntiffi JN THE CIRCUIT COURT OF THE FIPTEENTH JUDICl:Al ClRCUfON AND FOR PAtM:BEACH ouNTY fLORIOA Complex Utlgatlon Fla CJv Pro CASENO on IVVUB U.AMA-il SCOT:J OTH TEIN individually BRA"Ql.E Ef WAAOSi 267tndMdually and fndivldUaUy COPY REOt VEO FOR FlUNG itM Uef41i lnts _QMPJ.t Plaln,flff JE:FFREY EPSTEIN hereinafter nEPSTEIN"t by and through his ul derstgned attomQys flies this action against D.efendants SCOTT ROTHSTEtN tl divldually BRADLEY EOWARDS irtdlvldually and L.M lodMdually Aceordlngly gPSTEIN states S.YMM O.F ACTIO.N Attorney Scott Rothstein aded by oth1;1r lawyers and employees at the firm of Rothstetn Roo 267enfeldt and Adler P.A for personal greed and enrichment in betrayal of th eth1cat legal and fiduciary uties to their own ellent and professional obligations lo the admirilstratlon of Justtce deliberately engaged In a pattern of racketeering that cinvolved staggering series of gravely serious obstructions of justice actionable frauds and he orchestration and conducting of egregious civil lltlgatlon abuses that resulted in profoundly serious Injury to J_effrey Epstein Qne of several targets of their misconduct EXHIBIT I I I i Epstein RRA et al Page2 and others Rothstein 267and RRAs fraud had no boundary Rothstein and his co conspirators fori;Jad Federal court orders and opinions Amongst the violations of law that are th subject cf this lawsuit-are the marketing of non-.exlstentEpstein ttlements nd the sanctioning 0f se depositions.that were m1related to any principled Uttgatft purpose blilt instead designed 1o discover extraneous private info-rmatfon about _.Ep:st.ein or hJs-wrsona1 and bustl:ress 267as.soctates including well-krtown public figures In rder10,deftaud investors an.d pport exto,rtiohate demands for payment from Epstein The misconduct featured the filing of tegaJ mot10ns and the purs1..1lt of a cMI Utlgatlon strategy that wa unretated to ttie mertts or value ofiheir clients cases and instead had as Us improper purpose the furthering of Roths.telns misrepre eli tions and deceit tt,-thlrd party Investors As a result EpsteJn was subject to abustve Investigatory tactics unprlhclpled media attacks and unsupportable legal filings This lawsuit is filed and wm be Vigorou:sty pura-ued against all these defendants The Hothsooln racketeering enterprise endeiavo 267reo to friprcirribethe oora varues of both state and federal Justice tems in South Frorida aiitHo,vlndlcaJe the hardworking and honest lawyers and their clteiits who were adversely affected by tha misconduct that is the subject of this Complaint PlalAtiff resertes the right to add additional defendants co-conspirators as the facts and evidence is developed GENERAL ALLEGATO.NS This is an action for damages In excess of exclusive costs interest and attorneys fees I i Ep teln RAA,.etal Page a Pla ritf ISPStSN is c:fn adult and currently is residing and works in PaJm Beach County Florida Defendant SCOTT ROTHSTEIN CR0THSTEIN is an individual residing in Broward County lortda and was Ucensed to practice law in the State of Florida Ill Nr.wem.ber2009 ROT St:EIN voliJhtarlly r-atlnqufshed his law-license In the,mtdst of the fmptt sto.fr,of RQth in Rosenfeldt and Adler P.A RRA was dlsba1r.ed by the Florida SlW-l"l me Court on November On December ROTHSTEIN 267was arrested and amilgne lln Federal Court In Broward county Floiida At atnlm reievanOreteto ROTHSTEIN was the managing partner and-GEO cf Defendant ROTHSTE1N and Stuart Rosenfeldt are and were 1he prinolpal jwne:rs of e:ep.iy:f.il RRA and each co-founded-RRA Defendant BRADLEY EDWARDS EDWAROS is an lndMdual re.siding In Broward County 267Flor1da and is licensed to practice law tn the State of F1onda At all limes relevar,,t hereto EDWARDS was an employee agent associ te partner sparehold er and/or otherreprcesentatlve of RRA Defendant is an individual residing in Palm ach,County Florida At aJI timel:i ralevant hereto L.M was represented by RRA ROTHSTElN and EDWARDS in a civU lawsuit against Epste1n and was an essential participant In the scheme referenced infra bY among other things substantlaUy changfng prior sworn testimony so as to assist the Defendants in promotin their fraudulent scheme for the i Epstein Rr A et a_l Page4 267promise of a muflRnUilon oonar reoovery relative to the Civi Actions defined below lrwoMntfEi;P teln which was com1:lletely out of proportion to-her alleged d.:ttTiages Non.,par:ty R.RA Is a Florida Professlonal Ser.vice Corporation witl"l __ princlpal addies of East Las Olas Blvd Suite Fort Lauderdale FL ln,addftlon to its tinclpal office RRA also maintained seven offices In Florida New York arid Veneati-ela arn:femployed over70 attomeys and 267support-staff RRAalso maintains a:ri,offi at tt09 Nt2d 267Street HaUendaie Beach Fforlda RRA through Its tlbrnays 267tncludlng those named as Defendants herein conducted 267bustne,s throughout Flonda and relevant to this action conducted busftle and ffled lawsuits on behalf cif clients Palm Beach County Florida RRA is currently a deb.tor In b.1;1:nkroptcy RRA is not named as a Defendant FACTUAL ALLEGATIONS The United states In United States of Amert a Scott Rothstein Case No 603StCR:.Cohr.i United States District Court Somhem District of Floridai has brought an action for Racketeering Conspiracy U.S.C o2 against Seqtt Rothstein who was the chief executive officer and chairman of RRA Within the lnmnnaHGn which was flied the United States ofAmarlca has Identified the enterprjse as belh!iJ lhe Jaw firm RRA through which Rothstein In conjunction with his oo consplrators not yet identified by the USA engaged in the pattern of racketeering through its base of operation at the offices of RRA from sometime In up through and continuing iAto November of Through various criminal acfivltfes lncludin mall fraud wire fraud and money laundering the United States of America asserts that i i I I Epste:m v.:RRA et Rothstein iind his co-conspirators untawfuHy obtafned approximately blk li from investors by ira In connection with a Ponzi schet-na The USA further alleges that D:Rothstein and co-c:onspitators initiated the crlrrilnal oonduet alleged rn the Instant lnformatibn in order ta pel 0nally enrich thernselves and to-supplement the Income and sus tJle dally operation of R.RA In essence In the absen of Rothstein and his co collspiratofs cof.ldueting the Poazf scheme the deliy-opt tJori of RRA Which im;Juded yroll tompen atlon to lawyers staff ainvestlgators tc acoounts pa bfe Jncluding unlimited lmpropeT harassing and potential_ illegal lrivesUgation on cases including Epsteln-:r-elated matters would in all llkeHhood would not have been Ustair:mble A copy of the fnrormattQnis-attached as 267Exh1bit to this,:action As more fuUy set forth herein RRA held itself out a:s legftimate!y and property engaging in the practice of taw ln reality ROTHSTEJN and o1he:ra In RRA weFe using RRA to market Investments as described betowi so as to Mk investors-out ofhtlndreds of milflons of dollars ROTHSTEf and others in RRA devised an elaborate plan through which were sold purported confidential assignments of a structured pay-out settlements supposedly reached on behalf of RRA for clients in exchange for immediate payments to 267these cHents of a discounted lump.sum a:roount Investors-were being promised lh excess of a return on their Investment which was to be paid out to the investors over time While some of the cases relled upon to Induce Investor funding were existing fifed 267cases It Is believed that the confidential structured pay-out settlements were all fabricated Epst1:iln RRA et al Pages Based on meai"a repons Federaf Bureau of Investigation FBI pre conferences ancl re1e and th ln.fonnatton th.e 267.masslve Ponzi scheme and pattern of crimfnal aotlvity me nt to fore investors.began sometime In arid continued.thrcu t-hefaU of the schema was uncovered by some of the Investors and the FBI lw of Nhvember of civn lawsuits were and cootinue to be filed against various efendants result their 267massfv.e.fraUilh,.llen1 antJ r::rlmlnal schema This fraudulent and llfegal lnvwttnent scheme ls aJso evidenced by the filing Amended Comp int For DISSQ/utlon Al,d For Emergency Ttan fero Cotporate Powers to S-tua,t A Rosenfeldt Or In The Altt1Jslive For tlw Ap JO/ntment:;of A Gu:stodien er Receiver by ROSENFELDT aMd RRA against ROTHSTEIN lndlvldually Case No In the Circuit Court of the Seventeenth Judiclal Circuit Broward County Florida Complex Business Oh1 hereinafter dissoluti in action and attached net trras Exbibit:2 Pla1ntlff references the RRA dissolution action for the sole purpose that It ackAowledg!!s that RRA and ROTHSTEIN were in fact conducting an fllegat and Improper investment or Ponzi scheme based on promises of fihaliclal returns from settlements or outcomes of supposed legal a.ctlons Including the actions brought against Plaintiff EPSTEIN The RRA dissolution action alleges In part that RROTHSTEIN the managing partner and CEO of the firm RRA has according to assertions of certain investors allegedly orchestrated a substantial misappropriation of funds from investor trust accounts that made use of the Jaw firms name RRA The investment business created and operated by ROTHSTEJN centered around the sale of Epate1n RRA el al Page7 interests in structured settlements See Prelirrilnary statement of RRA dissolution 267action Exhibit reto tn furtherance of the scheme RRA..s le.tterhead us in commurdcatlons rcgatdlngdny stn;ieM op.po/itiJ:ii,ities Jrt 267pt,1rportea truclured settrements RRN trust a1Zoount was used to-.depo-sit f:1undreds of r:nillfons of-dollars or wire transfer of mc;nies frot dupeiflnvestQt.s,and ottierVlctlms RRA personally guaranteed payments t5i Rofhstelr scheme went so far as to manufacture raise and fmtlduteht Coort opinbnir/or-dera lntjUding foiging 267the signatures of U.S District Judge Kenneth A Judge Susan.H Black Hlh Circuit-in othen;ases it.ls not et koowR if he forged slmiar daoomenl Espteln related malters See Composite E,xhlbit hei:eto The detans of this fraudulent scheme are being reveal_ed on a dally basis through v1;1tiolfS rep.ort:s and court documents The most recent estlm te of the financial soope:of ffie so:heme is that it exceeds billkm dollars R-elevan:tte this-acilian EPST81:N is currently as a defen anttn three clvU acllon alleging inter alla sexual assault and battel that were handled by RM and its attorneys IRcili-dlng EDWARDS prior to its Implosion one of which is filed in federa"J c0urt Jane Doe Epstetn Case No oa U.S.D.C S.D Fla Jane Doe Js a named Defendant herein and two of which have been filed in state court In the Judicial Circuit Court Palm Beach County State of Florida L.M Eps1ein Case No AB E.W Epstein Case No stein RR alak P.age8 AS hereioa:ft-er cotlecftvely referred to as the CMt Actions and fs a n.am Oeferatantl1erein The Clvfl Actions were all fifed In At:1gust and September-of What Is clear rs that a fraudulent and imp per investment or Ponz.Lsoheme was In iact conducted and operate by RRA and certain of the named Defendants which 267:sche:rne:d ctly Impacted EPSiEIN as a named defendantln tlie Civll Actions Ht Mla.ml e,Y,:-i:i"ntiLd61.eibper Alen Sakowifz was quoted In a Nb le;mber aftlcJe:,-as sa nm that h.eicJ with in:August of became suspicious He stated was cenvinced it-was all a Ponzl s,ohe:rne an I notffied the FBl In detaU Mow Scotty ROTHSTEtN wa5 hldln behind a legmmaffi law firm to peddle fake investments Attorney Sakowltz was also quoted as sayhg ROTHSTEIN bad 267sophistiba eavesdtopp1ng equipment and fonner law enforcement officers Who would sift through a potentiat defendants garbage looking for damaaing vldente to 267use with investors show how potential defendants ould be esseoce blackmailed Into paying settlement that far exceeded the value of any legitimate damage clahn Ft Lauderdale a ome.y Wilam Scherer represents multiple Rothstein related Investors He b1dieated,1n an article.that RRNRothstein had used the Epstein Pldy as a-shpWpiece aa balt That-s the way he raised all the money He would use 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 In fac on November William S-cherer on behalf of certain clients filed a page Complaint against ROTHSTEIN David Boden Debra Villegas Andrew Barnett TO Bank N.A Frank E-plteln RR-A etal Psge9 Spinosa Jermifer Kerstetter Rosanna Caretsky and Frank Preve asserting various ailegations that further prove the massive Ponzi scheme behind the RRA fagade and as Nov mber a page Amended Complaint naming additional ttciams:-was,fetli Zt ln,adofflon anch1porrlntormatlon a,nd 1,elief iWTHSTEtN Da Boden Debbie Villegas Antf rew Barnett Michael Flsten and Kenneth Jenne all ernptoyees of RRA through broke or middlemen would stage regular meetittgs during whtch false statements re made about the number of cases/clients that existed or RRA had gainst SP-STEIN and the valt:1e thereof They woold sbbw end snare actual case files ftorn the EP TElN aclions.wlth hedge fund manag rs Thu he attom.eys an cltent hav:e walv any attorney 225ctie.nt or work p.rQduct-prMteges,-tat otherwise m:ay have existed Baca.use potential investors were given access to some of the actual