Epstein Secrets

r. 1975)). The parole evidence rule serves to protect a party to a written contract from infirmity of memory, perjury, or the death of witnesses. Adler, 721 F.Supp. at 476. 1181 We have examined the November 1984 contract and find it to be a complete integration of the parties' agreement. See con

pt the relevant rule of New York landlord-tenant law for purposes of deciding the remaining issue in this dis- pute, and hold that, consistent with New York law, OFM was entitled to arbitrarily withhold its consent to Epstein's request to sublet the Premises to Fisher. Even assum- ing OFM had a hidden a

d in part and denied in part. I. Federal Courts .3=409 In diversity action, federal court sitting in New York must apply New York law, including New York's choice-of-law rules. 2. Contracts e=s144 Under New York's choice-of-law rules, when court is construing meaning of con- tract, court should apply

t may not be introduced to create ambiguity. Arthur M. Handler, Whitman & Ransom, New York City, for plaintiff. Elliot Silverman, Cold & Wachtel, New York City, for defendant. ORDER CONBOY, District Judge: We have before us an action for breach of contract. Plaintiff Michael R. Stroll ("Stroll") see

ge Ray that impose restrictions on the possession of electronic data produced in response to a subpoena for emails from the Rothstein, Rosenfeldt, Adler law firm? Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00793426 Case 09-34791-RBR Doc 6482 Filed 10/19/18 Page 27 of 97 1 2 3 4 5

Did you ever learn that privilege was being asserted with respect to the production of any emails that were contained on a Rothstein, Rosenfeldt, Adler server? A Separate from a conversation with my attorneys, I don't recall. Q Are you aware, as you sit here today, that federal bankruptcy Judg

ead them. Q And what did you do with them after you read them? A I left them on my desk. Q Which desk? A I don't remember exactly. I believe New York, as I said before. Q What happened to those documents after you left them on your desk? A After being informed by my counsel, I Palm Beach Repo

ge Ray that impose restrictions on the possession of electronic data produced in response to a subpoena for emails from the Rothstein, Rosenfeldt, Adler law firm? Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00793528 Case 09-34791-RBR Doc 6488 Filed 10/22/18 Page 31 of 165 2 3 4 5 6

Did you ever learn that privilege was being asserted with respect to the production of any emails that were contained on a Rothstein, Rosenfeldt, Adler server? A Separate from a conversation with my attorneys, I don't recall. Q Are you aware, as you sit here today, that federal bankruptcy Judg

ead them. Q And what did you do with them after you read them? A I left them on my desk. Q Which desk? A I don't remember exactly. I believe New York, as I said before. Q What happened to those documents after you left them on your desk? A After being informed by my counsel, I Palm Beach Repo

16 17 18 19 20 21 22 23 24 25 of the files during the operative period of Adler's and Rothstein's dealings, allegedly, as it relates to Adler, clearly as it relates to Rothstein by his own testimony as to appease these investors and to further his own Ponzi scheme. Again, this is by no

A00788321 211 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 of the files during the operative period of Adler's and Rothstein's dealings, allegedly, as it relates to Adler, clearly as it relates to Rothstein by his own testimony as to appease these investo

12 13 14 15 16 17 18 19 20 21 22 23 24 25 deposed on Friday. She is here. She is ready to be deposed. THE WITNESS: Here in Florida or New York? MR. SCAROLA: She's in New York. The agreement was that she would be deposed in New York. That's where they wanted her to be deposed. She flew to

investors who were coming down from New York, as I recollect. And the presentation was by Mr. Rothstein allegedly through some intervention by Mr. Adler. And as I recollect, that was the substance of Mr. Epstein's testimony, as it related to those issues. MR. SCAROLA: May I respectfully call the

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 you look

2995 EFTA00788182 72 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 private island, what was going on in New York with the young women who were known to have been traveling back and forth with Mr. Epstein, and as to whom very substantial evidence existed that

overy motion. The facts underlying that action are briefly as follows: Scott Rothstein was the managing partner and CEO of Rothstein, Rosenfeldt and Adler ('RRA"), a 70-lawyer firm in Fort Lauderdale, Florida. Balin Aft Ex. A, Ex. 1 ("Rothstein Information") ¶¶ 1-2; id., Ex. 2 (Amended Complaint for D

tion (whether Edwards participated in Rothstein's fraudulent Ponzi scheme, not whether Epstein sexually abused Jane Doe) and entirely different law (New York's stringent Shield Iaw, not the less protective federal reporter's privilege). And the unpublished Epstein interview, which was conducted months befo

Scherer's Complaint, it is the partners and people who held themselves out to be partners of the Roth -- Scott Rothstein, including Mr. Berger, Mr. Adler, Mr. Edwards and other people associated with the firm like Mr. Fisten, Diane Villegas, if that's how you pronounce her name, Russell Adler, and ma

sition opsffrey Epstein, p. 25; lines 5-25. BY MR. SCAROLA: Q. Okay. What media did Mr. Edwards go to? A. I am aware of at least the Daily News in New York City. I have been told by other people that there were other media, local media. I've been told that the -- his investigator was sent to California to

d 33:15 along 40:17 assurances 12:5 Biscayne 1:14 39:1340:4,5,6 adjourned 44:16 already 22:5 attached 43:4 Bob 3:1819:7 cases 3:2 6:97:3,11 Adler 1:17 always 30:16 attack 33:17 Boehringer 1:20 8:13,22 9:3,5,5,15 admit 20:3,18 25:11 Amendment 6:24 attention 15:1,22 bond 25:22 10:3,11 12

Atterbury, Goldberger and Weiss-one of the law firms representing Mr. Epstein. Richard Kahn is a partner at the law firm of Sullivan and Cromwell in New York and has no association with the Atterbury firm. Checking public records available on the Internet, I located the IRS returns of "The C.O.U.Q. Found

521 17:9 Adam 1:13 3:4 29:13 add 29:5 35:7 42:21 addenda 36:16 Adderly 3:17 additional 29:22 address 29:15 addressed 33:15 adjourned 44:16 Adler 1:17 admit 20:3,18 25:11 3223 36:8 admits 23:20 admitted 23:17 24:9 41:19 ado 23:13 advantage 20:24 adverse 18.18 advice 12:7 affidavit 432

Atterbury, Goldberger and Weiss—one of the law firms representing Mr. Epstein. Richard Kahn is a partner at the law firm of Sullivan and Cromwell in New York and has no association with the Atterbury firm. Checking public records available on the internet, I located the IRS returns of "The C.O.U.Q. Found