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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 admitted to, a
ized that it has been "expansively interpreted" by Florida courts. In Microbilt Corporation v. Cher Systems, Inc., 2013 WL 6628619 (Dec. 16, 2013), the Bankruptcy Court, applying Florida law, avowed: The rule of absolute immunity extends to the parties, judges, witnesses, and counsel involved and related to the jud
der. 2. Included within that submission was extensive internal email correspondence from Edwards' time as an attorney at Rothstein, Rosenfeldt and Adler. These emails were admittedly obtained from a CD that Epstein's current counsel acquired from its predecessor counsel, Fowler White. 3. At least
er White's possession and retention of the CD at issue is currently the subject of a Motion for Issuance of an Order to Show Cause that was filed in the Bankruptcy Court on March 19, 2018. The Bankruptcy Court has scheduled a hearing on that motion for April 13, 2018. 4 EFTA00811314 Edwards adv. Epstein Case No.
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 admitted to, a
en "expansively interpreted" by Florida courts. In 13 EFTA00714936 Microbilt Corporation v. Chex Systems, Inc., 2013 WL 6628619 (Dec. 16, 2013), the Bankruptcy Court, applying Florida law, avowed: The rule of absolute immunity extends to the parties, judges, witnesses, and counsel involved and related to the jud
The critical nature of these documents is vividly demonstrated by Rothstein's testimony during his recent deposition that he had asked Edwards or Adler to specifically set aside a flight manifest for an Epstein private jet. (Tr. Rothstein Depo 12/21/11 at 2278). Rothstein further testified that he
f would show as follows: SUMMARY OF ARGUMENT On or about February 23, 2011, Edwards, in response to several orders entered by Judge Raymond Ray in the Bankruptcy Court, filed a one hundred and fifty-nine (159) page privilege EFTA00582857 Epstein v. Rothstein and Edwards DRAFT 2/3/12 4:26 PM Case No. 502009CA04
Entities connected to both Adler and the Bankruptcy Court

Jeffrey Epstein
PERSONScott Rothstein
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSONJack Goldberger
PERSON
Rosenfeldt
PERSONMaria Farmer
PERSONJack Scarola
PERSONJane Doe
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
United States
LOCATIONthe Southern District
LOCATION
Kenneth Marra
PERSON
Joe Biden
PERSONLeon Black
PERSON
Prince Charles
PERSON
Bill Clinton
PERSON
Prince Andrew
PERSONMartin Weinberg
PERSON