Epstein Secrets

. vs. Henry, 839 So2d. 702 at Note 4, 18 Third DCA opinion in 2000, both of which both 19 Judge Cope and the panel in the SCI case note that 20 the Supreme Court's citation in Levin to Wright 21 vs. Yurko, which I cited in the memorandum, which 22 was a Fifth DCA decision back in 1984, implicitly 23 24 25

OURT: Off the record for one second. 21 MR. KING: Yes. 22 (Discussion off the record.) 23 MR. KING: And I cited the Taylor case, 24 which was a Supreme Court of Idaho decision, which 25 discusses that issue and which shows that for www.phippereporting.com 888 811-3408 001241 EFTA00613538 32 1 tho

pon Epstein's justifiable belief at the time of filing his Complaint that these two individuals, and other unknown partners of theirs at Rothstein, Rosenfeldt, Adler, engaged in serious misconduct involving a widely publicized illegal Ponzi scheme operated through their law firm. Rothstein himself admitte

pposition to Edwards' MSJ revealing relevant information in pretrial discovery." (emphasis added). The Fourth District explained in Brancaccio that the "Supreme Court has disapproved of procedures which require a party to surrender one constitutional right in order to assert another..." 711 So. 2d, at 1210. Thus,

e there was no time in the schedule to depose Mr. Rothstein. The deposition of Scott Rothstein was taken in the bankruptcy proceeding of Rothstein, Rosenfeldt and Adler ("RRA"), but not completed, from December 12, 2011 through December 7 EFTA00808032 Epstein v. Rothstein and Edwards Case No. 502009CA0

rotected by the litigation privilege. As unequivocally stated in the decision of Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013), and the Florida Supreme Court cases cited therein, Florida's litigation privilege provides to all persons involved in judicial proceedings an absolute privilege from civil liabil

pon Epstein's justifiable belief at the time of filing his Complaint that these two individuals, and other unknown partners of theirs at Rothstein, Rosenfeldt, Adler, engaged in serious misconduct involving a widely publicized illegal Ponzi scheme operated through their law firm. Rothstein himself admitte

and as grounds therefor states as follows: &nicer Does Not Permit a Party to Ignore Trial Court Orders In this and other motions, Epstein relies on the Supreme Court's decision in Binger to argue that Epstein should be permitted to ignore this Court's pre-trial orders, as long as there is no prejudice to Edwards.

ction' in the Complaint, which includes the following allegations: Attorney Scott Rothstein aided by other lawyers . . . at the firm of Rothstein, Rosenfeldt and Adler, 5., for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and professional oblig

R. SCAROLA: Your Honor, the next issue It So based upon those two very fundUnantal IS before the Court relates co the plaintiff's II principles, the U.S. Supreme Court recognition, the 19 entitlement to an adverse inference instruction 10 Fifth Anentrient protections do not apply in the 20 arising out of each

client .• II variety of cases. It wan the entire contents of It So it was obvious that whet wes to happen at Ix the e-mail server of Rothstein, Rosenfeldt, Adler, 12 that point was they were to take over the 17 and it was recognized that those e- could 13 ninisteriol task es officers of the cour

R. SCAROLA: Your Honor, the next issue It So based upon those two very fundUnantal IS before the Court relates co the plaintiff's II principles, the U.S. Supreme Court recognition, the 19 entitlement to an adverse inference instruction 10 Fifth Anentrient protections do not apply in the 20 arising out of each

client .• II variety of cases. It wan the entire contents of It So it was obvious that whet wes to happen at Ix the e-mail server of Rothstein, Rosenfeldt, Adler, 12 that point was they were to take over the 17 and it was recognized that those e- could 13 ninisteriol task es officers of the cour

recoveries against Epstein from various civil actions. Shortly before Epstein's complaint was filed, Edwards' partner, Rothstein, was disbarred by the Supreme Court of Florida, and charged by the United States Government with various federal crimes arising out of the scheme. Epstein eventually narrowed his claims

4) fraud. Epstein's complaint set forth details of a Pont scheme that Edwards, Rothstein, and others perpetrated through their law firm, Rothstein, Rosenfeldt, and Adler, P.A. ("RRA"). (It 1-36).' The scheme included fraudulent promises to investors of multi-million dollar recoveries against Epstein from v

onor of having been selected by the 10 chief justice of the Florida Supremo Court to fulfill II 12 13 14 any responsibilities on behalf of the Supremo Court of Florida? A Yes. The position of chief justice rotates among the justices in the court. And at the time the IS chief justice of the Florida S

noon or evening, and I went to that. 10 So there were probably about seven or IL eight or nine of u➢ there. Somebody -- maybe Stuart 12 13 IS Rosenfeldt -- had already hired Kendall Coffey, who was -- Kendall la a Miami attorney. Kendall and I practiced together at Greenberg Traurig in the '70a. Ke

rotected by the litigation privilege. As unequivocally stated in the decision of Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013), and the Florida Supreme Court cases cited therein, Florida's litigation privilege provides to all persons involved in judicial proceedings an absolute privilege from civil liabil

pon Epstein's justifiable belief at the time of filing his Complaint that these two individuals, and other unknown partners of theirs at Rothstein, Rosenfeldt, Adler, engaged in serious misconduct involving a widely publicized illegal Ponzi scheme operated through their law firm. Rothstein himself admitte

ief it. It wasn't properly presented. And that would have put me in an odd position, because that had been my position. But also, when it went to the Supreme Court and it was a tagalong case after Fischer was -- the Fischer opinion was issued and they issued an order saying, Is there any reason for us to revi

561-471-2995 EFTA00788139 29 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 named partner of Rothstein, Rosenfeldt, Adler -- a firm which Brad Edwards, at the time, was part of -- in funding the largest Ponzi scheme in history. It was also known -- Judge, if y