Epstein Secrets

Australian A venue South Suite 1400 West Palm Beach, FL 33401-5012 561-659-8300 Fax: 561-835-8691 iagesq(cv,bellsouth.net Counsel for Defendant Jeffi'ey Epstein Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq .. Adam D. Horowitz, Esq.

:/ EPSTEIN'S MOTION FOR PROTECTIVE ORDER REGARDING THE DEPOSITION OF STORY COWLES AND INCORPORATED MEMORANDUM OF LAW Defendant, JEFFREY EPSTEIN ("Epstein"), pursuant to Rule 26(c), Federal Rules of Civil Procedure, moves for a protective order to prohibit the deposition of Story Cowles, and states:

as hired by Jack Goldberger, Esq., co-counsel for Mr. Epstein, on I July 16, 2008 and has been employed by Mr

esq(cv,bellsouth.net Counsel for Defendant Jeffi'ey Epstein Certificate of Service Jane Doe No. 2 v. Jeffre

pstein Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stua

iscussed the claims asserted against him with Mr. Cowles other than when his attorneys were present or when he was transmitting information between Epstei11 and his attorneys. See Exhibit C. 2 i I ! Case 9:08-cv-80119-KAM Document 536 Entered on FLSD Docket 04/29/2010 Page 3 of 8 9. In Octob

xhibit H), in which he granted a protective order regarding the depositions of Michael Fisten and Rick Fandrey, investigators previously employed by Rothstein, Rosenfeldt & Adler ("RRA"). As the Court may recall, RRA represented Jane Doe prior to its implosion. 5 Case 9:08-cv-80119-KAM Document 536 Entered on FLSD Doc

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNCERTIFIED TRANSCRIPT DISCLAIMER IN THE MATTER OF EPSTEIN v. ROTHSTEIN DRAFT !!!! NOT PROOFREAD EFTA00804162 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

bove cause, testified on his oath as follows: THE WITNESS: Yes. DIRECT EXAMINATION BY MR. SCAROLA: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each of your residence addresses? MR. GOLDBERGER: I think it's beyond the scope. I'm going to object to Fifth

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

you okay with me doing it? MR. SCAROLA: We want Mr. Epstein to invoke any privilege that Mr. Epstein consid

12 13 14 15 16 17 18 19 20 21 22 23 24 25 Q Did it ever come to your attention that emails contained on the server of the law firm Rothstein, Rosenfeldt & Adler had been produced connection with the state court civil proceedings by the bankruptcy trustee to a special master that had been appointed for purp

-MARRA/JOHNSON JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. ______________ ___;! Related case

ED MOTION TO STRIKE Defendant, JEFFREY EPSTEIN ("Epstein"), submits this Response in Opposition to Plaint

, Jane Doe did not give or receive oral sex from Mr. Epstein, did not engage in anal or vaginal sex with Mr.

,000 in damages in this case, primarily to "hurt Jeffrey Epstein." See 9/20/09 Deposition Transcript of Ja

3, 2009. Jane Doe is represented by the law firm Rothstein, Rosenfeldt & Adler ("RRA"), which as been in the news regarding alle

IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, -VS- SCOTT individually, Intervenors.' ROTHSTEIN, BRADLEY J. individually, and and JANE DOE, Respondents CASE NO. 4D18-0762

Background Facts 4 Epstein Attempts to Intimidate His Victims by Filing Suit Against and 5-11 Retaliates Against their Lawyer ARGUMENT 12-26 EPSTEIN'S PETITION FOR WRIT OF MANDAMUS SHOULD BE DENIED BECAUSE EPSTEIN WAITED UNTIL THE EVE OF TRIAL, MORE THAN TEN MONTHS AFTER THE CASE HAD BEEN SET F

APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, -VS- SCOTT individually,

ision AG of anything whatsoever having to do with Mr. Epstein's prosecution of that one-count Complaint agains

s ".." (App. 1). The gravamen of the Complaint was that after Edwards had filed those cases against Epstein, he had briefly joined the law firm of Rothstein, Rosenfeldt & Adler, P.A. ("RRA"), which subsequently imploded after Rothstein was charged with (and later pled guilty to), operating a Ponzi scheme (App.1). Rothstein

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNCERTIFIED TRANSCRIPT DISCLAIMER IN THE MATTER OF EPSTEIN v. EDWARDS DRAFT ONLY !!!! NOT PROOFREAD EFTA00792811 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

y were not passengers on the planes. And that is true. It is true that all of Brad Edwards' clients acknowledged that they were not passengers on Jeffrey Epstein's private jets. But both the Florida Evidence Code and federal rules of evidence expressly permit the federal rules are very explicit about this: Ex

nto details with regard to what happened between Jeffrey Epstein and each of the three claimants against

ith -- have a seat, please. Thank you. -- being Mr. Epstein and Mr. Edwards, and the counterclaim brought by

through these and -- let me zoom in. On this top line are all of those circumstances subsequent to 4/9/09 when Bradley Edwards became a member of Rothstein, Rosenfeldt & Adler, which counsel says gave raise to a reasonable suspicion that Bradley Edwards was a knowing participant in the Ponzi scheme and was using fabrica

7524 fax October 13, 2010 Honorable David F. Crow Palm Beach County Courthouse Room 9.1215 205 N. Dixie Highway West Palm Beach, FL 33401 Re: Epstein v. Rothstein, et al. Palm Beach Circuit Case No. 50 2009 CA 040800XXXXMB-AG Dear Judge Crow: Enclosed please find a copy of the Joint Statement pu

• Fort Lauderdale • West Palm Beach EFTA00722471 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro.1201 Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M., individually,

CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro.12

ntiff. Those minor females were represented for a period of time first by Bradley J. Edwards, individually, and them by the now defunct Law Firm of Rothstein, Rosenfeldt & Adler, ("RRA") when Edwards joined that firm. Some of these lawsuits were transferred to a newly formed firm of Farmer, Jaffee, Weissing, Edwards, Fisto

ly, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. Case No. 50 2009 CA 040800XXXXMBAG Judge: CROW PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR ATTORNEYS' FEES PURSUANT TO §57.105 OF THE FLORIDA STATUTES Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his

R-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR ATTORNEYS' FEES PURSUANT TO §57.105 OF THE FLORIDA STATUTES Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to §57.105 of the Florida Statutes, hereby moves this Court for an award of attorneys' fees

CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, Counter-Defendant, vs. SCO

ls, and other unknown partners, engaged in serious misconduct involving a widely publicized illegal pyramid scheme operated through their law firm, Rothstein, Rosenfeldt & Adler. Rothstein himself admitted to, and was convicted for, this pyramid scheme, which featured civil cases against Epstein in which Edwards was lead co