Epstein Secrets

Flexner LLP 401 East Las Olas Boulevard, Suite 1200 Fort Lauderdale, FL 33301 Email: [email protected] Laura A. Menninger Haddon, Morgan and Foreman, P.C. 150 East Tenth Avenue Denver, CO 80203 Email: Imenningerahmfiaw.com Re: v. Maxwell Dear Counsel: CHARLES J. OGLETREE, JR. DIANE L HOUK

the Washington Post with submissions from a disciplinary proceeding pending before the EFTA00805072 EMERY CELLI BRINCKERHOFF & ABADY LLP Page 2 Florida Bar that reference information that was developed during discovery in this case. In keeping with plaintiff's enduring practice of insisting on selective

order granting summary judgment in favor of Epstein upon application of the litigation privilege based upon the then binding precedent of Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013). Final judgment was thereafter entered in favor of Epstein. Edwards appealed the judgment as it pertained to his

in Cases")4 that were being used to defraud investors in the Ponzi Scheme.5 [Cite Epstein Affidavit]. News outlets also reported at that time that the Florida Bar had begun actively investigating dozens of attorneys employed by RRA in connection with the Ponzi Scheme. [Cite Epstein Affidavit]; Miami Herald, S

heard argument solely as to the litigation privilege. 2 EFTA00808206 the litigation privilege based upon the then binding precedent of Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013). Final judgment was thereafter entered in favor of Epstein. Edwards appealed the judgment as it pertained to his

ns of dollars and to fund the RRA Ponzi Scheme. In November 2009, I also became aware of news stories that as a result of the Ponzi scheme at RRA, the Florida Bar had commenced investigations into over one-half of the attorneys employed by RRA. At or about the same time in November 2009, I also became aware t

u're holding the money, which 9 you're free to. But I don't know, even under the 10 best of circumstances and the best relationship 11 with Mr. Foreman, that I have the authority to 12 waive his fee. Arid that doesn't exist currently -- 13 certainly monetarily. So... 14 MR. JOSEPH GELLER: If I m

and this is 21 important — we are heavily involved in making sure 22 that clients' rights of the firm are being 23 protected. 24 We met with the Florida Bar. They're in full 25 agreement with what we're doing, and that would be Page 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 s

Haddad, Tonja 8/26/2013 For Educational Use Only Wolfe v. Foreman, — So.3d — (2013) 38 Fla. L. Weekly D1540 2013 WL 3724763 Only the Westlaw citation is currently available. NOTICE: THIS OPINION HAS NOT BEEN RE

PHERD, C.J., specially concurring. The only remarkable thing about this case is its existence. As the managing attorney of the Miami office of The Florida Bar explained to Mr. Wolfe (himself a licensed Florida attorney), when he refused to accept staff counsel's initial rejection of his Bar complaint agai

rocess claims filed against Epstein by the appellant, Bradley J. Edwards. The trial judge relied in part upon the then binding precedent of Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013) (holding that the litigation privilege applies to causes of action for malicious prosecution and abuse of process

ons of dollars and to fund the RRA Pont Scheme. In November 2009, I also became aware of news stories that as a result of the Ponzi scheme at RRA, the Florida Bar had commenced investigations into over one-half of the attorneys employed by RRA. At or about the same time in November 2009, I also became aware t

issue was one for the jury. However, this Court granted summary judgment in favor of Epstein based on the litigation privilege, relying on Wolfe v. Foreman, 128 So.3d 67 (Fla. 3d DCA 2013). Accordingly, Final Judgment was entered in favor of Epstein. 2 EFTA00613502 Edwards appealed the summary judgm

licious prosecution or abuse of process; 19 rather, it would be through the court with 20 contempt proceedings, perhaps. It would be 21 through the Florida Bar for, you know, 22 inappropriate actions taken by an attorney. It 23 could be perjury for a litigant which would be 24 handled by the state. 25

ken by him occurred during the litigation of his abuse of process claim against Edwards. For support, he relies primarily on the decision of Wolfe v. Foreman, 2013 WL 3724763 (Fla. 3d DCA July 17, 2013), wherein the Third District found that the litigation privilege barred both an abuse of process claim a

nformed about subsequent developments in Rothstein’s prosecution. See Letter attached hereto as Exhibit | 92. Jeffrey Epstein filed a-complaint with the Florida Bar against Bradley Edwards, Esa, raising allegations that Edwards and others were involved in the wrongdoing of Scott Rothstein. After investigating the