Civil Action fih3s lnvestor--thiid parties 267may have became aware of a name of an existing Plaintiff Who haf Jed 267anonymolil against 267spsw-Jn 267and had opposed dlsclosur of her legal name In all other instances by RRA ROTHSTEIN and EDWARDS claiming the need for anonymity with regard to existing or abrltated clients they were able to effectively use 2671nitial.s Jane Doe or other aoonymoul3 designations wl:iich was a key element in the _fraudulent scheme Ffctitlous names could created to make the investors believe many other cases existed against Epstein _I Ep teln RA tat Page10 1n each of RRAs Civil Actions the Plaintiffs are or were te 267presented by RRA and its attbtneys lticludlng ROTHSTEIN and EDWARDS 2s addi mv.estors were told that ih addition to the Civll Actions another fifty plus 267anoaymous,.fe:male v,ere repres 267snte.d by RRA with the potentiaf tor hundreds miltle,,_ns of dollars in settlements and that RAA and attomeys 267would sue Epstein ool he paid emibttarit.;.seWement amounts to protect h:ls high-profile fi;iends Upon informatlon and bellef EDWAR-OS 267knew or should have known that ROTHSTEtN Was utitmng RRA as a 267front for th massive Ponzt sc:heme and/or were llirtfH ileged iraterestot iilV lment rn Clvil.Acli rnr alld other ciaims involving Ep 267siefn Furthefr evidencing that EDWAAtlS and possibly Other att-omeys of RRA 267knew or should have known and participated in the continuation of the massive Ponzi sobeme a fiont-pag_ Pafm Beach-Post article dated November reported on the re.cent filing of an amended torfetne complatnt by prosecutors agaf nst 225dozens of ROTHSTEJNs reat estate properth:ts for-e!gn cars re5tatnants and other assets 267lricludtng 1-2imillion in the tawyef-s bank account ro Morocoo long with millions rn re donated to 267political campaigns and chaiitabte funds The artic1e 267further reported that Attorney Scott ROTHSTEIN tapped into mHllons of dollars from his massive investment scam to cover payroll costs at his expanding Fort Lauderdale lawfirm federal authorities said in court records released Monday ROTHSTEINs law firm RRA generated revenue of million in one recent year yet his 70:.lawyer law firm had a payroll of million i i ri I i i i i i i ate1n;v stal pa,9 pro euJQi said ROTHSTEtN who owned 267half of RRA used favest rs ffiQney 267fyom-hls Ponzi schem to make up the sho"rtfall 267they satd Subseque.nt artfctes and court filings have reflected ROTHSTEU received com.pensation hi exce1?s of ml!Ron In and nilUlon in while his partn Rosem J9t.teceJve tgreater than 6.mlmon In RQTHSf:ElN attempted to 267lure the entltylmowR as D3 Capital Club by offering opp nity to ITTVesf a pre--suli eoart 267settlement agafr,st EPSTEIN _yet thls suppesed setement never existed and was entirely fabricated to 267augmeat his concocted swr-y ROTHSTEIN upon Information and belief invited to his office to view thfrteen bankers boxes of oase files in Ja-ne Doe one tifh:CMI Actto:ns an.attempt to substantiate-that.the clalms against EPSTEIN er 267legltfma.te 267and that iie eY.ld _nce obtained againM him by RRA ROTH_STEtM and WARDS the litigation Team 267was real Upon lrifQrmation and 267belief ROTHSTEIN and others offered other investors Dke the entity In the Clvil Acl1ons Involving EPSTE1N Fisten a forrner Dade County pollca officer with a questionable police record and RRA inves_tlgaior and Jenne a mtmer attorney 267Broward County She:riff and felon assisted ROTHSTEIN In making 267these offers by providing confidential prtvlleged and work product Information to prospective thlrd--party Investors Jl il tl14::ef e4P,-bt xe4i _,seJzed by the FBJ part of ltS lnvestir,,atfon_,at RA c.;gl"t ls,tm:f lfjU t;ela.JJ.Ag ffia QM ActlonsJnv.oMng EPSTE_!N porterl by eoun 267sel for 1he hkn:t 1:ilfl ritl ote i:ls ean be r-eVle_WM tl a other dlsaovery Epstein wJII ni.it-Rn 9,tbe.:d p.lb1oelfl.e-fiauii:ao,f those lhvolv.ed i i I l:pslelf-1 RRA el al Page By using the Civil Actions against EPSTEIN as balr and fabricating settlements fe9i:,if9ing_ same ROTHSTEJN and others were able to lure investors into ROTHSTEiWS lalr andf-bilke Hhem of mUlions ofdollarswh1cll in tum was ed to fund theilitlgatfon,,agal iff;EPSfi:tN 267for the sote purpose of oontlnuing the ma ive Ponzi scheme:._ As part ofthis scheme ROTHSTEIN and the UUgatlon Team lndMdually and In a CDn rted _e.ffQrt have unethically-and Illegally Sold allowed to be sold and/or assisted witt the sale of lntere In non 267,seted pE!rsonal Injury lawsuits Which are non-iass1gnable and non tra fertlble or sold non-existent structured settlements incJuding those cases.Involving Epst ln Reached agreements to share attorneys fees with non-lawyers Used Investor.money to pay plaintiffs I.e L.M E.W and Jane Do up tront mot:1ey.sueh that plaintiffs would fuse to settle the Civil Acilons Opndueted searches wiretaps or lntetceptetl conversatlons in vlolatton of state or federal laws and Bar rules and UtHized the judicial process incfudlng but not limited to unteasonabfe and unnecessary discovery for the sole purpose of furthering the Ponzi scli:erri"a Af.r,J such actions by ROTHSTEIN and other attorneys Including the litlgation Team,.directltor Indirectly would potentially be a violatfon of various Florida-Bar Rules i I I i i i I i I i i gpsteln RRA et al Pagl;l including,prohibitlng the improper sharing of fees or costs and venous conftlots of Issues rules Evideneing"that the Litigatton Team knew or:shourd have-J nown ofthe lmproper rpose that ROTHSTEIN was pursuing In the CQritlnuatlon of the sctienie ROTH TEiN used RAAs Litigation Team in the EPSTmN cases to purs.qe lssue.s and 267eVtdence iJntelated to 267and unne ssary to the cla1ms pied In the Clvir Actions but sigrnflcantly beneffclal to lure Investors Into the Ponzi scheme orohestrated by ROTHSTEIN and other to-conspirators Upon 267mformation and hellet ROTH-STEIN.and 0ftlers cl TI"Ae tJ:tef irWestlgators discovered that there were hlgh1 rofile lndlvlduals onbb.ar-d Epsteins private jet where se assaults took place and showed D3 and posslb others copies of a flight log purpoii dJy eonta1nlng names of celebrlties dignitaries and lntemationa figures For iRstance th:e Litigation Team relentle sly and knowingly-pursued fllght and passenger marilfe;s:ts regarding flights EPSTE-lN took with:thesa faJJ10Us Individuals knoWing full well that no 1.1nderage women were onooard arid no tlliclt actMUes took place ROTHSTElN and the Litigation Team also 267inappropriately attempted to take the i:lepostlons of these celebrities In a calculated effort to bolster the marketing scam that was taking place One of Plaintiffs counsel EDWARDS deposed three of EPSTEINS pilots and sought fhe deposition of a fourth pflot currently serving in lraq The pilots were deposed by EDWARDS for over twelve hours and EDWARDS never asked one question rehitfng to or about E.W LM and Jana Doe RRA clients as related to i i I i psielh RRA et al transportation on fflghts of RRA cfients on ariy of EP.STElt-tS planes But EOWARDS asked many lnflammatory and leading Irrelevant 267questions about the pilots thoughts arid beliefs which wl never be admissible at trial which could ooly 267have been asked for the putposes of Apumping the case and thus by using the depo_sftions sell the cas,ea ra_part Jlf them to thfrd _pgrtles use Of these facts R.OTHSfttJN cla.1m:ed that Epstein 267wanted to make certain nor,ie of these lndlviduals would be depased and therefore he t,;ad off red to sate-the claims of RRA female cfients variout pc tentlal plaintiffs tn r:tatto11s agalnst EPSTEIN The offer of a mflon dollar settlement by EPSTEfN Wc;lS completely fabricated no such offer had ever-been made OWAROS office also notified Defendant that he ln:tertdad to take the depositions of.and was subpoenaing i Donald Tromp re 267aJ-estate magnate and business mogt.il Alan Dershowttz noted Harvard Law professor constitutional attorney and one of EPSTEINS criminal defenseattomeys i rii B!H 267Clinton Former President of the United states i iv Tommy Mottola fonne President of Sony-Record and David Copperfield illusionist The above-named individuals were friends and acquaintances of EPSTEIN with whom he knew through business or philanthropic work over the years None of the above-named lndlviduals had any connection whatsoever with any of the Litigation Teams clients E.W L.M or Jane Doe Epsteln_v RRA etal Pai,e EDWMOS flied amended-answers to 267tnterrogatorfei tn,;tha s1ate court matters E.W and LM an fisted additionat 267hlgh profile wltnesses 267.t/mtwould 267a11egedly be called at trial lncfuding but-not limited to i Bill Richardson Governor of New Mexico formerly U.S Repres.entative a 267nd.Ambassador to the United Nations and ii My arii:t ljll persons having knowJedge of EPS1EJNS char.itable politieal or other donations 4t the sate purpose of the scheduling-of these d-eposltfons or listing high profile friends/-ecquafntances as potential witness-es was agatn to 225pump the 267cases to investors ThenHs no evidence to date that any of these lndMduats had or have any knowledge 267regatding RRA CIVIi Aotions tn furtherance of their Illegal and fraudulent scheme against ROTHSTE1H EDWARDS who either know or should have known and at times LM tn hefCMI Action against EPSTEIN a Included clailtiS for damages in Jane Does federal action in excess of rather than simply alleging the jutisdldtional lfmlts OrgaAized a Jane Doe TV media interview without any legitimate legal pwrpose other than to upump the federal case for potential These high-profile celebrity 273purported witnesses have no personal knowledge regarding the facts on these Thtee C.eses but were being Qlntacted subpoenaed listed to harass and infimldata lhem end Epstein and to add star appeal the marketing effort of lhe Ponzi scheme Epstein RRA et al Page investors or to prejudice 267Epste1n right to a fair Wal in Palm Beach County cc EDWARDS Berger and Russell A-dler another nam p:artner In RRA alf attended EP.STElWs dep9!!tion At tiJat time outrageotl questions were as:ked of EPStEIN which had no beartng on the cas-e but so that the video and questions could be shown to Investors Conducted and attempted to conduct completely lrrelevant eG ie 267-.lairelaied to the claims 1A or lbfed tter of.the Civil Acllons fer the purpose of hara 260tlijln9 nd embarra 267sstng witnes.ses and EPSTEIN and causing EPSTEIN to spend tens of thq_usands dollars in unneoessaiy attorneys fees and costs defending what.appeared to be-dlscovel related to the Civil Actions but was entir-e!y-wlated to the fYrtharanca Qfthe-Ponz.i ach el AfteT EOWAADS was recruited and o1ned RRA In he spring of the tone and tenor of meto.rlc directed to case against EPSTEIN used by Attorney EDWARDS and Berger changed dramatically in addressing the court on various motions from being substantive oh the facts pied to ridiculously inflammatory nd otind-bite rJch such as the Ju transcript when ated to the Court in E.W./L.M What,the evidence Is really going to show Is that Mr Epstein at least dating back as Epstem RM et at Page far as our Investigation and resources have permitted back to o-r has every stngle day hi life made an attempt to stll 253Jalty abuse chlidren Were not talking about five were not miking about i 267w,lre talking abot.1:t tOO were not talldng about which I beUeve ls 267the ruimbef known to taw enfor:cemea:t we are talldngc:aboutthe1:1sands of ehtldr-er:I and It is througll a very intricate and cornpfrcated,s that he vised where lle has as many aa 2.DJJr,opJe weddng 265rtdero aUl hlm that he is paying Well schedutt Uiese a-ppomtm s,;to Ideate these girls As an example EDWARDS filed an unsupporta and legally deficient Motion for lnjunction Re 242ttafnlng Fraudulent Transfer of Assets A1 Gjntrnent of a R-ecelver,to Tcake.Charge of Property of Epstefn and to Post a million Bond to SeCQre Potential Judgment in Jane Doe Epsteln 267ase No Marra/Johnson The motion was reported In the press as was the ultimate goal i.e to pump the cases for Investor following However the Court founo 225ptaln tr-s 267.moti9n _entirely devoid of evidence and-denied the motion in toto ROTHSTBN told investor.s he had another females that he represented and that Epstein had offered mlon to resolve j?h d?m?ѐ GE x?K?tʯnV Az d,g4 vk;?W h2 T?Ծ?u l?I?ʿ ՊƮ HX T?T 2?aٺ?p 8a??DŦV8 s?M YjO HT??o 1?TZk?z?шS D?P k0 wp?gD?K Ca"??Rt rZ 3_ BTR TWĐ i??喉 kh 2P?H DG MM Chrw?X5?dW qJ D?Gs0?j?M?b i?4s W?g??K?n Zi S?L 4eQׯ6XZӴ?L 春wB?3 cu Rҿڔ_mR?t?G?O?TA?YyKvY i c?W t?z涉?6 z?v?V b_?Z A?h,u I V,?M 짖?g SKi?Cs?W?ڐ?M g荃?Hj?"?M I S?H?P moF N_P?t?G Tw?ť ϗQ?H?u 8i GT;_?m lF CIJS3j خY S?ޕSD?fTp n?