Epstein Secrets

2 At the March 8, 2018 hearing, University of Utah Law Professor, Paul G. Cassell, Esq., appeared pro hac vice below for non-parties L.M., E.W. and Jane Doe, on a limited confidentiality issue not before this Court. On behalf of non-parties, L.M., E.W. and Jane Doe, Mr. Cassell filed an Unopposed Emerge

d from this case on August 9, 2010. (App. 5). 5 EFTA00793697 all claims in the December 7, 2009 Complaint. (App. 4). Rothstein retained counsel, Mark Nurik, who moved to set aside the default, but an order was never entered on that motion. Mr. Nurik has not withdrawn from this case and has been on the

Complaint. (App. 4). Rothstein retained counsel, Mark Nurik, who moved to set aside the default, but an order was never entered on that motion. Mr. Nurik has not withdrawn from this case and has been on the service list since 2010. On April 12, 2011, Epstein filed an Amended Complaint against Rothste

Ponzi scheme, RRA was also engaged in litigation against Epstein in three civil cases. The cases were Jane Doe v. Epstein, Case No. 08-CIV- 80893 ("Jane Doe"), U.S. District Court, Southern District of Florida; L.M. v. Epstein ("LM"), Case No. 50-2008 CA 028051XXXXMB-AB; and E.W. v. Epstein ("EW" or "Jan

assets to avoid paying any judgments that may be obtained by RRA clients against Epstein; g) On August 13, 2009 an email was sent from Rothstein to Mark Nurik ("Nurik"), an attorney at RRA, regarding legal research on causes of action against Epstein. On - 6 - FOWLER WHITE BURNETT P.A. • 901 PHILLIPS POI

ORIDA 33401 • (561) 802-9044 EFTA00584200 Epstein v Rothstein, Edwards Case No.: 502009CA040800XXXXMBAG Second Amended Complaint that same day, Nurik sent an email to Rothstein regarding discussions about Epstein. Also on August 13, 2009, Adler sent an email to Rothstein regarding legal research o

Ponzi scheme, RRA was also engaged in litigation against Epstein in three civil cases. The cases were Jane Doe v. Epstein, Case No. 08-CIV- 80893 ("Jane Doe"), U.S. District Court, Southern District of Florida; L.M. v. Epstein ("LM"), Case No. 50-2008 CA 028051XXXXMB-AB; and E.W. v. Epstein ("EW" or "Jan

assets to avoid paying any judgments that may be obtained by RRA clients against Epstein; g) On August 13, 2009 an email was sent from Rothstein to Mark Nurik ("Nurik"), an attorney at RRA, regarding legal research on causes of action against Epstein. On that same day, Nurik sent an email to Rothstein reg

as sent from Rothstein to Mark Nurik ("Nurik"), an attorney at RRA, regarding legal research on causes of action against Epstein. On that same day, Nurik sent an email to Rothstein regarding discussions about Epstein. Also on August 13, 2009, Adler sent an email to Rothstein regarding legal research o

6, 09-80802, 09-81092, DECLARATION OF ADAM D. HOROWITZ 1. My name is Adam D. Horowitz. I am an attorney for Jane Doe No. 4. 2. The deposition of Jane Doe No. 4 was scheduled for September 16, 2009 at 1:00 p.m. at 350 Australian Ave. South, Suite 115, West Palm Beach, Florida. On the day before the de

CERTIFICATE OF SERVICE I certify that on this 3rd day of November, 2009, with the agreement and consent of Defendant Scott W. Rothstein's counsel, Mark Nurik, Esq., a true and correct copy of the above and foregoing was served via email on Mr. Nurik, at [email protected]. This 3rd day of November, 2009.

consent of Defendant Scott W. Rothstein's counsel, Mark Nurik, Esq., a true and correct copy of the above and foregoing was served via email on Mr. Nurik, at [email protected]. This 3rd day of November, 2009. 9 COFFEY B UR LINGTON OFFICE IN THE GROVE, PENTIIOUSE 2699 SOUTH BAYSHORE DRIVE MIAMI, F

