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RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor. CASE NO.: 09-34791-RBR CHAPTER 11 MOTION FOR RELIEF FROM AMENDED ORDER ID.E. 1068t AND TO COMPEL JEFFREY EPSTEIN TO PAY FOR THE PRODUCTION OF ALL DOCUMENTS IN RESPONSE TO HIS REOUEST Movants, LM and Bradley J. Edwards, move this Court for relief from Amended O
omen who allege that they were sexually exploited, sexually abused, and otherwise victims of intentional and despicable conduct of Jeffrey Epstein. Epstein's conduct has been the subject of several lawsuits vigorously litigated by Mr. Edwards, as well as similar lawsuits filed by other well-known attor
IEF FROM AMENDED ORDER ID.E. 1068t AND TO COMPEL JEFFREY EPSTEIN TO PAY FOR THE PRODUCTION OF ALL DOCUMEN
om JSilven@conradscherencom (VIA CM/ECF and EMAIL) EFTA00724500 Case 09-34791-RBR Doc 1120 Filed 11/02/10 Page 6 of 11 Michael D. Seese, Esq. Hinshaw & Culbertson, LLP I E Broward Blvd Ste 1010 Ft Lauderdale, Florida 33301 [email protected] (VIA CM/ECF and EMAIL) Internal Revenue Service Centralized I
LORIDA Fort Lauderdale Division www. flsb.uscourts.gov IN RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor. Case No. 09-3479 I-BKC-RBR Chapter 11 JEFFREY EPSTEIN'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS FROM TRUSTEE PURSUANT TO DOCUMENT PRODUCTION PROTOCOL ESTABLISHED BY DE #672 JEFFREY EPSTEIN ("EPSTEIN"),
EPSTEIN'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS FROM TRUSTEE PURSUANT TO DOCUMENT PRODUCTION PROTOCOL ESTABLISHED BY DE #672 JEFFREY EPSTEIN ("EPSTEIN"), by and through undersigned counsel, respectfully moves this Honorable Court pursuant to the provisions of Fed.R.Civ.37(a) (which is incorporated
Debtor. Case No. 09-3479 I-BKC-RBR Chapter 11 JEFFREY EPSTEIN'S MOTION TO COMPEL PRODUCTION OF DOCUMEN
enue Miami, FL 33131 (Via CM/ECF) Conrad & Scherer, LLP 633 South Federal Highway Ft. Lauderdale, FL 33301 (Via CM/ECF) Michael D. Seese, Esq. Hinshaw & Culbertson, LLP I E Broward Blvd., # 1010 Ft. Lauderdale, FL 33301 (Via CM/ECF) William George Salim, Jr. Moskowitz Mandell & Salim 800 Corporate Dr., # 51
2 of 10 privilege and/or attorney work product. II. Background 3. Movant, L.M. is a party plaintiff in a civil lawsuit' against party defendant Jeffrey Epstein in which she alleges that Epstein sexually exploited, abused, and/or assaulted her when she was a minors. The parties recently reached a confidentia
ereof, states as follows: I. Introduction 1. Jeffrey Epstein, through his counsel, seeks to pull the wool over the eyes of this honorable Court. Epstein asks this Court to usurp the properly exercised jurisdiction of the Circuit Court over a subpoena duces tecum issued by the state court in connectio
STETTIN OF PRIVILEGED DOCUMENTS AND TESTIMONY TO JEFFREY EPSTEIN Movant, L.M., moves this Court pursuant
h Federal Highway Fort Lauderdale, FL 33301 Tel: 954-462-5500 [email protected] [email protected] Michael D. Seese, Esq. (VIA EMAIL) Hinshaw & Culbertson, LLP 1 E Broward Blvd Ste 1010 Ft Lauderdale, Florida 33301 Tel: 954.4677900 Fax: 954.4671024 [email protected] Internal Revenue Service C
, FJW on behalf of LM states as follows: I. BACKGROUND A. The Pending Summary Judgment and Protective Order Motions As this Court is well aware, Jeffrey Epstein (a convicted sex offender) has sued one of his alleged victims, ■ as well as attorney, Bradley J. Edwards, Esq.', in Florida state court for cond
rds, Esq.', in Florida state court for conduct that allegedly occurred in the course of Edwards' representation of multiple young female victims of Epstein's sexual abuse. While an employee of the now defunct Rothstein, Rosenfeldt, Adler firm and with his current firm, Edwards filed and pursued civil la
ctive Order Motions As this Court is well aware, Jeffrey Epstein (a convicted sex offender) has sued one o
Mulli, Esquire Tripp Scott 110 Southeast Sixth Street Fifteenth Floor Fort Lauderdale. Fl. 33301 (VIA CM/ECF and EMAIL) Michael D. Seese, Esq. Hinshaw & Culbertson, LLP 1 E Broward Blvd Ste 1010 Ft Lauderdale. Florida 33301 (VIA CM/ECF and EMAIL) Internal Revenue Service Centralized Insolvency Operations B
ests have slowed and many court proceedings are on hold, investigators say their work can't stop. Read full article Victims' Rights Suffer Blow In Epstein Case In the latest twist in the Jeffrey Epstein saga, a split Eleventh Circuit panel ruled last week that the protections of the Crime Victims' Rig
Page: EFTA00032906 →gs are on hold, investigators say their work can't stop. Read full article Victims' Rights Suffer Blow In Epstein Case In the latest twist in the Jeffrey Epstein saga, a split Eleventh Circuit panel ruled last week that the protections of the Crime Victims' Rights Act do not arise until after a formal crimin
Page: EFTA00032906 →Blow In Epstein Case In the latest twist in the Jeffrey Epstein saga, a split Eleventh Circuit panel rule
Page: EFTA00032906 →ey & Lardner Foley Hoag Fragomen Del Rey Fried Frank Fross Zelnick Gibson Dunn Goldberg Segalla Goodwin Greenberg Traurig Greenspoon Marder Hinshaw & Culbertson Hodgson Russ Hogan Lovells Hogan Thompson LLP Holland & Knight Hueston Hennigan Husch Blackwell Immigration Law PLLC Jackson Lewis Jones Day
Page: EFTA00032907 →Entities connected to both Jeffrey Epstein and Hinshaw & Culbertson

Prince Andrew
PERSON
Eric Trump
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
Lawrence Krauss
PERSON
Stephen Hawking
PERSONMaria Farmer
PERSONthe Southern District
LOCATION
David Rodgers
PERSONScott Rothstein
PERSONRobert D. Critton
PERSONJack Scarola
PERSON
Jeffrey Sloman
PERSON
Eric Holder
PERSON
Jacksonville
LOCATION
Philadelphia
LOCATION
Houston
LOCATION
Fort Lauderdale
LOCATIONAce Greenberg
PERSON