ʣ?GiD S?TT Do8?9d Ww MޟCȽ 2o p4 xc e??Z?x UW X?i(F Epstein RRA 267eled Page but that he could settle confidently these cases for mlon separate and apart from hts legal fees ROTHSTEIN end the-L"itlgation Team knew or shoufd have known that-their three flied cases were weak and had rtihilmal value for the foilowlng reason ii i L.M testified-,sh.e never tr.ad any type.of sex with Epstein Worked at numerous strip cfl:lbs is an admltted prostitute and call gkl has a history of Illegal 267drug us-e pot pafnklers xanax Ecstasy and continu lly asserted the Amell_drnent 267during depositions ljf:Ofderto avokfanswering relevant but problem questions for her E.W testified she worked at eleven separate strip clubs iriGludlng Cheetah which RRA presented and in which ROTHSTEIN may have owned an Interest a,:td E.W also worked at PlaUnum Showgirls In Boynton Beach which was the sub ect of a recent police raid where danGers were allegedly selling prescription palnklers and drugs to pustomers and prostituting themselves Jane Doe federal case sef __ million from Epstein She and her attorneys claim severe i i i Epstel RRA et al Paga.19 emoilonal dlstrl3ss as a result of her having voluntarily gone to Epsteins home She testified that there was never omf and or sexual Intercourse nor did she ler touch his genltalla Yet Jane Doe suffered extreme emotional distress wait.prior to meeting Epstein as a result of having witrie.sse fath_er mum.er his girtftli;;nds son She was requfred to give sworn t8 tlmony In that matter and nas admted that she has.lled in sworn testimony Jane Ooe worked at two diffe nt trip clubs including 267Platinum Showgirls In Boynton Beach I Con.duQ E;Jd rfdlculous and Irrelevant dlscoveiy such as subpoenafng rd:s from an alleged sex therapist Dr Leonard Bard rn Massachusetts when the alleged police report reflected that EPSTEIN had only seen a chiropractor In Palm Beach named Dt Bard N0.:-records relating to EPSTEIN exist.ad for this alleged 3eX therapJst Or Bard and the a11eged subpoena for records was just another mechanism to pump the cases for investor appeal Allowed a Second Amended Complaint 1o be flied on behalf of L.M alleging that EPSTEIN forced the minor fnto 225oral sex yet L.M testified that she never engaged In oral anal or vaginal I i i I i f;psb!-hv RRA,--e.t e1I Page20 intercourse wlth EPSTEfN and she had never touched hls genitalia Told Investors as reported fn an Associated Press article that e.br es and other famous peop:ta flown EPSTEIN ne when assaults to-ck place The:refore e.ven though none ro ofRRAs elients claim th flew.of-EPSTEINS planes the t.itl ttori Team sought pUot and plane I Why Agaln to plime 267the Investment pump with new money wlthout 267relevance to the-existing claims made by the RRA clients After EDWARDS joined RRA EDWARDS and former Circuit Jud1e IIUan Berger filed and argued motion to make the Non Pmseootion Agreement NPA beblveen Epstein and USAO public Bllt RRA SIDWARD!fa-nd Berg and their three clients atready had a copy of the NPA They knew what it said and they knew the civil provisions ln the agreement had no impact whatsoever on the three pending Civil Actions The concept behind certain civil provisions in the NPA was to allow an alleged vlctlm to resolve a civil clalrn with Epstein maintain her complete privacy and anonymity and move on with her life As an assistant United States Attorney stated at a hearing in federal court the NPA was not designed to hand them a jackpot or a key to a bank Epstein v.,RRA et al P-aga ROTHSTEtN With the intent and improper motive to magnify his financial gain so 267gifitiliue to fund the fraudulent and Ulegal investment andlor Poli:Z:i schema had EDWARDS demand excas ve moneyirorn EPSTElN tn the Civil:Actions The 267aclloMs described In paragraph above herein had no itlmata purpose in pursuing the QMI Actions against EPSTE1N but rather were m.E?ant to further the fraudulent scheme and crtmlnal activity of ROTHSTEIN so that he and others oould fraudulantly overvalUe the settlement value of the existing and non-existent claims agaitisti;:PSTelN to potential Investors As a r-esult of the fraudulent Investment or Ponzi scheme RRA and its aitQm ys 1n the Civil Actions aga inst EPSTElN may have comprornlserl their olleints 2671nterests ROTHSTEIN and the Litigation Team would have been unable to give uhbfarsed legal counsel because outside tnvestor had been promised a financial int resf.l.tdheoutcome of the actions Additionally if a plaintiff re.ceJVed payments from fiiV merit mohlesiWhlle her action is pending this dearly could impact the plaintiffs decision of wh,ather or ndl to settle the current litigation or shade tnem testimoliY l.a 267cconilit petjUfy to 267galn the greatest return on the investment and to furtherpromotetbe Ponzi Scheme The truthfulness of L.M.s allegatlons and testimony in L.M.s state civil action have been severely compromised by the nee to seek a multi-million dollar payout to help maintain RRAs massive fraud Be ause fictitious settlements oflens of millions of dolfars in cases relating to EPSTEIN were represented to investors in this Ponzi scheme RRA and the attorneys In the Civil Actions needed to create a fiction that Epstein RRA age22 Jncluded extraoltliflciry damages However the 267aetual fads behlfid her action would never support sat:h extraordinary damages Therefore extraordinary meast1res were undertaken to create an entirely-Inflated value of her claims against EPSTEIN a To ugh she he1d he elf out as a vfetim of Epstein she admitted to having rei!Jmed over and over again to hlin C,es_pite her cur nt elaim of ab:Use She has now admitted 1:inder oatll to b.elng a::ea.1l gfr119 cort sin.ca the age of in her deposltJon September mns:crlpt Sbe ed Wet I llved life as a prostite see DT and I am a prostitute when I make tnoney see OT L.M admitted her activity with men other than Epstein bma"l lng a day fron:i-.prostitution on 267maybe more than occasion in-,one year aione OT LM adrriitted under oath io keeping a list of amounts slie collected from Johns in two or three lined books 267rnchJding a book of MPsalrns1 that she obtained from a religious store DT Under the circumstances her claim damages against EPSTEIN one of l.M.s many Johtis dtfring that period would be so incredible and certainly 267not likely to pToduce the extraordinary settlements promised to RRA-s lnvestors In April before she was represented by EOWARDS and RRA l.M ave sworn taped recorded testimony to the agents of the FBf She was represented by a lawyer other than EbWARDS at that statement She-spoke of EPSTEIN in a very positive and frtendly terms and directly contradicted the central allegations on whlch L.M.s cfvil action against Epstein Is now based However onc.e in the hands of Epstetn RRA et al Page23 EDWAAO-S and RRA l.M.s story changed dramatically All a sudden she want-ecf to sue EPSTEIN and like other RRA clients sought tens of minions of dollars a For exampli;J in her sworn statement to fhe P:Bl L.M was insfstent that Jefft-ey is an 267awesi:,rne mani FBI At the ooncluslon of she stated hope Jeffiey nothing happens to Jeffrey because hes an aw me man and it reEi1ly would-ba a shame Ifs a bame that ti las to through this use hes an t1wesom0 guy 225ancf lie didnt do nothing wrong nottUng pp FG.f In faQt L.M spoke so highly of EPSTEIN and 267her rnteracttons with him that the Attomays office Informed a federal court in July tllat the US Attorney could not consider LM a vlctim Yett by September the date on which L.M began her deposition In her civil action and now represented by RRA and EDWARDS l.M new anctf very different tale a.bout puJJ drted sexual misconduct under the supposed Influence of EPSTEIN had been thoroughly rehearsed and her role into the ROTHSTEIN s.carn was complete ln her deposition in her civil action L.M declared that I dont really care about money DT KHe needs time in Jail He doesnt want to be this Is not right for hiin to be on the-streets living daily OT psteln 267RRA et al Page24 d0nt think nw Whole llfe I have ived that shitty llfe because of Jeffrey Epstein OT In her swom FBI testfmony pra EDWARDS and RRA L.M was em:pha"tkl that her Interactions with Epstafn involved no Inappropriate foochlng_iln anyway In fact it was exactly the opposite Old he at any point kiss you t9-ucb 267you show any kind of afleotfon towards you I A Never Ver FBI he never pulled 267you 267clos 267erto him.in a sexualway A wish no never ever ever no never Jeffrey is an awe.some no FBI Yet L.M filed herseoond amended eompl lnt_in Apm after EDWARDS Joined RRA the allegations against EPSTEIN in LM.s compJaint became even more saisclous In paragraph f2 of LM.s Second Amended Gomplalnt LM alleges among other things that Jeffrey Epstein coerced induced or enticed the then minor PlalRtiff to co:mm various acts of sexual misconduct These acts Included but were not limited to fondling and inappropriate and illegal sexual touching of the then mfnor Pfatntf forcing or indueing the then minor plaintiff into oral or other seJCUal m1sconduct Epstein RRA et BL Page2S fu her sworn FB1 statement pre-EDWARDS and RRA LM tastified that Carolyn Andriana the Individual who first broaght LM tQ EPSTEINs home told LM 267make su you beGi;lUSe Jeffrey does.n want any tih9erage gins FBf __ Yet at her September deposltlon now represented EDWARDS and RRA L.M told a very different story My ql!Jeatlon was what did Caroiyn tell you to tell Mr Epstein about-your age A She sald It didnt matter Thats your recollection about what she said Yes she said I remember her saying it doesnt matter Dont worry aboutit DT Pre-.EOWARDS and-RRA LM testified to the FBI aJways made sure I had a fake ID anyways saying that I was a FBI Yet when questioned about her fake ID at her September depo she staiatk Arid did you have a fake ID Have you ever had a fake lD Epsteln A eta Pag A OT In her FBl statement pre-EDWARDS and RA L.M testified abo!it othsrs LM brought to the Epstein home L.M testm 3d th women she brou9ht ta E.P.STEiWs home were eager for opportUnny and-content with their experiences A None of my girls ever had a problem and th call me Theyd me you krJOIJli for to go to Jeffrey hqliJSe beeause they lOV Jeffrey Jefftey-is a respectful man He really ls hmean and he all thought we were of age mways this ts whafs so"sad ab9ut rt PB1 Did any of the gir1s complain about What h1;1ppened after they left there A No You asked me that question No averybooy loved-Jeffrey FBl Every girl that I brought to Jeffrey they said they were fine with lt and Ilka for example E.W another of RRAs clients in the Civil Actions a lot of girls be r_n _to __ pr.Jng tbem back for the money And as far as I know we all had run there FBI I i Epstalh RRA et Eil Pagei.7 Yet with EDWARDS and RM as her attorneys L:M did a 1ao at her September deposij:fon in saying A Once they were there they were scared out of their mind They did It anyways and some/of them walked and said L.M d:_ont v.sr do this to me That was the wot-st thing thi;tt ever llappened to me tDT A And then a Jot of girts weren comfortable OT The above represent only a fe.w of the dramatic changes L.M made in hat tetUmony prior to her represe.ntatltm by EDWARDS/RRA and after she hired ROTHSTEIN EDWARDS and,RRA As a result of the fraudulent Investment or Ponzi scheme L.M may knowingly ve compromised her-aliased interests ih her CMI Action or committed a fraud on the court RRA and the Litr tion Te wok an emotionally driven of facts involving alleged Innocent unsuspecting underage females and a Palm Beach Bilonaim and sought to tum It into a gold mine Rather than evaluating and re olving the cases-based on the merits i.a facts which Included knowledgeable voluntary and consensual actions by each of the claimants and substantial pre-Epstein psychological and emotional conditions of each of the claimants and substantial sexual experiences pre Epstein RRA and the Litigatron Team sought through protective orders and objections to block re1evant discovery regarding their Claimants They Instead forged ahead with discovery the main purpose of which was to pressure Epstein into settling the cases i I i i Epstein RAA etal Fortunately their tactics have not been successfuf As Magistrate Judge Linnea Johnson wrote in a discovery order dated September DE In Federal Case 267indenylng Plaintiffs Motionfor Protectiv Order This js his re.psteln,sJ right The Record in this case ls c:lear that.the childhood of many of the Plainflffs was marred by lns1ahce of abuse and negleqt which in tum may have 267reS11fted In whole or iri part in the damages claimed by the Platri In addftloh in can 6mn1bu Order dated ber DE In Federal Case t9 Magistrate Judge Linnea Johnson wroti;J i!Here the request a.Us.sue goes to the very heart of the Plaintiffs damage claims requesting not only general information relating to Plaintiffs sexual history but fnq iring as to scpei;;iflc Instances wherein Plalnif received Gompensatlon or conslderation for sex acts claim other males sexual assaulted batt red or abuses her aniloi 267-cIi:iim othar males committed I-ewd or lascivious acts on her As a global matter Plaintiffs qlearly and unequivocally place their sexual history ln Issue by their aHegatlons that Epsteins actions in this case has negatively affected their relaUonshfps by among other things distrust in men 225sexual intimacy pr-0oler-ns 225diminished trust social problems problems in personal relattonshlps feeling of stress around men upremature teenage pregnancy antisocial behaviors and 225hyper-sexuality and promiscuity Considering these allegation there simply can be no question that Epstein Is entitled to know