9 A. I didn't tell you that. 10 Q. Okay. Let me ask you then: Did you ever 11 use Qtask, you personally create a project as it 12 related to Jane Doe's case against Mr. Epstein? A. No. 14 Q. To your knowledge did you direct anyone 15 well, let me strike that. Did you direct anyone to 16 crea

A00599740 Page 80 A. I'm finished. 2 Q. Which case was he the referring lawyer, Mr. Howell? 4 A. Q. And he may be the referring lawyer on Jane 6 Doe, and ., you just don't know as you sit here, 7 or he is? 8 A. He referred .'s case. 9 Q. And the other two cases is he is shown as 10 the

9680 Page 20 1 behalf; that is, who purports to represent 2 Mr. Rothstein since you left the firm that day? 3 A. No. 4 Q. Do you know Mr. Nurik? 5 A. Yes. 6 Q. Do you recog -- are you aware that he 7 represents Mr. Rothstein? A. Yes. 9 Q. Okay. Have you spoken with him since that

, ROTHSTEIN, EDWARDS (who either know or should have known) and, at times, L.M. in her Civil Action against EPSTEIN: a) ded claims for damages in Jane Doe's federal action in rces s of $50,000,000.00 rather than simply alleging the jurisdictional limits. b) Organized a Jane Doe TV media interview witho

CERTIFICATE OF SERVICE I certify that on this 3rd day of November, 2009, with the agreement and consent of Defendant Scott W. Rothstein's counsel, Mark Nurik, Esq., a true and correct copy of the above and foregoing was served via email on Mr. Nurik, at [email protected]. This 3rd day of November, 2009.

consent of Defendant Scott W. Rothstein's counsel, Mark Nurik, Esq., a true and correct copy of the above and foregoing was served via email on Mr. Nurik, at [email protected]. This 3rd day of November, 2009. 'Si Fla LA M. Baia.i 9 COFFEY B URLINGTON OFFICE IN THE. GROVE, PENTHOUSE 2699 SOU I H

ical in evaluating your Notice and Mr. Epstein's case against Mr. Edwards. Additionally, as part of a preservation order sought and obtained in the Jane Doe case, a case principally handled by Mr. Edwards both prior to his employment/association with RRA, during his employment/association wit

o seek the deposition of Mr. Rothstein. Obviously, Mr. Rothstein can shed substantial light on issues that directly impact our clients. However, Mr. Nurik indicated to me that Mr. Rothstein would be unavailable for a deposition at any time in the near future. I have noticed Mr. Rothstein's deposition

AL 10104 FORREST HILL BLVD WELLINGTON, FL 33414 150. All witnesses that Defendants have listed on their Witness List not objected to by Plaintiff, Jane Doe. 151. All rebuttal witnesses. 152. All People on Jeffrey Epstein's Inmate Visitor Log while he was in jail. WITNESS TESTIMONY EXPECTED TO BE PRESE

S. Ross, Gs q. 155. 156. Alfredo Rodriguez 11349 SW 86TH LN, Miami, FL C/O Federal Public Defender or Bureau of Prisons 157. Scott Rothstein do Mark Nurik One East Broward Boulevard, Suite 700 Fort Lauderdale, Florida 33301 EFTA00798057 2. Each contested factual issue expected to be addressed by th

riod and say, You 25 know, I should have realized there was something that were being prosecuted on behalf of throe young 1 woman: M., B.N. and Jane Doe. And w➢ will refer to them when I talk to you about them in that ➢ame way, 4 referring to sham by those initial➢ and that 5 pseudonym. 4 Desc

f them wore appealed. I wa➢ reversed a number of times. 23 0 Rough gue➢➢? 24 A I Couldn't tell you. I couldn't tell you how 2S many [limos. Nurik or Rothstein -- did they feel bullied or 2 threatened by Epstein lawyer➢? MR. SCAAOLA: Objection, predicate. 4 THE WITNESS: You are assuming tha

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

and consent of Defendant Scott W. Rothstein's counsel, Mark Nurik E a true and correct copy of the above and foregoing was served via email on Mr. Nurik, at This 3rd day of November, 2009. s; S 9 COFFEY B URLINGTON OI+ICk IN THE DROVE. PENTHOUSE 2699 SOUTH SAYSHORE DRIVE MIAMI, FLORIDA 33 133