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e entry of an order. Counsel for Defendant wrote and enclosed copies of this motion and proposed agreed orders to Kendall Coffey, Esq., counsel for Stuart A. Rosenfeldt, individually, and Rothstein Rosenfeldt Adler, P.A., Coffey Burlington 2699 South Bayshore Drive, Penthouse, Miami, Florida 33133, and Paul Singerm
T. S.D. OF FLA. - W.P.B. DEFENDANT EPSTEIN'S EMERGENCY MOTION FOR ORDER FOR THE PRESERVATION OF EVIDENCE, & INCORPORATED MEMORANDUM OF LAW (AS TO JANE DOE v. EPSTEIN, Case No. 08-CIV-80893 Marra/Johnson) Defendant, Jeffrey Epstein, (hereinafter "Epstein"), by and through his undersigned attorneys, pur
gal investment scheme is also evidenced by the recent filing of Amended Complaint For Dissolution And For Emergency Transfer of Corporate Powers to Stuart A. Rosenfeldt, Or, In The Alternative, For the Appointment of A EFTA00725333 Epstein v. RRA, et al. Page 16 Custodian or Receiver by ROSENFELDT, individually,
PSTEIN, ROTHSTEIN, the Litigation Team and, at times, L.M., E.W., Jane Doe in the Civil Actions against EPSTEIN: a) Included claims for damages in Jane Doe's federal action in excess of $50,000,000.00 rather than simply alleging the jurisdictional limits. b) Made Jane Doe available for TV media intervie
gal investment scheme is also evidenced by the recent filing of Amended Complaint For Dissolution And For Emergency Transfer of Corporate Powers to Stuart A. Rosenfeldt, Or, In The Alternative, For the Appointment of A Custodian or Receiver by ROSENFELDT, individually, (a named Defendant herein), and RRA, against R
ion Team and, at times, L.M. in the Civil Action against EPSTEIN: EFTA00725306 Epstein v. RRA, et al. Page 19 a) Included claims for damages in Jane Doe's federal action in excess of $50,000,000.00 rather than simply alleging the jurisdictional limits. b) Made Jane Doe available for TV media intervie
nd illegal investment scheme is also evidenced by the filing of Amended Complaint For Dissolution And For Emergency Transfer of Corporate Powers to Stuart A. Rosenfeldt, Or, In The Alternative, For the Appointment of A Custodian or Receiver by ROSENFELDT, and RRA, against ROTHSTEIN, individually. (Case No. 09 05930
OTHSTEIN, EDWARDS (who either know or should have known) and, at times, L.M. in her Civil Action against EPSTEIN: a) Included claims for damages in Jane Doe's federal action in excess of $50,000,000.00 rather than simply alleging the jurisdictional limits. b) Organized a Jane Doe TV media interview witho
nd illegal investment scheme is also evidenced by the filing of Amended Complaint For Dissolution And For Emergency Transfer of Corporate Powers to Stuart A. Rosenfeldt, Or, In The Alternative, For the Appointment of A Custodian or Receiver by ROSENFELDT, and RRA, against ROTHSTEIN, individually. (Case No. 09 05930
A, ROTHSTEIN and EDWARDS claiming the need for anonymity with regard to existing or fabricated clients, they were able to effectively use initials, Jane Doe or other anonymous designations which was a key element in the fraudulent scheme. Fictitious names could be created to make the investors believe m
nd illegal investment scheme is also evidenced by the filing of Amended Complaint For Dissolution And For Emergency Transfer of Corporate Powers to Stuart A. Rosenfeldt, Or, In The Alternative, For the Appointment of A Custodian or Receiver by ROSENFELDT, and RRA, against ROTHSTEIN, individually. (Case No. 09 05930
THSTEIN, EDWARDS (who either know or should have known) and, at times, L.M. in her Civil Action against EPSTEIN: a) Included claims for dirnages in Jane Doe's federal action in excess of $50,000,000.00 rather than simply alleging the jurisdictional limits. b) Organized a Jane Doe TV media interview witho
Entities connected to both Stuart A. Rosenfeldt and Jane Doe

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
Kenneth Marra
PERSON
United States
LOCATION
Alan Dershowitz
PERSONthe Southern District
LOCATIONMaria Farmer
PERSONRobert D. Critton
PERSON
George W. Bush
PERSONMichael J. Pike
PERSONLeon Black
PERSONSouthern District
LOCATIONScott Rothstein
PERSON
Prince Andrew
PERSON
Donald Trump
PERSON
Bill Clinton
PERSON
Palm Beach County
LOCATION
Jeffrey Sloman
PERSON
Marc Rich
PERSONRothstein Rosenfeldt Adler
ORGANIZATION