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.

d consent of Defendant Scott W. Rothstein's counsel, Mark Nurik Es , a true and correct copy of the above and foregoing was served via email on Mr. Nurik, at This 3rd day of November, 2009. M.P ICSAM 9 COFFEY B 1./RLINGTON OFFICE IN THE GROVE, PENTHOUSE 2699 SOUTH BAYSHORE DRIVE MIAMI, FLORIDA

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

consent of Defendant Scott W. Rothstein's counsel, Mark Nurik, Esq., a true and correct copy of the above and foregoing was served via email on Mr. Nurik, at [email protected]. This 3rd day of November, 2009. 'Si Fla LA M. Baia.i 9 COFFEY B URLINGTON OFFICE IN THE. GROVE, PENTHOUSE 2699 SOU I H

CERTIFICATE OF SERVICE I certify that on this 3rd day of November, 2009, with the agreement and consent of Defendant Scott W. Rothstein's counsel, Mark Nurik, Esq., a true and correct copy of the above and foregoing was served via email on Mr. Nurik, at [email protected]. This 3rd day of November, 2009.

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

assets to avoid paying any judgments that may be obtained by RRA clients against Epstein; g) On August 13, 2009 an email was sent from Rothstein to Mark Nurik ("Nurik"), an attorney at RRA, regarding legal research on causes of action against Epstein. On - 6 - FOWLER WHITE BURNETT P.A. • 901 PHILLIPS POI

ORIDA 33401 • (561) 802-9044 EFTA00584200 Epstein v Rothstein, Edwards Case No.: 502009CA040800XXXXMBAG Second Amended Complaint that same day, Nurik sent an email to Rothstein regarding discussions about Epstein. Also on August 13, 2009, Adler sent an email to Rothstein regarding legal research o

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

assets to avoid paying any judgments that may be obtained by RRA clients against Epstein; g) On August 13, 2009 an email was sent from Rothstein to Mark Nurik ("Nurik"), an attorney at RRA, regarding legal research on causes of action against Epstein. On that same day, Nurik sent an email to Rothstein reg

as sent from Rothstein to Mark Nurik ("Nurik"), an attorney at RRA, regarding legal research on causes of action against Epstein. On that same day, Nurik sent an email to Rothstein regarding discussions about Epstein. Also on August 13, 2009, Adler sent an email to Rothstein regarding legal research o

or MORSE shall appear before this Court and testify, under oath. as to his receipt of these funds, under penalty of perjury and subject to action by the Florida Bar; .. 22. That based upon argument and representations of MORSE's counsel, made under oath; MORSE is suffering from significant financial distress du

consent of Defendant Scott W. Rothstein's counsel, Mark Nurik, Esq., a true and correct copy of the above and foregoing was served via email on Mr. Nurik, at [email protected]. This 3rd day of November, 2009. 9 COFFEY B UR LINGTON OFFICE IN THE GROVE, PENTIIOUSE 2699 SOUTH BAYSHORE DRIVE MIAMI, F

CERTIFICATE OF SERVICE I certify that on this 3rd day of November, 2009, with the agreement and consent of Defendant Scott W. Rothstein's counsel, Mark Nurik, Esq., a true and correct copy of the above and foregoing was served via email on Mr. Nurik, at [email protected]. This 3rd day of November, 2009.

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

and consent of Defendant Scott W. Rothstein's counsel, Mark Nurik E a true and correct copy of the above and foregoing was served via email on Mr. Nurik, at This 3rd day of November, 2009. s; S 9 COFFEY B URLINGTON OI+ICk IN THE DROVE. PENTHOUSE 2699 SOUTH SAYSHORE DRIVE MIAMI, FLORIDA 33 133

pro hac vice, an order for the payment of which will be issued when and if the motion to appear is granted. An additional fee of $250 is required by the Florida Bar. IS. CONFIDENTIAL APPELLATE JUDGE FEEDBACK FORM FOR ATTORNEYS: Please go to our website, www.4dca.ore, click on "Clerk's Office", then click on "Ap

am B. King Tonja Coleman tw W. Chester Brewer Jack Alan Goldberger LONN WEISSBLUM, Clerk Fourth District Court of Appeal Philip M. Burlington Mark Nurik Clerk Palm Beach EFTA00592356 Fourth District Court of Appeal 1525 Palm Beach Lakes Blvd. West Palm Beach, Florida 33401 (561) 242-2000 ACKNO

and this is 21 important — we are heavily involved in making sure 22 that clients' rights of the firm are being 23 protected. 24 We met with the Florida Bar. They're in full 25 agreement with what we're doing, and that would be Page 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 s

pon counsel in the sense this was an emergency hearing. THE COURT: Did he accept service? MR. JOSEPH GELLER: We have not spoken directly with Mr. Nurik and have not — THE COURT: But you delivered copies of these papers with a notice bearing upon Mr. Nurik? MR. JOSEPH GELLER: They were served by fa

all of ua at 32 the firm went through in terms of being interviewed 33 by law enforcement and that sort of thing, I was 34 also interviewed by the Florida Bar. And one of the 25 points they raised was the fact that I was being II 15 17 IS 19 Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00798

f them wore appealed. I wa➢ reversed a number of times. 23 0 Rough gue➢➢? 24 A I Couldn't tell you. I couldn't tell you how 2S many [limos. Nurik or Rothstein -- did they feel bullied or 2 threatened by Epstein lawyer➢? MR. SCAAOLA: Objection, predicate. 4 THE WITNESS: You are assuming tha

licious prosecution or abuse of process; 19 rather, it would be through the court with 20 contempt proceedings, perhaps. It would be 21 through the Florida Bar for, you know, 22 inappropriate actions taken by an attorney. It 23 could be perjury for a litigant which would be 24 handled by the state. 25

lm Beach, FL 33401 Attorneys for Jeffrey Epstein Fred Haddad, Esq. FRED HADDAD, P.A. 1 Financial Plaza, Ste. 2612 Attorneys for Jeffrey Epstein Mark Nurik, Esq. LAW OFFICES OF MARC S. NURIK 1 E. Broward Blvd., Ste. 700 Fort Lauderdale. FL 33301 Attorneys for Scott Rothstein Jack Goldberger, Esq. A