Epstein Secrets

by any other object; or the handling or fondling of the sexual organ of another for the purpose of masturbation." Fla. Stat. § 796.01(1)(d). Also, the Florida Supreme Court jury instructions define prostitution as involving "sexual intercourse." As a result, topless massages—even ones for hire that include self masturb

e Business Records Certifications and Inventory Forms and return everything to Special Agent Kuyrkendall at the Federal Bureau of Investigation, 505 South Flagler Drive, Suite 500, West Palm Beach, FL 33401- 5933. Thank you for your assistance with this matter. Sincerely, R. ALEXANDER ACOSTA UNITED STATES ATTORNE

ed in anticipation of litigation with respondents." Nationwide Mut. Fire Ins. Co. v. Harmon, 580 So. 2d 192, (Fla. 4th DCA 1991). Forty years ago, the Florida Supreme Court, in Sof Drugs, Inc. v. Vermette, 236 So. 2d 108, 112 (Fla. 1970), explained what is covered by the work product privilege: [T]hose documents, pictu

ssary and proper. Respectfully submitted, Joseph L. Ackerman, Jr. Florida Bar No. 235954 FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Flagler Drive 16 EFTA00582872 Epstein v. Rothstein and Edwards DRAFT 2/3/12 4:26 PM Case No. 502009CA040800XXXXMB/Div. AG West Palm Beach, Florida 33401 T

se in midst of the collapse of a firm in which he was a member, called Rothstein, Rosenfeldt & Adler, P.A. ("RRA"). 4. Rothstein was disbarred by the Florida Supreme Court on November 20, 2009. Subsequently, Rothstein was arrested, arraigned in federal court, pled guilty and ultimately was sentenced to fifty (50) year

alm Beach, FL 33409. Respectfully submitted, Joseph L. Ackerman, Jr. Fla. Bar No. 235954 FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: Facsimile: WA80743 COMPLkS2amended Complaint,ILA.docx - 9 - FOWLER WHITE BURNETT P.A. • 901 PHILLIPS

nts is without a basis in Florida law. We find no evidence that the Florida courts derive an evidentiary privilege from Fla.Stat. 905.27. Indeed, the Florida Supreme Court has noted that Mlle rule of secrecy concerning matters transpiring in the grand jury room is not designed for the protection of witnesses bef

ached Certification nd immediately returning it with the records to Special Agent I at the following address: Federal Bureau of Investigation 505 South Flagler Drive, Ste. 500 West Palm Beach, Florida 33401-5923 EARLY VOLUNTARY TURNOVER Please note that we are requesting an early voluntary turnover of the mater