Epstein Secrets

Counsel for Defendant Jeffrey Epstein Case 9:08-cv-80119-KAM Document 405 Entered on FLSD Docket 11/12/2009 Page 10 of 33 L.M. Plaintiff, V. JEFFREY EPSTEIN, Defendant. ____________ __;/ IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA028051XXXX

IDENCE, & 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, pursuant to Rules 26, 34, and 37, Fed.R.Civ.P. (2009), moves for entry of an order for the preservatio

eturn for settlement funds alleged paid or to be paid on behalf of Jeffrey Epstein; c. Soliciting money to help finance ongoing litigation against Jeffrey Epstein; d. Soliciting money to be given to, or used on behalf of, the plaintiffs in litigation against Jeffrey Epstein; Case 9:08-cv-80119-KAM

ORE CLERK U.S. DIST. CT. S.D. OF FLA. - W.P.B. DEFENDANT EPSTEIN'S EMERGENCY MOTION FOR ORDER FOR THE PRESERVATIO

18 of 33 e. Communication between third party investors or potential investors and the plaintiffs or their attorneys involved in litigation against Jeffrey Epstein; f. Payments made by RRA to or on behalf of any plaintiff 2. Any and all fee agreements that exist or have existed between the following:

or attorney for any plaintiff and/or any other person acting for or on behalf of any plaintiff, or under her authority and control. D. "RRA" means Rothstein Rosenfeldt & Adler, P.A. E. "Money" means any tangible thing of value. REQUESTED ITEMS 1. For the time period from January 1, 2008, to present, any and all docwnents re

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. Case No. 50 2009 CA 040800XXXXMB AG SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWA

ive as necessary in order to bring within the scope of each request all documents which might otherwise be construed to be outside its scope. 5. "Epstein" refers to Jeffrey Epstein, the Plaintiff in the captioned lawsuit. 6. " , "you" or "yours" refers to 7. "Edwards" means Bradley J. Edwards, a de

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

aptioned lawsuit. 8. "Rothstein" means Scott W. Rothstein, a defendant in the captioned lawsuit. 3 EFTA00600175 9. "RRA" means the law firm of Rothstein Rosenfeldt & Adler, P.A., and any of its past or present employees, independent contractors, attorneys, partners, shareholders, investigators, agents or other representativ

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. Case No. 50 2009 CA 040800XXXXMB AG SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWA

ive as necessary in order to bring within the scope of each request all documents which might otherwise be construed to be outside its scope. 5. "Epstein" refers to Jeffrey Epstein, the Plaintiff in the captioned lawsuit. 6. 7. "Edwards" means Bradley J. Edwards, a defendant in the captioned lawsuit

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

aptioned lawsuit. 8. "Rothstein" means Scott W. Rothstein, a defendant in the captioned lawsuit. 3 EFTA00656513 9. "RRA" means the law firm of Rothstein Rosenfeldt & Adler, P.A., and any of its past or present employees, independent contractors, attorneys, partners, shareholders, investigators, agents or other representativ