Epstein Secrets

that RBA's trust accounts were maintained with a well established international banking institution, in accordance with the rules and regulations of the Florida Bar, and that at:7.gs to balances in the trust accounts was allegedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and o

mitted, COFFEY BURLINGTON Counsel for Plaindffs 2699 South Bayshore Drive, Penthouse Miami, Florida 33133 (305) 858-2900 B OS I LLADNECIV FEIN Florida Bar . 259861 Annexed hereto as Exhibit A is an affidavit from Plaintiff Rosenfeldt attesting to the truthfulness of the allegations contained herein.

with new money without any relevance to the existing claims made by the RRA clients. I) After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non- Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, EDWARDS and Berger, and their three

on the following Service List in the manner specified by CM/ECF on this 3rd day of September, 2009 By: -+--f=-'-"'----- ROBER . CR JON, JR., ESQ. Florida Bar No. 224 I 62 [email protected] MICHAEL J. PIKE, ESQ. Case 9:08-cv-80119-KAM Document 288 Entered on FLSD Docket 09/03/2009 Page 3 of 4 Flo

ered by the Court's Order on other 5th Amendment Privilege issues (DE 242). 3. The undersigned counsel has spoken with Brad Edwards' law partner, William Berger, and each party has agreed to the extension of time until September 11, 2009. 4. While the undersigned lawyers are attempting to resolve certain i

m By: ___ -1------ ROBERT D. RITTON, JR., ESQ. Florida Bar o. 224162 rcrit@bclcl w.com MICHAEL J. PIKE, ES

lf of C.M .. A., Adam Langino on behalf of B.B., William Berger on behalf of three Plaintiffs were present for th

otion is being filed, the undersigned has not received a response from Mr. Coffey or Mr. Singerm By: s/Robert D. Critton ROBERT D. CRITTON, JR., Florida Bar No. 224162 [email protected] Certificate of Service I HEREBY CERTIFY that a true copy of the foregoing was electronically filed with the Clerk of

A028058XXXXMB AB), (hereinafter "civil actions"). 3. In each of these civil actions, each of the Plaintiffs is represented by Bradley J. Edwards, William Berger and the RRA law firm, 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. Attorneys Russell Alder and Peter Feaman have also appeared for the

that RRA's trust accounts were maintained with a well established international banking institution, in accordance with the rules and regulations of the Florida Bar, and that access to balances in the trust accounts was allegedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and ot

with new money without any relevance to the existing claims made by the RRA clients. I) After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non- Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, EDWARDS and Berger, and their three

THSTEIN investors that RRA's trust accounts in ned with a well established international banking institution, in accordance with d regulations of the Florida Bar, and that access to balances in the trust accoun I egedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and other co

"pump" w money without any relevance to the existing cla y the RRA clients. 41 /4 I) After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non- Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, EDWARDS and Berger, and their three

RRA clients felt that Rothstein had lied to her repeatedly about funding, and that she was one step away from going to another lawyer and going to the Florida Bar. 11. RRA employed a team of investigators on the Epstein Actions, including Michael Fisten ("Fisten") and former Broward County Sheriff and convic

ions discussing investigative techniques and other Epstein matters; j) In the month of September, 2009, emails were exchanged between Edwards and William Berger ("Berger"), a partner at RRA who also participated in the Epstein actions, regarding Litigation Strategy. k) On September 11, 2009, Edwards sent a

RRA clients felt that Rothstein had lied to her repeatedly about funding, and that she was one step away from going to another lawyer and going to the Florida Bar. II. RRA employed a team of investigators on the Epstein Actions, including Michael Fisten ("Fisten") and former Broward County Sheriff and convic

ions discussing investigative techniques and other Epstein matters; j) In the month of September, 2009, emails were exchanged between Edwards and William Berger ("Berger"), a partner at RRA who also participated in the Epstein actions, regarding Litigation Strategy. k) On September 11, 2009, Edwards sent a

that RRA's trust accounts were maintained with a well established international banking institution, in accordance with the rules and regulations of the Florida Bar, and that access to balances in the trust accounts was allegedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and ot

with new money without any relevance to the existing claims made by the RRA clients. I) After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non- Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, EDWARDS and Berger, and their three

that RRA's trust accounts were maintained with a well established international banking institution, in accordance with the rules and regulations of the Florida Bar, and that access to balances in the trust accounts was allegedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and ot

with new money without any relevance to the existing claims made by the RRA clients. I) After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non- Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, EDWARDS and Berger, and their three