whether Plainliffs were molested or the subject of other sexual activity or lewd i I Epste_ln RRA et al Pag_e and tascivi0:us conduct lh oroer to determine whether there is an aUemative bas1 for":tlie_ psychptoQfbal disorders Plalntiffs claim have sustained whether Pl intiff etngaged In prostitutton or other similar type acts and hQw 225certain acts alieged:lri th CQmpiaint materially affected Plaintiffs relationships wltJ:i othets or how tho acts did not hf;!;Ve such an affect on those relatfonships:amtior whether Plaintiffs suffete:d from the alleged emotlollal and psychological disorders as a r.esutt or-other sexual acts prior to the acts allaged in the Comp1alnt To deny E"pstefn tt,QS discovery woufd be tantamount to mtng him fr-om mo_unting a defens ROTHSTEiN EOWARDS and L.M.s actions constitute a fraud upon EPSTEIN as 267RRA ROTHSTEIN 267and the Utfgatlon Team represented-lhemseives to be a.cling In good faith and with the bests IAter sts of their clients In mtnd at aH times when in reality they were 267,actllig ln furtherance of the fnvestment or Ponzi scheme described heretn 267STEt"N justifiably relied to his detriment on the representations of R.RA and Defendants ROTHSTE1H etr WARDS and L.M as to how he condu.cted and.defended the CM1Actions brought against-him As a direct and proximate result of the fraudulent and Illegal Jnvestment or Ponzi schema or.cihestratad by ROTHSTEIN and as yet other unknown co-conspirators and as a r.esult of1he 11tigation tactics undertaken by the Litigation Team and L.M a set forth here-Jn Pfatntlff PSTEIN has incurred and continues to incur the monetary damages Including but not limited to having to pay an amount in excess of the Civil Actions true value as a result of them refusing to settle In that a percentage of any payment by Epstein RRA,.et al Page30 EPSTElN may nave_ been promised to third party investors incurring significant aoctilienal-legal fees end costs as result of Defendants refusal to conduct settlement negotiations in a forthright and good faith manner be-cause any monies pait by EP-eTElN is th reaflty a promlsed return OR an inves.tmetit and inGU!red significant attorneys fees and costs fn defending tne discovery that not relevant material and/ar talcum.tad to lead to the admisslblty of evidence but which wa!l dan for the 267sole puJl Ose of 225-pumplng fbe cases to Investors qPSTEIN has also been Injured in that the sco.pe of the fraudulent and crirnin rae.ketaetlng ctMty sc permeated the RRA iaw firm that EP TEfN has been prev nted from fully and fairly defending the clvll actlans brought agalnst him In essence the very existen of RRA was based on the continuation of the massive Ponzi scheme orehe.stiated by ROTHSTEIN and other co-conspirators In ordet to contlntie to bring In monies from Investors ROTHSTEIN and other ccH;onspirators used theCMt Ac:oons agatnst EPSTEIN along with other manufactured lawsu as a means ofobtaimng masslve amounts of money ROTHSTEIN EDWARDS and L.M are Hable for damages caused to:EPSTEiN lodlviduafly and jointly and severally Eit::;l2 t2 i 7l i 274Ja1mrt fflJ1e-fena nI Plaintiff reaDeges and incorporates paragraphs through as if fully set forth her-ein i I i i I Epstelh RM eli ge RRA ROTHSTEIN EDWARDS rid L.M each and collectively constitute an enterpr se pursuant to Fla Stat ROTHSTEIN EDWARDS and LM engag In a pattern of crlmiha:I activity as defi11ed In and Fla stat As alleged he:reln ROTHSTEIN and EDWARDS commltt-ed multfp1 predicate a.en ln Vlo1ation and Fla Stat lncltiding violations of Florida 267Statutes Ch pter relating to seeur-lties tra:nsa ons Ch ipter relating to fraudulent practices false pretenses and fraud generally which lnclude.s LM Cliapter relating to forgery relating to extonlon which jnoludes l,M and Chapter relating td perjury wh1on Includes L.M Sl,lbstantrally more than two predicate acts the el1ing of or partlefpatloli of the al of 267fabricated settlements outlined herein in 2421odirtg the Clvl Actions involving Epstein as wen as ttie lmpropet lttlga11on tactics outlined above occurred within a flv.e-year:tima period As a direct and proximate rosuJt of ROTHSTEfN EDWARDS aild LM.s violatl ms of Fla Stat EPSTEIN has been Injured Pursuant to Fla Stat Plalntiff 267EPSTEIN Is ei:ititled to threefoJd of his actual damages sustained reasonable altomerfs fees and court oosts and such other damages as allowed by law WHEREFORE Plaintiff EPSTEIN respectfully demands the entry of a judgment for damages against air the,named Defendants i EpstellI RRA et el Page32 Plaintiff realleges and incorporates paragraphs through as If runy 267set ferth herein RRA atong wit ROTHSTEIN EDWARDS E!nd LM each and oollectively constitute an enterprise purs antte FJa stat During alt times relevant hereto ROTHSTEIN EDWARDS an LM war and are associated with the enterprise RRAt and each other De.fendaRts ROTHSTEIN EDWARDS and L.M as persons ass0 lated with the enterprise RRA and each other as an enterprise unlawfully CQnducted or partlcfpated directly or JnttirecUyl in such an enterprtse through a pattern of ra:cketeerlng Flii stat as alle.ged aboV8 herein The breadth and scope of ROTHSTEIN EDWARDS and potentially L.M.s racketeering activity continues to be lnVe:3 267tJ9aled by the FBJ as numerous ciVll lawsuits against some of th.e Defendants and others continue to be flied by persons who have been maged As of th fliing of thts Complainti criminal charges have only been brought against ROTHSTEIN Substa"ritlaUy more than two predicate acts Le tile selling of faprlcated 267ett1ements outlined herein including the Civil Actions imiolvlng Epstein as well as the Improper litigation tactics outlined above occurred within a five year time period Pursuant to Fla Stat ROTHSTEIN and EDWARDS engaged in a pattern of Mraeketeering activity through the commission of crimes as defined In a Fla Stat Including Chapter relating to securities Chapter rel-a-ting to fraudulent practices false pretenses and fraud lnciuding L.M generally pstelt1 R-RA et al Psga.33 Chapter 81.3,.relating to fergery relating to extortlon inciudihg L.M Chapter relatlil po petjury 267Qne 225uding LM Pursuant to Fla Stat Plalntlff seeks the following relief agaln Dew ms kQTHSTElN EDWARDS and L.M a Ordering ROTHSTEtN 267and EDWARDS to divest thems.efves of arw 267lnlet In the enterprtse RRA Enjoin all Defendants from engaging in the same type of conduct pnd ac1Mties as descfibed herein ar:id Temperafity ent:itntng ROTttSTErN EDWARDS and LM from the continuatlOn of the CMI Actfons brought agalhst EPSTEIN until crlmlnal charges have been fonnally brought against RRA and/or any of the Defondants such that EPSTEIN may be altowed to evaluate whether a stay or dismissal of an Civil Actions against him Is merited EPSTEIN furlfuer seeks an award of hJs reasonable attomeys fees and costs and such oth rellefthaUhis Court deems appropriate WHEREFORE Plaintiff EPSTEJN respectfutty demanct the entry of a judgment for the relief sought arid-damages against the named Delendants Count Abuse of Pr icess Against AU Defendants Plaintiff real!eges and Incorporates paragraphs through as if fully set forth herein EpslelA RRA ehl Pa After tnstltutlng the Civil Actions against EPSTEIN the actions of Defendants ROTHSTElN EDWARDS Bnd LM as alleged In paragraphs through herein toAstitute an iUegaJ Improper o.r perverted use of process ROTHSTEIN EOW:AROS and L.M possessed ulterior motives or p!;rrposes fn e.xetclslng Stlch fflegaltilprQp.er or perverted US of pro AS a result of ROTHSTEJN EDWARDS and LrvLs actions EPSTSN suffered damages WHEREFQ PlaihtifH!PSTEIN resp8 tfu!ly demands the entry of a judgment for dama,ges,-agalf.fat aU lhe named Defendants Count IV Fraud Against All Defeodants Plairittff realleges and incorporates paragraphs through as if ruuy forth heJein ROTHSTEIN by and through Defendant EDWARDS and LM mada false statements offact to E:PSTt:lN and his attomi3ys and agen known to be false at the time made and/or intentlonalry concealed materlai information frorn EPSTEIN and h.ls attorneys 267and agents for the purpose of Inducing EPSTEIN to act in relianc::e thereon EPSTE1N did so act on the misrepresentation and/or concealment by incurring additional attorneys fees costs and expenses in aggresli?ively defending the civil actions whereas in reauty because the Civil Actions against Plalntiff were being exploited and over.:iJalued so as to lure ad 1itional investors and to attempt to extort as much money as possible from EPSTEIN so as to continua the massive fraud Epstein RRA.cetat Page WHl:REFORE Plaintiff EPSTEIN 267emands judgment against Defendants for darnage Hncurred and for any other rellefto which,he:is entitled under the Jaw 267consptracyto CommiU:mud Against All D.aferiirants 7G Plaintiff realleges and Incorporates paragraphs througn and and as if ftilly set forth herein ii ROTHSTEIN EOWARb.S and L.M oonsphdtd comltjit a ftatrd 267opon EPSTEiN ROTHSTEIN EDWARDS and L;M combined by and ihrough concerted action as 267deta:lfed hereto to accompllsh an unlawful purpose or ac:complish some purpose by unli:i,wtW-means The unlawfUl_purpose was among other thing ftie tnihestratlng and continuation of the ma sive fraudulent P.onzr schema and receipt of nies for the eontlriuation of the scheme The uhlawful-means Includes but is not Hmlted to the use of the CMl Aciions against EPSTblN In an unlawful Improper and frau.dulentma11ner As a direct and proximate result of ROT-HSTEINT EDWARDS and L.M.s conspiracy to defraud EPSTEIN EPSTEIN suffered damages WHEREFORE Plaintiff EPSTEIN demands ju_qgment against Defendants for dama9es lnourred and for any other relief to which he ls entitled under the Jaw Jury.Ttfa1 Pla1rrtiff-demands Jury Trial c;m all tssues so triable By ROBERT t:RJrtbN JR Florida Epstetn A et Page-38 rcrlt bct 242faw.com MIGHAcL PIK ESQ Florida Ba:i mpike hcif claw:Wm BURll;tAN CRITTON LUTTIER COLEMAN Banyan Blvd Uite WestPalm 267Bee FL Fax 5tU Attom9YSJor Plaintiff I i i UNITED STATES DISTRICT COURT SOUTIIERN DISTRICT OF FLORIDA CASE NO l-CR-COHN UNITED STA TES OF AMERICA Plaintiff SCOTT ROTHSTEIN Defendant PLEA AGREEMENT The United States of America and SCOTT ROTHSTEIN hereinafter referred to as the defendant enter into the folJowing agreement The defendant agrees to plead guilty to the five count Information which charges the defendant in Count with a Racketeering Conspiracy in violation of Title United States Code Section in Count with Conspiracy to Commit Money Laundering in violation of Title United States Code Section in Cowit with Conspiracy to Commit Mail Fraud and Wire Fraud in violation of Title United States Code Section and in Counts and with Wire Fraud in violation of Title I United States Code Section The defendant is aware that the sentence will be imposed by the Court after considering the Federal Sentencing Guidelines and Policy Statements hereinafter the Sentencing Guidelines in an advisory capacity The defendant acknowledges and understands that the Court wilJ compute an advisory sentence under the Sentencing Guidelines and that the applicabJe advisory guidelines will be detennined by the Court relying in part on the results of a Pre-Sentence Investigation by the Courts probation office which investigation will commence after the guilty plea EXHIBITP has been entered The defendant is also aware that under certain circumstances the Court may depart from the applicable advisory guideline range and impose a sentence that is either more severe or less severe than the advisory guidelines range The Court is pennitted to tailor the ultimate sentence in light of other statutory concerns Knowing these facts the defendant understands and acknowledges that the Court has the authority to impose any sentence within and up to the statutory maximum authorized by law for the offenses identified in paragraph and that the defendant may DQ.t withdraw the plea solely as a result of the sentence imposed The defendant also understands and acknowledges that the Court may impose a statutory maximum tenn ofimprisonment ofup to twenty years for each of the offenses set forth in Counts through for a total ofup to one hundred years followed by a tenn of up to three years of supervised release for each offense In addition to a tenn of imprisonment and supervised release the Court may impose a fine of up to with respect to the offenses set forth in Counts and and may impose a fine with respect to the offense set forth in Count of the greater of or twice the value of the property involved in the money laundering transactions The defendant further understands and acknowledges that in addition to any sentence imposed under paragraph of this agreement a special assessment in the amount of with respect to each of the offenses set forth in counts I through for a total of will be imposed on the defendant which will be paid by the defendant at the time of entry of this plea The defendant further understands and acknowledges that in addition to any sentence imposed under paragraphs and of this agreement that restitution may be imposed as part of that sentence The defendant agrees that for purposes of triggering