Epstein Secrets

the facts that existed at the time I filed suit, as set forth below and more fully in my Summary Judgment Motion. 1 EFTA00313265 5. I filed the Action against Rothstein and Edwards because, based on the facts described below and in the Summary Judgment Motion, I believed at the time of filing my o

of dollars and to fund the RRA Ponzi Scheme. 7. 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. 8. At or about the same time in November 2009, I also became awa

lawsuit. In pertinent part, Epstein's affidavit summarized the following as probable cause for the filing of his suit against Edwards: I filed the Action against Rothstein and Edwards because, based on the facts described below and in the Summary Judgment Motion, I believed at the time of filing my o

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

he facts to footnotes. In pertinent part, Epstein's affidavit alleged the following as probable cause for the filing of the complaint: I filed the Action against Rothstein and Edwards because, based on the facts described below and in the Summary Judgment Motion, I believed at the time of filing my o

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

on the facts that existed at the time I filed suit, as set forth below and more fully in my Summary Judgment Motion. EFTA00313643 5. I filed the Action against Rothstein and Edwards because, based on the facts described below and in the Summary Judgment Motion, I believed at the time of filing my o

of dollars and to fund the RRA Ponzi Scheme. 7. 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. 8. At or about the same time in November 2009, I also became awa

he same, based on the facts that existed at the time I filed suit, as set forth below and more fully in my Summary Judgment Motion. 5. I filed the Action against Rothstein and Edwards because, based on the facts described below and in the Summary Judgment Motion, I believed at the time of filing my o

of dollars and to fund the RRA Ponzi Scheme. 7. 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. 8. At or about the same time in November 2009, I also became awa

s disagreement between the parties is properly the subject of Defendant's Motion to Dismiss First Amended Complaint For Failure to State a Cause of Action, and Motion For More Definite Statement; Motion to Strike, and Supporting Memorandum of Law (D.E. 47) which is currently pending before this Court.

00175324 Case 9:08-cv-80811-KAM Document 35 Entered on FLSD Docket 01/07/2009 Page 7 of 7 v. Epstein, et al. By: ROBERT D. RITTON, JR., ESQ. Florida Bar o. 224162 rcrit@bcIcl w.com MICHAEL J. PIKE, ESQ. Florida Bar #617296 moikeebdclaw.com BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Drive,

ose would be to sanction Rosenbaum for his alleged un- authorized disclosures of his clients' privi- leged information in his Request for Judi- cial Action and at the April 16 hearing, enjoin Rosenbaum from future similar con- duct, determine whether Rosenbaum vio- lated Florida Bar Rules of Professiona

grievances against one another they are already embroiled in Judicial dissolution proceedings, and if complaints have not already been filed with the Florida Bar, they are likely to be." Rule 24(a) does not require interven- tion by Garfinkel and Katzman to protect themselves from Rosenbaum's complaints aga