Epstein Secrets

dwards' clients' Appellee Brief filed in that case, attached to this Notice as Exhibit B. In Jane Doe No. 1, the United States Court of Appeals for the Eleventh Circuit held that Epstein's former counsel had waived the work- product privilege with respect to documents sought by Edwards' clients, after having voluntar

ection as to grand jury materials). Exhibit B, at 36 n.13. Epstein also files as Exhibit C the August 4, 2010, hearing transcript; In re Rothstein Rosenfeldt Adler, P.A., United States Bankruptcy Court, Southern District of Florida, Case No. 09- 34791-BKC-RBR, The following are statements made by William Scherer

pt penalty"); Watkins, 943 F.2d at 1301, 1304 1301; Jaeger v. Massis, No. 00-7390. 2000 U.S. App. LEXIS 27908 (2d Cir. Nov. 3, 2000). Courts within the Eleventh Circuit have not hesitated to impose severe sanctions pursuant to their inherent powers, including cases where a party has acted in bad faith. See, e.g., I

009 CA 040800XXXX MB AG (hereinafter "the Epstein lawsuit"). 4. On April 17, 2010, Epstein served a subpoena in the Epstein lawsuit upon Rothstein Rosenfeldt Adler, PA ("RRA") Bankruptcy Trustee Howard Stettin, seeking to obtain documents from the Trustee, which included documents from attorney Edwards related

L/slm I Decisions of the United States Court of Appeals for the Fifth Circuit handed down prior to September 30, 1981, are binding as precedent in the Eleventh Circuit, Sag Bonner v. City of Prichard, Ala., 661 F.2d 1206, 1207 (11th Cir. 1981). K&E 19439748.2 EFTA00193952 EFTA00193953

t November 11, 2009, contained the approximate amount of $10,085.00; (BA11)Toronto Dominion Bank, N.A. account 6860420923 in the name of Rothstein Rosenfeldt Adler, P.A, Attorney Trust Account 3, which, on or about November 11, 2009, contained the approximate amount of $720,892.08; (BA12)Toronto Dominion Bank,