the mandatory restitution provisions of Title United States Code Section the offenses to which the defendant is pleading guilty under this agreement in this case are offenses against property and were committed by fraud and deceit as those terms are understood within Title United States Code Section A ii The defendant accordingly understands and acknowledges that as a result of his plea of guilty pursuant to the terms of the plea agreement in this case the Court may order that he pay restitution pursuant to the provisions of Title United States Code Sections and Promptly following the entry of his guilty plea the defendant agrees to take all necessary steps to make the following property available as partial satisfaction of any restitution order entered in this case a all property subject to the post-Information Protective Order in this matter and all property identified in the Bill of Particulars for Forfeiture The defendant further understands and acknowledges that in addition to any sentence imposed under paragraphs and of this agreement forfeiture may be imposed as part of that sentence The defendant agrees to the forfeiture of all of his right title and interest to all assets listed in the Information and listed in the Bill of Particulars and/or their substitutes hereinafter the assets whether controlled individually or through defendants wholly owned or partially owned corporations or third-parties which are subject to forfeiture pursuant to Title United States Code Sections aX1 and/or a The defendant agrees to assist the United States in achieving forfeiture of the assets and agrees to assist the United States with forfeiture of same such assistance to include truthful testimony especially to the extent that the assets are in the names of corporations or other entities or individuals The defendant knowingly and voluntarily waives any right to a jury trial or any other adversarial proceeding regarding the assets and waives any notification about forfeiture proceedings whether administrative or judicial The defendant further waives any statute oflimitations with respect to the commencement of such forfeiture proceedings or judicial The defendant also waives any defenses to the forfeiture excessive fine or penalty under the Eighth Amendment The defendant also peal of the forfeiture The defendant further acknowledges that the property in whole or in part be used to satisfy any obligation the defendant may have local taxes interest and/or other penalties which may now exist or which ce flee of the United States Attorney for the Southern District of Florida reserves the right to infonn the Court and the probation office of all facts icing process including all relevant information concerning the offenses barged or not as well as concerning the defendant and the defendants nly to the express tenns of any agreed-upon sentencing recommendations ment this Office further reserves the right to make any recommendation as ttity of punishment ited States agrees that it will recommend at sentencing that the Court reduce iiOfY sentencing guideline level applicable to the defendant offense pursuant the Sentencing Guidelines based upon the defendants recognition and acceptance of personal responsibility However the United States will not is sentencing recommendation if the defendant fails or refuses to make 1lete disclosure to the probation office of the circumstances surrounding the 1ct is found to have misrepresented facts to the government prior to ment or commits any misconduct after entering into this plea agreement whether administrativ including any claim of agrees to waive any a forfeited cannot eithei for any federal state may come into existe11 The hereinafter this Offic pertinent to the sentei committed whether background Subject contained in this agree to the quality and quar The Un by three levels the advii to Section of affinnative and timely be required to make th full accurate and com relevant offense condi entering this plea agree including but not limited to committing a state or federal offense or making false statements or misrepresentations to any governmental entity or official The defendant is aware that the sentence has not yet been detennined by the Cow1 The defendant also is aware that any estimate of the probable sentencing range or sentence that the defendant may receive whether that estimate comes from the defendants attorney the government or the probation office is a prediction not a promise and is not binding on the government the probation office or the Court The defendant understands further that any recommendation that the government makes to the Court as to sentencing whether pursuant to this agreement or otherwise is not binding on the Cowt and the Court may disregard the recommendation in its entirety The defendant understands and acknowledges as previously acknowledged in paragraph above that the defendant may not withdraw his plea based upon the Courts decision not to accept a sentencing recommendation made by the defendant the government or a recommendation made jointly by both the defendant and the government In the event that the applicable offense level is deemed by the Court to be or above life the government agrees to not oppose a variance however the Government reserves the right to oppose any sentence recommended by the defendant This agreement resolves the defendants federal criminal liability in the Southern District of Florida growing out of any criminal conduct by the defendant known to the United States Attorneys Office for the Southern District of Florida as of the date of this plea agreement Said provision does not prohibit potential prosecution for any acts of violence presently unknown to the United States The United States agrees that it will not oppose defendants request that the Court recommend to the BWCau of Prisons that the defendant be designated to the lowest security level faciJity deemed appropriate by the Bureau of Prisons The defendant is aware that Title United States Code Section affords the defendant the right to appeal the sentence imposed in this case Acknowledging this and in exchange for the undertakings made by the United States in this plea agreement the defendant hereby waives all rights conferred by Section to appeal any sentence imposed including any restitution order or to appeal the manner in which the sentence was imposed unless the sentence exceeds the maximum pennitted by statute or is the result of an upward departure and/or a variance from the guideline range that the court establishes at sentencing The defendant further understands that nothing in this agreement shall affect the governments right and/or duty to appeal as set forth in Title United States Code Section However if the United States appeals the defendants sentence pursuant to Section the defendant shall be released from the above waiver of appellate rights By signing this agreement the defendant acknowledges that he has discussed the appeal waiver set forth in this agreement with his attorney The defendant further agrees together with the United States to request that the district court enter a specific finding that the defendanCs waiver of his right to appeal the sentence to be imposed in this case was knowing and voluntary The defendant further waives any right to file any motion or make any claim whether under U.S.C or any other provision of law to collaterally attack his conviction his sentence or the manner in which sentence was imposed unless the sentence exceeds the maximum permitted by statute The defendant confinns that he is guilty of the offenses to which he is pleading guilty that his decision to plead guilty is the decision that he has made and that nobody has forced threatened or coerced him into pleading guilty The defendant affirms that he has discussed the matter of pleading guilty in the above-referenced cases thoroughly with his attorney The defendant further affinns that his discussions with his attorney have included discussion of possible defenses that he may raise if the case were to go to trial as well as possible issues and arguments that he may raise at sentencing The defendant additionally affirms that he is satisfied with the representation provided by his attorney The defendant accordingly affinns that he is entering into this agreement knowingly voluntarily and intelligently and with the benefit of full complete and effective assistance by his attorney The defendant accordingly agrees that by entering into this agreement he waives any right to file any motion or make any claim whether under U.S.C or any other provision of law that contests the effectiveness of counsels representation up to the time of the entry of his guilty plea This is the entire agreement and understanding between the United States and the defendant There are no other agreements promises representations or understandings unless contained in a Jetter from the United States Attorneys Office executed by all parties and counsel prior to the change of plea Date Date lfl Date Dare,J/ir/v JEFFREY SLOMAN UNITED STA TES ATTORNEY PAUL SCHWARTZ ASSISTANT UNITED STATES A TIORNEY ASSISTANT UNITED STATES ATTORNEY LaVECCHIO UNITED STATES ATTORNEY TI ROTHSTEIN DEFENDANT STATEMENT OF FACTS The United States of America and SCOTT ROTHSTEIN enter into the following stipulated statement of facts in support of the defendants plea of guilty Had this case proceeded to trial the government would have presented evidence which would have established beyond a reasonable doubt that from in or about through in or about November Defendant ROTHSTEIN conspired with persons known and unknown to the United States Attorney to use the law finn Rothstein Rosenfeldt and Adler P.A hereinafter referred to as RRA as a criminal Enterprise in order to conduct a pattern of racketeering activity Such pattern of racketeering activity included criminal acts which violated mail fraud wire fraud money laundering and conspiracy statutes The government would have presented evidence at trial which would have involved witness testimony and documentary and electronic evidence seized pursuant to a search warrant The governments trial evidence would have established the following Defendant ROTHSTEIN was an attorney admitted to practice law in Florida He was the Chief Executive Officer and Chainnan of RRA In or about Defendant ROTHSTEIN and other co-conspirators initiated a scheme to generate criminal proceeds through fraudulent acts Defendant ROTHSTEIN induced investors through the use of false statements to loan money to himself and fictitious borrowers in return for promissory notes He solicited bridge loans on behalf of purported clients of RRA that ist he would falsely infonn individuals that clients of RRA desired to borrow funds for undisclosed business deals and in return would agree to pay high rates of interest Defendant ROTHSTEIN was aware that no such cJients or requests for business financing actually existed Defendant ROTHSTEIN and co-conspirators also solicited investors to purchase purported confidential settlement agreements Such settlement agreements were falsely presented as having been reached between putative defendants based upon claims of sexual harassment and/or whistle blower actions The investors were falsely infonned that such settlement agreements were pre litigation and therefore there was no pending litigation or court oversight Defendant ROTHSTEIN and other co-conspirators relied upon the purported success of RRA the existence of actual RRA civil matters and his standing in the community to lure potential investors in order to convince them to make such investments The investors were falsely informed that the confidential settlement agreements were available for purchase The purported settlements were allegedly available in amounts ranging from hundreds of thousands of dollars to millions of dollars and could be purchased at a discount and repaid to the investors at face value over time For instance in or about late a potential investor was solicited by Defendant ROTHSTEIN and/or co-conspirators to purchase a purported settlement in the amount of The settlement was alleged to be paid to the purported plaintiff in three installments of each over the course of three months The payment schedule was alleged to insure the confidentiality of the settlement The purported plaintiff allegedly had agreed to accept an immediate payment of in satisfaction of the settlement agreement In order to facilitate the scheme the investor received a fraudulent settlement agreement which set fonh the terms of the civil settlement but the names of the purported plaintiff and defendant were excised due to the alleged confidentiality of the settlement The government would further establish that in order to facilitate and perpetrate the scheme Defendant ROTHSTEIN and co-conspirators created false and fraudulent settlement agreements bank statements assignments of settlement agreements sale and transfer agreements and personal guarantees among other documents Defendant ROTHSTEIN and other co-conspirators falsely infonned investors that