Epstein Secrets

the Rothstein, 20 it docunonts, chat wore sent co us not covering all of the 724. And obviously, your Honor knows from the 2s , 31 Rosenfeld[, Adler urn a trustee was appointed by the bankruptcy court to take control of the firm, 22 materials that you have reviewed much attention was =2 and t

ot 10 And those two eases together stand for the It just put someone on the stand co talk about hits. 11 basic principle that you may not loose Civil 12 Thank you, Judge. 12 liability solely upon the assertion of e Fifth 13 THE COURT: Okay. I was writing as wo were I) Armodnent privilege. B

the Rothstein, 20 it docunonts, chat wore sent co us not covering all of the 724. And obviously, your Honor knows from the 2s , 31 Rosenfeld[, Adler urn a trustee was appointed by the bankruptcy court to take control of the firm, 22 materials that you have reviewed much attention was =2 and t

ot 10 And those two eases together stand for the It just put someone on the stand co talk about hits. 11 basic principle that you may not loose Civil 12 Thank you, Judge. 12 liability solely upon the assertion of e Fifth 13 THE COURT: Okay. I was writing as wo were I) Armodnent privilege. B

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

vance to a significant issue in the case, and are not reasonably obtainable from other available sources" (quoting Gonzales, 194 F.3d at 36)) with.. Civil Rights Law § 79-h(c) (to overcome state Shield Law privilege for non-confidential material, party must make "a clear and specific showing" that the

s an attorney admitted to practice law in Florida. Defendant Rothstein wilt& Chief Executive Officer (CEO) and Chairman of Rothstein, Rosenfeldt and Adler, CR-COHN 14.6.alS1 RA ! c, 1U1D{ 6WCZARI • - FILED by DEC 0 1 2009; STEVEN M. LARIMORE CLERK U. S. DIST. CT. S. D. of FLA. - FT. LAUD. Roth

E.W./L.M.: "What the evidence is really going to show is that Mr. Epstein — at least dating back as completely irrelevant r subject matter of the Civil EFTA00795603 Epstein v. RRA, et al. Page 17 far as our investigation and resources have permitted, back to 1997 or '98 — has every single day o

8,9 clear 11:7 client 3:21 10:17 close A acc 7:24 access 6:18 7:24 11:2 12:8 12:15 13:22 addendum 4:14 addresses 8:19 adduced 3:4. Adler 2:12 Administr... 5:22 8:18 9:18 11:22 13:10 14:5 12:18 Anybody 3:23 14:14 anyway 10:2 apparently 2:3 Avenue 2:19 An 1:4,4 a.m 13:3

r says. May I quote Judge Marra. 'If a specific tangible need arises in a civil case the relief should be sought in that case.' In other words, the Civil cases which are in front of Judge Hafele is one forum that Judge Marra said go to it. Judge Marra did not say that this Court does not have Jurisdic