Epstein Secrets

of Record Kendall Coffey, Esq. Coffey Burlington Office in the Grove, Penthouse 2699 South Bayshore Drive Miami, FL 33133 Paul Singerman, Esq. Berger Singerman, 2000 South Biscayne Blvd. Suite 1000 Miami, FL 33131 Linnea R. Johnson United States Magistrate Judge

Emergency Motion for Order for the Preservation of Evidence & Incorporated Memorandum of Law Page 7 of 9 Stettin, Esq. as Court Appointed Receiver, Berger Singerman, 2000 South Biscayne Blvd., Suite 1000, Miami, FL 33131. At the time this motion is being filed, the undersigned has not received a response from

f Law Page 5 of 9 10. Defendant has previously served Subpoenas Duces Tecum for Deposition, dated November 5, 2009, upon Bradley J. Edwards, Esq.; Rothstein Rosenfeldt Adler, PA; Stuart Rosenfeldt, Esq., as Records Custodian For RRA; and Herbert Stettin, as the Court Appointed Receiver for RRA. The Subpoenas, which were

ecord Kendall Coffey, Esq. Coffey Burlington Office in the Grove, Penthouse 2699 South Bayshore Drive Miami, FL 33133 James C. Cunningham, Jr. Berger Singerman, 2000 South Biscayne Blvd. Suite 1000 Miami, FL 33131 2568019-3

idence, the Court enters this Order: Defendant Epstein's November 12, 2009 Motion to Preserve Evidence [DE # 405] alleges that Plaintiff's counsel, Rothstein Rosenfeldt Adler, P.A. ("RRA") has been accused of serious unethical and possible criminal misconduct and requests an order requiring the preservation of certain do

ned for at least 45 days; and (3) granting such other relief as the Court deems just and proper. Dated: November 16, 2009 Respectfully submitted, BERGER SINGERMAN, P.A. Proposed Attorneys for Alleged Debtor 350 East Broward Boulevard, 10th Floor Telephone: (954) 525-9900 Facsimile: (954) 523-2872 By: s/ C

[D.E. 405] The Honorable Herbert Stettin ("Stettin"), the State Court appointed1 receiver ("Receiver") and Chief Restructuring Officer ("CRO") of Rothstein Rosenfeldt Adler, P.A.'s ("RRA"), hereby responds to the Defendant's Emergency Motion For Order For The Preservation of Evidence [D.E.405], and states: 1. Certain

been determined that the documents wrongfully in the possession of Epstein were originally formatted in the way described above by the law firm of Berger Singerman, as counsel for the Trustee of Rothstein Rosenfeldt Adler ("RRA") in the Federal Bankruptcy proceeding litigated before United States Bankruptcy Cou

in the possession of Epstein were originally formatted in the way described above by the law firm of Berger Singerman, as counsel for the Trustee of Rothstein Rosenfeldt Adler ("RRA") in the Federal Bankruptcy proceeding litigated before United States Bankruptcy Court Judge Raymond B. Ray in case 09-34791. 4. The subjec

MENTS ONLY THE STATE OF FLORIDA TO: Herbert Stettin, Trustee in Bankruptcy for Rothstein Rosenfeldt Adler, PA CIO James C. Cunningham, Jr., Esq. Berger Singerman, P.A. 200 South Biscayne Blvd., Suite 1000 Miami, FL 33131 YOU ARE COMMANDED to appear at Prose Court Reporting, 101 NE 3'd Avenue, Suite #1500,

ually, Defendants. I SUBPOENA DUCES TECUM FOR DEPOSITION - DOCUMENTS ONLY THE STATE OF FLORIDA TO: Herbert Stettin, Trustee in Bankruptcy for Rothstein Rosenfeldt Adler, PA CIO James C. Cunningham, Jr., Esq. Berger Singerman, P.A. 200 South Biscayne Blvd., Suite 1000 Miami, FL 33131 YOU ARE COMMANDED to appear a

IAL LAWYER SPECIAL CONSUMIR 2ADMITTE 0 TO PRACTICE IN FLORIDA AND COLORADO JUSTICE COUNSEL Sent by E-mail and U.S. Mail Isaac Marcushamer, Esq. Berger Singerman 200 South Biscayne Blvd., Suite 1000 Miami, FL 33131 Re: L.M. v. Jeffrey Epstein CASE NO.: 502008CA028051YJOOMBAD Dear Isaac: I am enclosing a

MB AD Plaintiff, v. JEFFREY EPSTEIN, Defendant. SUBPOENA DUCES TECUM FOR DEPOSITION THE STATE OF FLORIDA TO: Herbert Stettin, as receiver for Rothstein Rosenfeldt Adler, PA 5401 Hammock Drive Coral Gables, FL 33156-2105 YOU ARE COMMANDED to appear at Prose Court Reporting, 101 NE 3rd Avenue, Suite #1500, Ft. Laud

IAL LAWYER SPECIAL CONSUMIR 2ADMITTE 0 TO PRACTICE IN FLORIDA AND COLORADO JUSTICE COUNSEL Sent by E-mail and U.S. Mail Isaac Marcushamer, Esq. Berger Singerman 200 South Biscayne Blvd., Suite 1000 Miami, FL 33131 Re: L.M. v. Jeffrey Epstein CASE NO.: 502008CA028051YJOOMBAD Dear Isaac: I am enclosing a

MB AD Plaintiff, v. JEFFREY EPSTEIN, Defendant. SUBPOENA DUCES TECUM FOR DEPOSITION THE STATE OF FLORIDA TO: Herbert Stettin, as receiver for Rothstein Rosenfeldt Adler, PA 5401 Hammock Drive Coral Gables, FL 33156-2105 YOU ARE COMMANDED to appear at Prose Court Reporting, 101 NE 3rd Avenue, Suite #1500, Ft. Laud

IAL LAWYER SPECIAL CONSUMIR 2ADMITTE 0 TO PRACTICE IN FLORIDA AND COLORADO JUSTICE COUNSEL Sent by E-mail and U.S. Mail Isaac Marcushamer, Esq. Berger Singerman 200 South Biscayne Blvd., Suite 1000 Miami, FL 33131 Re: L.M. v. Jeffrey Epstein CASE NO.: 502008CA028051YJOOMBAD Dear Isaac: I am enclosing a

MB AD Plaintiff, v. JEFFREY EPSTEIN, Defendant. SUBPOENA DUCES TECUM FOR DEPOSITION THE STATE OF FLORIDA TO: Herbert Stettin, as receiver for Rothstein Rosenfeldt Adler, PA 5401 Hammock Drive Coral Gables, FL 33156-2105 YOU ARE COMMANDED to appear at Prose Court Reporting, 101 NE 3rd Avenue, Suite #1500, Ft. Laud