the purported confidential settlements were either negotiated on behalf of clients of RRA or had been referred by other law firms The investors were falsely informed that the purported settlements were based upon sexual harassment and/or whistle-blower qui-tam actions against corporate defendants Defendant ROTHSTEIN and other co-conspirators established and maintained trust accounts at several fmancial institutions in order to receive the investor funds and to give the appearance of legitimacy and security False and fictitious trust account bank balance statements were created along with purported lock letters Such letters allegedly reflected that the funds in the trust accounts would be disbursed only to specific investors lnstead funds were disbursed among and between the various trust accounts and elsewhere by interstate wire transfers and other means in order to facilitate promote and conceal the fraud to launder the proceeds derived therefrom and to enrich ROTHSTEIN and his co-conspirators ROTHSTEIN and his co-conspirators created fraudulent on-line banking documents to further mislead investors and to facilitate the fraud Defendant ROTHSTEIN and co-conspirators also initiated and conducted a separate scheme to defraud clients ofRRA in order to perpetuate the Ponzi scheme Such clients had retained RRA to institute and file a civil lawsuit Unknown to the clients RRA settled the lawsuit and had obligated the clients to pay to the defendant In order to perpetrate the fraud and deceive the clientst defendant ROTHSTEIN created a false and fraudulent court order purportedly signed by a Federal District Court Judge which falsely alleged that the clients of RRA had prevailed in the lawsuit and were owed a judgement of approximately million The fraudulent court order also falsely stated that the defendant had transferred funds to the Cayman Isands for the purpose of secreting the assets Defendant ROTHSTEIN and other co-conspirators falsely advised the clients on several occasions that in order to recover the defendant funds they had to post bonds to be held in the RRA trust account Defendant ROTHSTEIN and other co-conspirators fraudulently caused the clients to wire transfer a total of approximately million over several years to a trust account controlled by defendant ROTHSTEIN purportedly to satisfy the bonds Defendant ROTHSTEIN and other co-conspirators were questioned by the clients as to the progress of the alleged lawsuit In order to delay the return of funds to the clients defendant ROTHSTEIN fraudulently created a false Federal court order purportedly issued by a United States Magistrate Judge ordering RRA to return the transmitted funds by a later date Defendant ROTHSTEIN and other co-conspirators utilized funds obtained through the Ponzi scheme to supplement and support the operation and activities ofRRA to expand RRA by the hiring of additional attorneys and support staff to fund salaries and bonuses and to acquire larger and more elaborate office space and equipment in order to promote the ongoing scheme and to enrich the personal wealth of persons employed by and associated with RRA Defendant ROTHSTEIN and other co-conspirators engaged in the below described conduct in order to facilitate the activities of the Enterprise and to conceal and promote the scheme to defraud investors Defendant ROTHSTEIN and other co-conspirators utilized funds illegally obtained through the Ponzi scheme to make political contributions to local state and federal political candidates in a manner designed to conceal the true source of such funds and to circumvent state and federal laws governing the limitations and contribution of such funds Defendant ROTHSTEIN and other co-conspirators distributed lavish gifts including exotic cars jewelry boats loans cash and bonuses to individuals and to members of RR.A in order to engender goodwiJI and loyalty and to create the appearance of a successful law firm Defendant ROTHSTEIN and other co 225conspirators made large charitable contributions to public and private charitable institutions including hospitals and other legitimate charitable and nonprofit organizations using funds derived from the Ponzi scheme Ponzi scheme funds were also used to provide gratuities to high 225ranking members of police agencies in order to curry favor with such police personnel and to deflect Jaw enforcement scrutiny of RRA Defendant ROTHSTEIN and other co-conspirators utilized funds obtained through the Ponzi scheme in order to purchase controlling interests in restaurants located in the Southern District of Florida Such restaurants were used in part as a mechanism to give gratuities to individuals including politicians business associates and attorneys in order to foster goodwill and loyalty as locations to solicit potential investors and as secure locations for conspiratorial meetings Defendant ROTHSTEIN and other co-conspirators associated with well known politicians in public forums and elsewhere in order to gain greater notoriety and to create the appearance of wealth and legitimacy Such acts were calculated in part to enhance defendant ROTHSTEIN and other co-conspirators ability to solicit potential investors in the uponzi scheme Defendant ROTHSTEIN and other co-conspirators used funds derived from the Ponzi scheme to maintain the appearance of affluence and wealth by purchasing expensive real and personal property in order to convince potential investors of the legitimacy of RRA and of the purported investment opportunities Defendant ROTHSTEIN purchased expensive real property personal property business interests vessels vehicles and other indicia of success and wealth The governments evidence would establish that Defendant ROTHSTEIN and co conspirators through the use of RRA as the criminal Enterprise knowingly and intentionally engaged in the above-described pattern of racketeering activity in order to generate proceeds for their enrichment through various criminal activities including mail fraud wire fraud and money laundering The governments evidence would establish that the activities of the Enterprise affected interstate commerce through the transmission of funds among and between financial institutions and across state boundaries among other means The Enterprise maintained offices in Broward County Florida and elsewhere and the pattern of racketeering activity emanated from the Southern District of Florida Investors were solicited through wire and mail transmissions through the United States and elsewhere In order to further the fraud scheme Defendant ROTHSTEIN and other co-conspirators caused to be transmitted wire communications in interstate and foreign commerce including an interstate wire transfer sent from TD Bank to Gibraltar Bank on or about December and an interstate wire transfer sent to TD Bank from JP Morgan Chase on or about October The proceeds derived from the Ponzi scheme were laundered through the accounts maintained at several financial institutions in order to promote cany on and conceal the criminal activities of RRA Had the forfeiture portion of the case proceeded to trial the government would have established at least by a preponderance of the evidence the standard of proof required for sentencing that the properties listed for forfeiture in the forfeiture allegations of the Information and in the Bill of Particulars for Forfeiture were properly sought for forfeiture because the defendant acquired or maintained an interest therein or were derived from proceeds obtained directly and indirectly through the commission of the above.described racketeering activity The government would have further established that the properties were involved in and/or were traceable to the money laundering activity described above and that such properties were also the proceeds of or were derived from the mail and wire fraud activity described above The undersigned hereby stipulate and agree that the aforesaid facts are true and correct and that they encompass all of the necessary elements to establish the guilt of the defendant to the charges of Conspiracy to Violate the RICO Act in violation of Title United States Code Section Conspiracy to Commit Money Laundering in violation of Title United States Code Section Conspiracy to Commit Mail Fraud and Wire Fraud in violation of Title United States Code Section and Wire Fraud in violation of Title United States Code Section Date fo Date Date:X.J,i._/d DaJ.e Date 1-cl JEFFREY SLOMAN UNITED STA TES A ITORNEY PAUL SCHWARTZ SIST ANT UNITED ST ATES A TIORNEY ROTHSTEIN DEFENDANT ATES A TfORNEY SATTORNEY INRE UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION w.flsb.uscourts.gov ROTHSTEIN ROSENFELDT ADLER P.A Debtor CASE NO CHAPTER I PRIVILEGE LOG FARMER JAFFE WEISSING EDWARDS FISTOS LEHRMAN Dated February Total of pages EXHIBITQ Privilege Log Dated Farmer Jaffe Weissing Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Spencer Kuvin Transcript of Alfredo Rodriguez Joint W/P Priv Deposition Bradley Edwards Katherine Ezell WPB-Confidential-General Joint W/P Priv Financial Disclosure/Discovery Bradley Edwards Amy Ederi WP B-Ge neral--Confid ential Joint W/P Prlv Bradley Edwards Kikka Claudio C.M.A vs Epstein et Joint W/P Priv al File Bradley Edwards Paul Cassell Report this as a parole violation Joint W/P Priv Bradley Edwards Margaret Berk Scanned document from Joint W/P Priv Margaret Berk Bradley Edwards Katherine Ezell Subpoena directed to the Joint W/P Priv investigators Adam Horowitz Jacquie Johnson Epstein-Depa-New York Joint W/P Priv Bradley Edwards Spencer Kuvin RE:Transcript of Alfredo Joint W/P Priv Rodriguez Deposition Bradley Edwards Mercedes Estrada RE:Epstein vs Jane Doe Joint W/P Priv Epstein vs Jane doe No Bradley Edwards Spencer Kuvin RE Epstein Depo Joint W/P Priv Adam Horowitz Jacquie Johnson Trump Depo moved to Joint W/P Priv in NY Jacquie Johnson Kikka Claudio FW Out of state subpoenas Joint W/P Priv Adam Horowitz Jacquie Johnson RE:Epstein-Letter regarding Joint W/P Priv Leslie Wexner Privilege Log Dated I I I I Farmer Jaffe Weissin.e Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Adam Horowitz Jacquie Johnson RE Epstein-Notice of production Joint W/P Priv from non parties/depo of Jane Doe Bradley Edwards Katherine Ezell RE Leslie Wexner Joint W/P Priv Bradley Edwards AmyEderi FW Epstein Depo Joint W/P Priv Bradley Edwards Katherine Ezell RE Leslie Wexner Joint W/P Priv Bradley Edwards Katherine Ezell FW:meeting atty fr wexner Joint W/P Priv Bradley Edwards Stuart Mermelstein Meeting w/LesJie Wexner Joint W/P Priv Adam Horowitz Jacquie Johnson Depo Joint W/P Priv Adam Horowitz Jacquie Johnson Epstein-de po of Alan Oershowitz Joint W/P Priv Bradley Edwards Stuart Mermelstein Leslie Wexner Joint W/P Priv Bradley Edwards Amy Ederi RE:Regular Monthly Cong Call Joint W/P Priv Bradley Edwards Katherine Ezell RE:Regular Monthly Cong Call Joint W/P Priv Bradley Edwards Spencer Kuvin RE:Epstein commissioner Joint W/P Priv appointees Bradley Edwards Katherine Ezell Possible witness from Joint W/P Priv Switzerland Katherine Ezell Bradley Edwards RE:Article:Bear Stearns Joint W/P Priv Privilege Log Dated I I I I Farmer Jaffe Weissin2 Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Katherine Ezell Bradley Edwards Article:Bear Stearns Joint W/P Priv Amy Ederi Bradley Edwards Artide:Bear Stearns Joint W/P Priv Katherine Ezell Bradley Edwards USAO Chose Bradley Edwards Joint W/P Priv conversation Stuart Bradley Edwards RE:Epstein Depo;possible Joint W/P Priv Mermelstein deponents Katherine Ezell Bradley Edwards Discussion about possible Joint W/P Priv witness from Switzerland Spencer Kuvin Bradley Edwards FW:Transcript of Alfrefo Joint W/P Priv Rodriguez Depa and Copperfeild and Clintons whereabouts Mercedes Bradley Edwards RE:Epstein vs.Jane Doe Joint W/P Priv Estrada Adam Horowitz Bradley Edwards RE:Motion for protective Joint W/P Priv order/discussion Spencer Kuvin Bradley Edwards Discussion RE:Wexner Joint W/P Priv involvement Katherine Ezell Bradley Edwards Wexner served subpoena OH Joint Priv Katherine Ezell Bradley Edwards RE:Leslie Wexner Bob Joint W/P Priv Spencer Kuvin Bradley Edwards RE:Meeting w.Stanely Arkin Joint W/P Priv Adam Horowitz Bradley Edwards RE:Epstein;larry Visoski Joint W/P Priv confirmed Stuart Bradley Edwards RE:Leslie Wexner attorney info Joint W/P Priv 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Attachment:KeUen Trump Joint W/P Priv subpoena Bert Patton Jacquie Johnson RE:Epstein Depo-New York Joint Priv Mercedes Jacquie Johnson Trump and Maxwell Dep dates Joint Priv Estrada Adam Horowitz Jacquie Johnson RE:Epstein Depos in Joint W/P Priv NY OH Adam Horowitz Jacquie Johnson Maxwell,Trump Wexner convo Joint W/P Priv RE:Depo dates Adam Horowitz Jacquie Johnson Maxwell Trumo Wexner Convo Joint W/P Priv RE:Depo dates cont Stuart Bradley Edwards Wexler Lawyers info Joint W/P Priv Mermelstein Adam Horowitz Jacquie Johnson Epstein Depo-NY;2 Attachments Joint W/P Priv Adam Horowitz Jacquie Johnson Epstein Depos in Joint W/P Priv NY OH/PDF of Sarah Kellen Notice of Videotaped Depa Kikka Claudio Jacquie Johnson