Epstein Secrets

ed to the court, the filing "shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York." (Id. ¶ 10.) The docket sheet in v. Maxwell reveals that such motions were frequently made and routinely granted. As a result, a vast

by a grand jury. For example, in Davis, 702 F.2d 418, the Government, which was not a party to the underlying civil litigation, successfully "moved the Bankruptcy Court for an order permitting it access to the materials under seal," including transcripts of examinations taken under Rule 205 and exhibits marked at t

der from U.S. I EFTA00808132 Case 09-34791-RBR Doc 6384 Filed 05/14/18 Page 2 of 6 Bankruptcy Judge Raymond B. Ray of the Bankruptcy Court for the Southern District of Florida. See DE 1194, In Re: Rothstein Rosenfeld: Adler, P.A., No. 09-34791-RBR. If you are in possession of any of the attached documents as a

ned in violation of an order from U.S. I EFTA00808132 Case 09-34791-RBR Doc 6384 Filed 05/14/18 Page 2 of 6 Bankruptcy Judge Raymond B. Ray of the Bankruptcy Court for the Southern District of Florida. See DE 1194, In Re: Rothstein Rosenfeld: Adler, P.A., No. 09-34791-RBR. If you are in possession of any of t

r Epstein complied with that directive is squarely and appropriately before the court that issued the Order — the United States Bankruptcy Court for the Southern District of Florida. 2See March 8, 2018, Afternoon Hearing Transcript, 62:6-12 (Court allowed Epstein to file the exhibits under seal to protect his appell

ng, Edwards, himself, would be in violation of the Court's ruling by his reference to the e-mails in filings in this Court, the Appellate Court and the Bankruptcy Court. In fact, Epstein has taken numerous affirmative steps to ensure compliance with the Court's directives at the March 8, 2018 hearing. The disc is se

riginated in and arose out of this District. Furthermore, Defendants reside and/or maintain a principal place of business in this District. Venue in the Southern District of New York is therefore proper pursuant to 28 U.S.C. §139I(a). PARTIES 9. Plaintiff Marvin Gerber ("Gerber") is a resident of Wantagh, New York.

with over 20 years of accrued interest, now totals approximately one billion ($1,000,000,000) dollars, which represents the losses as determined by the Bankruptcy Court of the victims of his Ponzi scheme. 5 EFTA00809695 Case 1:18-cv-07580-JPO Document 7 Filed 08/21/18 Page 6 of 26 19. From 1975 through April 19

trike, which identified a Federal Court Order issued on November 30, 2010 by the Honorable Raymond B. Ray of the United States Bankruptcy Court for the Southern District of Florida, prohibiting Epstein's prior counsel, Fowler White, from creating or retaining the CD in question, and reserving 3 EFTA00811313 Edwar

er White's possession and retention of the CD at issue is currently the subject of a Motion for Issuance of an Order to Show Cause that was filed in the Bankruptcy Court on March 19, 2018. The Bankruptcy Court has scheduled a hearing on that motion for April 13, 2018. 4 EFTA00811314 Edwards adv. Epstein Case No.

ted on the attached service list this 19th day of July, 2010. I HEREBY CERTIFY that I am admitted to the Bar of the United State District Court for the Southern District of Florida and I am in compliance with the additional qualifications to practice in this court set forth in Local Rule 2090-1(A). FARMER, JAFFE, WE

er on these motions for protective order protecting privileged and work product materials from production to Epstein. 12. Now, Epstein has come to the Bankruptcy Court to pursue the discovery of privileged and attorney work product materials which the Circuit Court would not allow. See Epstein's Motion to Compel,

I The Court recognized that the privileged materials at issue were likely subject to an order from Judge Raymound B. Ray of the Bankruptcy Court for the Southern District of Florida. 3/8/18 Afternoon Session Tr. at 52:6-19; 54:9-20. EFTA00793948 7. Pursuant to Judge Ray's Order, Edwards is permitted to depose Epste

f Epstein's deposition. I The Court recognized that the privileged materials at issue were likely subject to an order from Judge Raymound B. Ray of the Bankruptcy Court for the Southern District of Florida. 3/8/18 Afternoon Session Tr. at 52:6-19; 54:9-20. EFTA00793948 7. Pursuant to Judge Ray's Order, Edwards is

cy for RRA to administer the firm's assets and claims. 22. On July 20, 2010, Bradley Edwards received a letter from the U.S. Attorney's Office for the Southern District of Florida — the office responsible for prosecuting Rothstein's Ponzi scheme. The letter indicated that law enforcement agencies had determined that

the obligation to file a privilege log does not arise."). B. Discovery Issues Related to the State Court Issued Subpoenas Are Not Properly Before the Bankruptcy Court The Razorback Creditors are also attempting to litigate issues relating to discovery in state court cases before this bankruptcy court. But neither

ed to the court, the filing "shall be accompanied by a Motion to Seal pursuant to Section 6.2 of the Electronic Case Filing Rules & Instructions for the Southern District of New York." (Id ¶ 10.) The docket sheet in Giulfre v. Maxwell reveals that such motions were frequently made and routinely granted. As a result,

by a grand jury. For example, in Davis, 702 F.2d 418, the Government, which was not a party to the underlying civil litigation, successfully "moved the Bankruptcy Court for an order permitting it access to the materials under seal," including transcripts of examinations taken under Rule 205 and exhibits marked at t

) and may be viewed as a waiver of the privilege or protection." 799 So. 2d at 340. The TIG court further observed that Local Rule 26.1(G)(3)(b), of the Southern District of Florida, spelled out the requirements for a valid privilege log, hi. at 341: Where a claim of privilege is asserted in objecting to any interro

f would show as follows: SUMMARY OF ARGUMENT On or about February 23, 2011, Edwards, in response to several orders entered by Judge Raymond Ray in the Bankruptcy Court, filed a one hundred and fifty-nine (159) page privilege EFTA00582857 Epstein v. Rothstein and Edwards DRAFT 2/3/12 4:26 PM Case No. 502009CA04