Depo subpoena notice for Joint W/P Priv Trump Jacquie Johnson Mercedes Estrada RE:Alan Dershowitz;Harvard Law Joint W/P Priv Info Jacquie Johnson Katherine Ezell RE:Epstein-Depos of Marcinkova Joint W/P Priv Sarah Kellen Adam Horowitz Jacquie Johnson RE:Esptein-Notice of Prodcution Joint W/P Priv from Non Parties Jacquie Johnson Katherine Ezell Notice Of Production from Non Joint W/P Priv Parties discussion Privilege Log Dated Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Adam Horowitz Jacquie Johnson Crittons notice of depo;Epstein Joint W/P Priv notice of hearing,Mark Epstein notice of depo Katherine Ezell Bradley Edwards Epstein Joint W/P Priv Jacquie Johnson Mercedes Estrada RE:Epstein Depo Joint W/P Priv Jacquie Johnson Katherine Ezell RE:Deposition of Jean Luc Joint W/P Priv Bruhnel Jacquie Johnson Adam Horowitz RE:Epstein Depo Joint W/P Priv Jacquie Johnson Margaret Berk Epstein Depos Joint W/P Priv Jacquie Johnson Lisa Rivera FW:Deposition of Jean Luc Joint W/P Priv Bruhnel Jacquie Johnson Lisa Rivera Depo of David Hart Rogers Joint W/P Priv Jacquie Johnson Katherine Ezell FW:Meeting w/SranJey Arkin Joint W/P Priv Jacquie Johnson Mercedes Estrada RE:Jane Does Epstein-Cross Joint W/P Priv Nods of Oct depos Jacquie Johnson Mercedes Estrada RE;Epstein-Depo for Joint W/P Priv Jacquie Johnson Mercedes Estrada RE:Epstein-Depo for Joint W/P Priv Jacquie Johnson Kikka Claudio RE:Epstein Depo-New York Joint W/P Priv Jacquie Johnson Adam Horowitz RE:Epstein Depositions for Joint W/P Priv in NY OH Privilege Log Dated I I I I Farmer Jaffe Weissintz Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Jacquie Johnson Kikka Claudio RE Ms Maxwell Depa Joint W/P Priv rescheduled Bradley Edwards Kikka Claudio FW:out of state subpoenas Joint W/P Priv Jacquie Johnson Kikka Claudio RE:out of state subpoenas Joint W/P Priv Jacquie Johnson Kikka Claudio RE:Epstein Joint W/P Priv Jacquie Johnson Kikka Claudio RE:Epstein Joint W/P Priv Jacquie Johnson Kikka Claudio FW:Epstein Depo Notices Subs Joint W/P Priv Jacquie Johnson Kikka Claudio RE:Epstein Depo-New York Joint W/P Priv Adam Horowitz Jacquie Johnson RE:Epstein-Depo of Mark Epstein Joint W/P Priv on in NY will take place as scheduled Jacquie Johnson Kikka Claudio RE:Epstein Depo-New York Joint W/P Priv Jacquie Johnson Adam Horowitz RE:Epstein Depositions Joint W/P Priv in NY OH Adam Horowitz Jacquie Johnson Epstein Hearing Joint W/P Priv Spencer Kuvin Jacquie Johnson RE Epstein-Deposition of Jane Joint W/P Priv Adam Horowitz Jacquie Johnson Epstein Depo Notices and Subs Joint W/P Priv Kikka Claudio Jacquie Johnson RE:Epstein Depo Joint W/P Priv Privilege Log Dated Farmer Jaffe Weissimr Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Adam Horowitz Jacquie Johnson RE:Epstein Depo Joint W/P Priv Margaret Estrada Jacquie Johnson Alan Dershowitz Joint W/P Priv Katherine Ezell Jacquie Johnson RE:Depo Joint W/P Priv Adam Horowitz Jacquie Johnson RE:Deposition of Jean Luc Joint W/P Priv Bruhnel Adam Horowitz Jacquie Johnson RE:Epstein Depo Joint W/P Priv Adam Horowitz Jacquie Johnson RE:Epstein Depo of Mark Epstein Joint W/P Priv Spencer Kuvin Jacquie Johnson RE:Epstein Sub to Bear Stearn Joint W/P Priv Margaret Berk Jacquie Johnson RE:Epstein Depos Joint W/P Priv Katherine Ezell Jacquie Johnson RE:Epstein-Depos of Marcinkova Joint W/P Priv Sarah Keller Adam Horowitz Jacquie Johnson RE:Epstein Joint W/P Priv Lisa Rivera Jacquie Johnson RE:Depo of David Hart Rogers Joint W/P Priv Adam Horowitz Jacquie Johnson RE:Epstein-Notice of Production Joint W/P Priv from Non Parties Margaret Berk Jacquie Johnson RE:Epstein depos Joint W/P Priv Katherine Ezell Jacquie Johnson RE:Epstein-Notice of Production Joint W/P Prlv from Non Parties Privilege Log-Dated I I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Adam Horowitz Jacquie Johnson Depo Joint W/P Priv Spencer Kuvin Jacquie Johnson RE:Epstein Joint W/P Priv Kikka Claudio Jacquie Johnson RE:Epstein depos on Joint W/P Priv Kikka Claudio Jacquie Johnson RE:Epstein depos on Joint W/P Priv Bradley Edwards Mercedes Estrada FW:Epstein-Confirming AT Joint W/P Priv Dial Telephone Conference for Mon at p.m Jacquie Johnson Spencer Kuvln FW:Epstein-Depos of Joint W/P Priv Marcinkova Sarah Kellen Adam Horowitz Jacquie Johnson RE:Epstein Sub to Bear Sterns Joint W/P Priv Jacquie Johnson Spencer Kuvin FW Epstein-Depos of Joint W/P Priv Marcinkova Sarah Kellen Spencer Kuvin Bradley Edwards RE:Actvity in Case Joint W/P Priv Doe Epstein Order on Motion to Stay Paul Cassel Bradley Edwards FW:Epstein Joint W/P Priv Adam Horowitz Bradley Edwards FW Motion to Dismiss Joint W/P Priv Susan Stirling Katherine Ezell RE:WPB-Confidentlal-Genereal Joint W/P Priv Financial Disclosure/Discovery Bradley Edwards Spencer Kuvin FW:Subpoena Info Joint W/P Priv Bradley Edwards Katherine Ezell FW:Meeting w/Stanley Arkin Joint W/P Priv Privilege Log Dated Farmer Jaffe Weissine Edwards Fistos Lehrman I BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Kikka Claudio FW:Proposal Request Joint W/P Priv Bradley Edwards Katherine Ezell FW:Meeting w/Stanley Arkin Joint W/P Priv Bradley Edwards Amy Ederi FW:Epstein Depa Joint W/P Priv Adam Horowitz Jacquie Johnson RE:Epstein-Notice of Production Joint W/P Priv from Non Parties Spencer Kuvin Bradley Edwards RE:Epstein Joint W/P Priv Bradley Edwards Katherine Jacquie FW:Meeting w/Stanley Arkin Joint W/P Priv Johnson Bradley Edwards Amy Ederi FW:Epstein Depa Joint W/P Priv Adam Horowitz Jacquie Johnson RE:Epstein Joint W/P Priv Adam Horowitz Jacquie Johnson RE:Epstein Joint W/P Priv Jacquie Johnson Jack Hill RE:Epstein Joint W/P Priv Jacquie Johnson Katherine Ezell RE:Epstein Joint W/P Priv Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv Privilege Log Dated I I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTlON OBJECTION Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv Bradley Edwards Katherine Ezell RE:Epstein Joint W/P Priv Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv Bradley Edwards Adam Horowitz RE:Epstein Joint Priv Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv Bradley Edwards Kikka Claudio RE:Epstein Joint W/P Prlv Jacquie Johnson Margaret Berk RE:Epstein Joint W/P Priv Bradley Edwards Spencer Kuvin RE:Epstein Joint W/P Priv Bradley Edwards Adam Horowitz RE:Epstein Joint W/P Priv Bradley Edwards Kikka Claudio RE:Epsteln Joint W/P Priv Privilege Log Dated I I I I Farmer Jaffe Weissin2 Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJEClION Bradley Edwards Carolyn Edwards Brian Ryalls Joint Priv BradleyEdwards Kikka Claudio RE:Regarding:C.M.A vs Epstein Joint W/P Priv Et al File Bradley Edwards Amy Ederi RE:Regular Monthly Cong Call Joint W/P Priv Jessica Caldwell Bradley Edwards RE:Release Joint W/P Priv Bradley Edwards Katherine Ezell RE:Meeting w/Stanley Arkin Joint Priv Bradley Edwards Katherine Ezell RE:Jane Doell Epstein Joint W/P Priv Bradley Edwards Stuart Mermelstein RE:Jane Doe II Epstein Joint W/P Priv Bradley Edwards Katherine Ezell RE:Jane Doe II Epstein Joint Priv Bradley Edwards Mercedes Estrada Re:Jane Doe No Jane Doe Joint W/P Priv No vs Epstein-Cross Notice Of Depos Bradley Edwards Mercedes Estrada RE Jane Doe Jane Doe Joint W/P Priv vs Epstein Bradley Edwards Mercedes Estrada RE Jane Doe Jane Doe Joint W/P Priv vs Epstein-Cross-Notice of Taking Video Deposition Bradley Edwards Adam Horowitz RE:Epstein Joint W/P Priv Bradley Edwards Kikka Claudio RE lgor Zinoview depo Joint W/P Priv Bradley Edwards Robert Josefberg RE:Epstein Joint W/P Priv Privilege Log Dated I I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Jack Hill RE Igor Zinoview depo Joint W/P Priv Bradley Edwards Kikka Claudio RE:Epstein Joint W/P Priv Kikka Claudio Bradley Edwards RE:Epstein Joint W/P Priv Spencer Kuvin Bradley Edwards RE:FYI Epstein Depa Joint riv Bradley Edwards Spencer Kuvin RE:FYI Epstein Depa Joint W/P Priv Spencer Kuvin Bradley Edwards RE:FYI Epstein Depo Joint W/P Priv Spencer Kuvin Bradley Edwards RE:FYI Epstein Depa Joint W/P Priv Spencer Kuvin Bradley Edwards RE:FYI Epstein Depo loint Priv Spencer Kuvin Bradley Edwards RE:FYI Epstein Depa Joint W/P Priv Katherine Ezell Bradley Edwards FW:Epstein Joint W/P Priv Katherine Ezell Bradley Edwards RE:Epstein Joint W/P Priv Adam Horowitz Jacquie Johnson RE:Epstein-Notice of Production Joint W/P Priv from Non Parties Bradley Edwards Katherine Ezell RE:Epstein Cases-depostions in Joint W/P Priv federal cases BATES DATE TO FROM DESCRIPTION OBJECTION Brad Edwards Katherine Ezell June hearing-WPS Joint-privilege Confidential Amy Ederi Brad Edwards June 25th hearing-WPS Joint-privilege Privilege Log Dated I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Confld enti a I Bradley Spencer Kuvin L.M Epstein defendant Joint-privilege Edwards Jeffrey Epsteins response to plantiff Bradley Katherine Ezell Leslie Wexner Joint-privilege Edwards Stuart Bradley Edwards Leslie Wexner Joint-privilege Mermelstein Bradley Katherine Ezell Leslie Wexner Joint-privilege Edwards Robert Bradley Edwards Epstein Joint-privilege Josefsberg Spencer Kuvin Bradley Edwards Epstein Joint-privilege Adam Horowitz Bradley Edwards Epstein Joint-privilege Spencer Kuvin Spencer Kuvin Bradley Edwards Epstein Joint-privilege Spencer Kuvin Bradley Edwards Epstein Joint-privilege Adam Horowitz Bradley Edwards Epstein Joint-privilege Stuart Mermelstein Adam Horowitz Bradley Edwards Epstein Joint-privilege Bradley Spencer Kuvin LM EPSTEIN hearing Edwards Spencer Kuvin Bradley Edwards LM EPSTEIN hearing Joint-privilege Bradley Spencer Kuvin LM EPSTEIN hearing Joint-privilege Edwards Adam Horowitz Bradley Edwards Mark Epstein Joi nt-prlvilege Bradley Spencer Kuvin Meeting with Stanley Arkin Joint-privilege Edwards Stuart Katherine Ezell Meeting with Leslie Wexner Joint-privilege Mermelstein Robert Josefsberg Privilege Log Dated I I I I Farmer Jaffe Weissimr Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Robert Katherine Ezell Meeting with Stanley Arkin Joint-privilege Josefsberg Bradley Katherine Ezell Meeting with Stanley Arkin Joint-privilege Edwards Spencer Kuvin Bradley Edwards Meeting with Stanley Arkin Joint-privilege Katherine Bradley Edwards Meeting with Stanley Arkin Joint-privilege Ezell Robert Spencer Kuvin Meeting with Stanley Arkin Joint-privilege Josefsberg Bradley Robert Meeting with Stanley Arkin Joint-privilege Edwards Josefsberg Adam Horowitz Bradley Edwards Motion for protective order Joint-privilege Bradley Kikka Claudio Proposal Request Joint-privilege Edwards Katherine Bradley Edwards Regularly Monthly Cong Call Joint-privilege Ezell Bradley Adam Horowitz Report this as a parole violation Joint-privilege Edwards Adam Horowitz Bradley Edwards Report this as a parole violation Joint-privilege Bradley Spencer Kuvin Sarah Kellen Joint-privilege Edwards Spencer Kuvin Jacquie Johnson Sarah Kellen Joint-privilege Katherine Bradley Edwards Subpoena directed to the Joint-privilege Ezell investigators Bradley Spencer Kuvin Subpoena Info Joint-privilege Edwards Adam Horowitz Elizabeth Villar Epstein Forensics/Investigations Joint-privilege INVOICE Richard Willits Bradley Edwards Epstein Investigator Joint-privilege Adam Horowitz Bradley Edwards Epstein Investigator Joint-privilege Bradley Lisa Rivera Alfredo Rodriguez Joint-privilege I f??f Nb bM?nN Zb wZ_ aƭ vA S??m G??k S?lyNs K9 k?E s??b We?Fk?F F??r F?Y Lh EPg e7 Нa?vg 4M Ed 0R a?b 8T ύ??M G9 dZݑ?N?XүP ls AG?e?K f?Ҥ0 颋?ݳD V?Y:?k?a Er?ɐF YD?X?T yf 3ht?F?r I2?M?uM?q??Ҕ q?:?јg/d u?K V0?ڱQAE Fd hL o?t ƛ0ts?El oH MkXg X?z L-y ᑺ?o a Q?e?B Ig l?p-?g љ0 F?އ9u 6?nU 6x m8U H?x b?P??h bE"?Ԩ 赏P Y3 X??B ao q??k R?s1 gz?b 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bv2?h_ 8ZX i??뙛TDH?C D2 l?IJ R?w B?P Lu??IQ m?VQx FP z4X c??z P??fҘ 鈒?if sF?1 W?s?f Privilege Log Dated I I I Farmer Jaffe WeissinJ Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJEOION Edwards Adam Horowitz Margaret Berk Correct Number Epstein Joint-privilege Deposition Bradley Mercedes Doe Epstein Joint-privilege Edwards Estrada Katherine Bradley Edwards E.W L.M Doe Epstein Joint-privilege Ezell Letter from Bob Critton Robert Bradley Edwards E.W L.M Doe Epstein Joint-privilege Josefsberg Letter from Bob Critton Spencer Kuvin Bradley Edwards Emailing Epstein deposition Joint-privilege revised Bradley Amy Ederi Epstein Confirming AT Dial Joint-privilege Edwards in Tel Cont for Monday at p.m Spencer Kuvin Bradley Edwards Epstein Hearing Joint-privilege Spencer Kuvin Bradley Edwards Epstein Depo New York Joint-privilege Bradley Amy Ederi Epstein Depo Joint-privilege Edwards Adam Horowitz Bradley Edwards Epstein Matter Cross Notice of Jo int-privilege Alfredo Rodriguez Deposition Bert Patton William Berger Epstein State of Florida Joint-privilege Emergency petition for Writ of Certiorari Emergency motion to review denial of stay Bradley Mercedes Epstein Joint-privilege Edwards Estrada Bradley Spencer Kuvin Epstein Joint-privilege Edwards Mercedes Susan Stirling Hearing taken on Joint-privilege Estrada onmotion to unseal before Judge Colbath Spencer Kuvin Katherine Ezell Hearing to Un-seal Joint-privilege Jack Hill Bradley Edwards Igor Zinoview depo Joint-privilege Privilege Log Dated I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Mercedes Jane Doe II Epstein Joint-privilege Edwards Estrada Bradley Lisa Rivera Jane Does Epstein Joint-privilege Edwards Bradley Adam Horowitz Jeffrey Epstein DC Joint-privilege Edwards Spencer Kuvin Bradley Edwards L.M Epstein Defendant Joint-privilege Jeffrey Epstein"s Response to Plantiff L.M."s Motion for Protective Order Spencer Kuvin Bradley Edwards LM EPSTEIN hearing Joint-privilege Bradley Katherine Ezell Meeting with Leslie Wexner Joint-privilege Edwards Adam Horowitz Bradley Edwards NEW ASSIGNMENT NEW Joint-privilege ALBANY RUSH Fwd Federal Subpoena Bradley Kikka Claudio Out of state subpoenas Joint-privilege Edwards Bradley Kikka Claudio Proposal Request Joint-privilege Edwards Bradley Adam Horowitz Report this as a parole violation Joint-privilege Edwards Spencer Kuvin Bradley Edwards Subpoena Info Joint-privilege Spencer Kuvin Bradley Edwards Transcript of Alfredo Rodriguez Joint-privilege deposition Bradley Spencer Kuvin Hearing to Un-seal Joint-privilege Edwards Adam Horowitz Jacquie Johnson Motion to stay Joint-privilege Bradley Adam Horowitz Mark Epstein Joint-privilege Edwards Bradley Stuart Mermelstein Meeting with Leslie Wexner Joint-privilege Edwards Adam Horowitz Bradley Edwards Epsteins assets Joint-privilege Privilege Log Dated I I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Adam Horowitz EPSTEIN Joint-privilege Edwards Adam Horowitz Bradley Edwards Activity in case Joint-privilege KAM Doe Epstein Response in Opposition to Motion Bradley Adam Horowitz Activity in case Joint-privilege Edwards KAM Doe Epstein Response in Opposition to Motion Bradley Spencer Kuvin Activity in Case Joint-privilege Edwards KAM Doe Epstein Order on Motion to Stay Bradley Spencer Kuvin Activity in Case Joint-privilege Edwards KAM Doe Epstein Order to Motion to Stay Bradley Spencer Kuvin BB Epstein/EW Epstein Joint-privilege Edwards Jacquie Johnson William Berger BB Epstein/EW Epstein Joint-privilege Bradley Katherine Ezell Bill Rileys Subpoena Depo Joint-privilege Edwards Notice Bradley Adam Horowitz Can you send me those Joint-privilege Edwards addresses Bradley Spencer Kuvin CMA depo notices attached Joint-privilege Edwards Stuart Bradley Edwards Continuing Deposition of Alfredo Joint-privilege Mermelstein Rodriguez Katherine Bradley Edwards Deposition of Bill Riley Joint-privilege Ezell Adam Horowitz Jacquie Johnson Deposition of Jean Luc Bruhnel Joint-privilege Bradley Jack Hill Igor Zinoview depo Joint-privilege Edwards Bradley Adam Horowitz Jane Does Epstein Joint-privilege Edwards Katherine Bradley Edwards Leslie Wexner Joint-privilege Privilege Log Dated I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Ezell Bradley Stuart Mermelstein Leslie Wexner Joint-privilege Edwards Bradley Mercedes Preservation of evidence Joint-privilege Edwards Estrada Sid Garcia Bradley Edwards l.M Epstein Joint-privilege Richard Willits Bradley Edwards Scheduling various depositions Joint-privilege regarding Epstein Bradley Katherine Ezell FYI Joint-privilege Edwards Spencer Kuvin Bradley Edwards FYI Joint-privilege Spencer Kuvin Bradley Edwards FYI Joint-privilege Katherine Bradley Edwards FYI Joint-privilege Ezell Bradley Spencer Kuvin FYI Joint-privilege Edwards Spencer Kuvin Bradley Edwards Hearing to Un-seal Joint-privilege Bradley Robert Hearing to Un-seal Joint-privilege Edwards Josefsberg Bradley Kikka Claudio Igor Zinoview Tommy Matola Joint-privilege Edwards depos Bradley Kikka Claudio Igor Zinoview depo Joint-privilege Edwards Jack Hill Bradley Edwards Igor Zinoview depo Joint-privilege Bradley Jack Hill Igor Zinoview depo Joint-privilege Edwards Bradley Stuart Mermelstein IMEs Joint-privilege Edwards Bradley Stuart Mermelstein IMEs Joint-privilege Edwards Stuart Bradley Edwards IMEs Joint-privilege Mermelstein Katherine Bradley Edwards Is Mark Epstein JEs brother Joint-privilege Privilege Log Dated I I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Ezell Adam Horowitz Bradley Edwards Is your client being deposed Joint-privilege tomorrow Bradley Margaret Berk Jane Doe Brinson Epstein Joint-privilege Edwards Bradley Spencer Kuvin Jane Doe II Epstein Joint-privilege Edwards Spencer Kuvin Bradley Edwards Jane Doe II Epstein Joint-privilege Bradley Katherine Ezell Jane Doe II Epstein Joint-privilege Edwards Bradley Stuart Mermelstein Jane Doe II Epstein Joint-privilege Edwards Adam Horowitz Bradley Edwards Jane Does Epstein Joint-privilege Spencer Kuvin Jacquie Johnson Jane Does Epstein Cross Joint-privilege NOOs of Oct depos Bradley Adam Horowitz Jeffrey Epstein DC Joint-privilege Edwards Adam Horowitz Jacquie Johnson Maxwells deposition Joint-privilege Kikka Claudio Jacquie Johnson Maxwells deposition Joint-privilege Robert Jacquie Johnson Meeting with Stanley Arkin Joint-privilege Josefbergs Spencer Kuvin Jacquie Johnson Epstein Depo New York Joint-privilege Bradley Katherine Ezell Meeting with Stanley Arkin Joint-privilege Edwards Bradley Katherine Ezell Meeting with Stanley Arkin Joint-privilege Edwards William Berger Spencer Kuvin Ew cert.4 dca Joint-privilege Bradley Katherine Ezell Hearing to Un-seal Jolnt-privllege Edwards Adam Horowitz Jacquie Johnson Epstein Hearing Joint-privilege Adam Horowitz Jacquie Johnson Epstein Depositions Joint-privilege Stuart Bradley Edwards Epstein depositions Joint-privilege Privilege Log Dated I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Mermelstein Adam Horowitz Jacquie Johnson Epstein Depo Joint-privilege Spencer Kuvin Bradley Edwards Epstein Depo Joint-privilege Stuart Jacquie Johnson Epstein Depo of Wexner Joint-privilege Mermelstein Bradley Adam Horowitz Epstein cases depositions in Joint-privilege Edwards federal cases Jack Hill Bradley Edwards Epstein Assets Joint-privilege Katherine Bradley Edwards Epstein claims Joint-privilege Ezell Bradley Mercedes Epstein Joint-privilege Edwards Estrada Bradley Mercedes Epstein Telephone Conference Joint-privilege Edwards Estrada Bradley Mercedes Epstein Monday Joint-privilege Edwards Estrada Monthly call in telephone conference AT Call in No participant code Kathy is the host Bradley Mercedes Epstein Monday Joint-privilege Edwards Estrada Monthly call in telephone conference AT Call in No participant code Kathy is the host Bradley Mercedes Epstein Confirming AT dial Joint-privilege Edwards Estrada in tel cont for Monday at p.m Bradley Mercedes Epstein Confirming AT Dial Joint-privilege Edwards Estrada in Tel Conf for Monday at p.m Bradley Mercedes Epstein Confirming AT Dial Joint-privilege Edwards Estrada in Telephone Conference for Monday at p.m Privilege Log Dated I I I I Farmer Jaffe WeissinR Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Mercedes Epstein Confirming AT Dial Joint-privilege Edwards Estrada in Telephone Conference for Tomorrow Bradley Iliana Yarzabal Epstein Confirming AT Dial Joint-privilege Edwards in Telephone Conference for Wednesday at Spencer Kuvin Bradley Edwards Deposition of Epstein was set for Joint-privilege tomorrow Bradley Richard Willits CMA vs Epstein Joint-privilege Edwards Bradley Mercedes Epstein Joint-privilege Edwards Estrada Bradley Mercedes Epstein Joint-privilege Edwards Estrada Bradley Mercedes Epstein Joint-privilege Edwards Estrada Bradley Spencer Kuvin Epstein Joint-privilege Edwards Bradley Adam Horowitz Epstein Joint-privilege Edwards Spencer Kuvin Bradley Edwards Epstein Joint-privilege Katherine Bradley Edwards Epstein Joint-privilege Ezell Jack Hill Bradley Edwards Epstein Joint-privilege Jack Scarola Bradley Edwards Epstein Depos of Marcinkova Joint-privilege and Sarah Kellen Bradley Iliana Yarzabal Epstein Monday Joint-privilege Edwards Monthly Call in Telephone Conference Bradley Edwards Katherine Ezell letter from Bob Critton Joint W/P Privilege Bradley Edwards Spencer Kuvin letter from Bob Critton Joint W/P Privilege Bradley Edwards Barry Stone letter from Bob Critton Joint W/P Privilege Privilege Log-Dated I I I Farmer Jaffe Weissine Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Spencer Kuvin Epstein Oepo Joint W/P Privilege Jacquie Johnson Adam Horowitz Depo of Epstein Joint W/P Privilege Jacquie Johnson Adam Horowitz Epstein Joint W/P Priv Bradley Edwards Robert Josefsberg Epstein Confirming AT Tel Joint W/P Priv Conf Jacquie Johnson Katherine Ezell Depos of Marcinkova Sarah Joint W/P Priv Kellen Jacquie Johnson Adam Horowitz Epstein Depo in New York Joint W/P Priv Bradley Edwards Spencer Kuvin Epstein Hearing JointW/P Mv Jacquie Johnson Adam Horowitz Letter regarding Leslie Wexner Joint W/P Priv Spencer Kuvin Bradley Edwards Monthly Call in Tele Conf Joint W/P Priv Jacquie Johnson Mercedes Estrada Monthly Call in Tel Conf Joint W/P Priv Bradley Edwards Jack Scarola Epstein Tel Conf Joint Priv Bradley Edwards Robert Josefsberg Epstein Tel Conf Joint W/P Priv Katherine Ezell Bradley Edwards Epstein Depo Joint W/P Priv Jacquie Johnson Adam Horowitz Depo of Larry Visoski Joint W/P Priv Bradley Edwards Adam Horowitz Depo of Larry Visoski Joint W/P Priv Bradley Edwards Katherine Ezell Epstein cases Oepos Joint W/P Priv Adam Horowitz Bradley Edwards Epstein cases Witness depos Joint W/P Priv Spencer Kuvin Bradley Edwards Epstein depo New York Joint W/P Priv Spencer Kuvin Bradley Edwards Epstein Oepo Notice Joint W/P Priv Jacquie Johnson Adam Horowitz Epstein Depa Joint W/P Priv Jacquie Johnson Adam Horowitz Epstein Depos in New York Joint W/P Priv Jack Scarola Jacquie Johnson Epstein Oepos Joint W/P Priv Spencer Kuvin Jacquine Johnson Epstein Depos Joint W/P Priv Katherine Ezell Bradley Edwards Epstein Depos Joint W/P Priv Privilege Log Dated I Farmer Jaffe Weissimr Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJEOION Bradley Edwards Jack Hill Epstein assests Joint W/P Prlv Bradley Edwards Kikka Claudio Epstein Depos Joint W/P Priv Lisa Rivera Jacquie Johnson Epstein Depos Joint W/P Priv Bradley Edwards Spencer Kuvin Epstein Depos Joint W/P Priv Adam Horowitz Jacquie Johnson Epstein Hearing Joint W/P Priv Adam Horowitz Jacquie Johnson Epstein Hearing Joint W/P Prlv Bradley Edwards Adam Horowitz Epstein Hearing Joint W/P Priv Adam Horowitz Jacquie Johnson Epstein Hearing Joint W/P Priv Adam Horowitz Bradley Edwards Alfredo Rodriguez Depa Joint W/P Priv Adam Horowitz Jacquie Johnson Notice of Production from Non Joint W/P Priv Parties Bradley Edwards Spencer Kuvin Epstein Order Joint W/P Priv Bradley Edwards Spencer Kuvin Epstein Order Joint W/P Priv Spencer Kuvin Bradley Edwards Epstein Order Joint W/P Priv Bradley Edwards Spener Kuvin Epstein Order Joint W/P Priv Stuart Jacquie Johnson Epstein Sub To Bears Stern Joint W/P Priv Mermelstein Privilege Log Dated a I I I Farmer Jaffe Weissin2 Edwards Fistos lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Mercedes Bradley Edwards Improper Serving of Maxwell Joint W/P Priv Estrada Bradley Edwards Spencer Kuvin Hearing on Yellow Cab Objection Joint W/P Priv Adam Horowitz Kikka Claudio Address for Nadia Marcinkova Joint W/P Priv Adam Horowitz Bradley Edwards Motion for Protective Order Joint W/P Priv Adam Horowitz Bradley Edwards Motion for Protective Order Joint W/P Priv Bradley Edwards Margaret Berk Spencer Cross-Examination Joint W/P Priv Bradley Edwards Mercedes Estrada Transcripts Joint W/P Priv Adam Horowitz Bradley Edwards Rules on Doe no Joint W/P Priv Bradley Edwards Katherine Ezell File case Joint W/P Priv Bradley Edwards Spencer Kuvin Epstein th Amendment rights Joint W/P Priv Bradley Edwards Adam Horowitz Motions to Compel Joint W/P Priv Bradley Edwards Adam Horowitz Motions fully briefed Joint W/P Priv Katherine Ezell Bradley Edwards Answers to the set of ROGS Joint W/P Priv Katherine Ezell Bradley Edwards Depo dates Joint W/P Priv Katherine Ezell Bradley Edwards Switzerland Witness regarding Joint W/P Priv Epstein Egg Shaped inch PENIS Adam Horowitz Spencer Kuvin Alfredo Rodriguez depo Joint W/P Priv Privllege Log Dated I I Farmer Jaffe Weissin2 Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Katherine Ezell Bradley Edwards Switzerland Witness regarding Joint W/P Priv training of little girls as sex traps Katherine Ezell Bradley Edwards Calling Switzerland witness Joint Priv Bradley Edwards Spencer Kuvin Emails searchable Joint W/P Priv Kikka Claudio Bradley Edwards Epstein address Joint W/P Priv Bradley Edwards Mercedes Estrada TV Interview that is too explicit Joint W/P Priv Bradley Edwards Spence Kuvin Seeking Computers Joint W/P Priv Kikka Claudio Bradley Edwards Current address for Nadia Joint W/P Priv Marcinkova Katherine Ezell Bradley Edwards Distribution of Costs Joint W/P Priv Jacquie Johnson Bradley Edwards Voicemail Joint W/P Priv Kiklca Claudio Bradley Edwards Supoenasfordepos Joint W/P Priv Spencer Kuvin Bradley Edwards Yellow Cab stuff Joint W/P Priv Adam Horowitz Bradley Edwards Religious Dildo Washer Joint W/P riv Kikka Ctaudio Bradley Edwards Sjobergs current address Joint W/P Priv Bradley Edwards Spencer Kuvin Yellow Cab stuff Joint W/P Priv Bradley Edwards Kikka Claudio Settfng Depos Joint W/P Priv Mercedes Bradley Edwards Motion for Status Conf Joint W/P Priv Estrada
