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t within his law firm and his client, that being Mr. Epstein. When further asked by the court, has Mr. Epstein
-RBR Doc 6482 Filed 10/19/18 Page 4 of 97 COURT: I disagree with you. .... Take that up in your state court litigation. (Apr. Tr. 43:19-45:6.) B. Epstein has Provided Sworn Testimony and His Attendance at the Show Cause Hearing is Not Necessary. The Court allowed Movants to take Epstein's deposition
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
ief Expedited Hearing Requested on or before October 24, 2018, so that the Court may rule prior to the October 26, 2018, hearing) Jeffrey Epstein ("Epstein") moves the Court, on an expedited basis, to be excused from attending the October 26, 2018, show cause hearing, and states: INTRODUCTION On April
n the United States Virgin Islands, August /‘(2018. I declare under penalty of perjury that the foregoing is true and correct. APPROV FORM: RNEY REY EPSTEIN EFTA00793497
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
ered users on the CM/ECF system, which includes counsel identified on the service list below. RICE PUGATCH ROBINSON STORFER & COHEN, PLLC By: /s/ Chad P. Pugatch CHAD P. PUGATCH (FBN [email protected] - AND — I hereby certify that I am admitted to the Bar of the United States District Court for the Sout
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
wed to intervene in this action, now respectfully submits this Motion to Compel Jeffrey Epstein to Provide Answers to Deposition Questions. Because Epstein has improperly refused to answer multiple questions at his recent deposition, the motion should be granted. Relevant Factual Background The facts
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
he Agreed Order." DE 6366 at 5 (citing DE 1194). Mr. Epstein improperly refused to answer many questions about
ils' Primary E-Mail: Searcy Denney Scarola Barnhart & Shipley, P.A. Attorneys for Bradley J. Edwards Scott J. Link, Esq. Link &Rockenbach, P.A. Chad P. Pugatch, Esq. Rice Pugatch Robinson Storfer & Cohen, PLLC 11 EFTA00793509 Case 09-34791-RBR Doc 6488 Filed 10/22/18 Page 12 of 165 Niall T. McLachla
gov IN RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor. CASE NO.: 09-34791-RBR CHAPTER 11 INTERVENOR-VICTIM L.M.'S WITHDRAWAL OF MOTION TO COMPEL JEFFREY EPSTEIN TO PROVIDE ANSWERS TO DEPOSITION QUESTIONS Intervenor L.M., proceeding pseudonymously, having previously been allowed to intervene in this action,
IM L.M.'S WITHDRAWAL OF MOTION TO COMPEL JEFFREY EPSTEIN TO PROVIDE ANSWERS TO DEPOSITION QUESTIONS Inter
NOR-VICTIM L.M.'S WITHDRAWAL OF MOTION TO COMPEL JEFFREY EPSTEIN TO PROVIDE ANSWERS TO DEPOSITION QUESTION
. Vitale, Jr. Es Florida Bar No.: Attorney E-Mails Primary E-Mail: Attorneys for Bradley J. Edwards Scott J. Link, Esq. Link &Rockenbach, P.A. Chad P. Pugatch, Esq. Rice Pugatch Robinson Storfer & Cohen, PLLC Attorneys for Jeffrey Epstein EFTA00793666 Case 09-34791-RBR Doc 6495 Filed 10/24/18 Page 4 o
ORT LAUDERDALE DIVISION www.flsb.uscourts.gov IN RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor. CASE NO. 09-34791-RBR CHAPTER 11 ORDER GRANTING JEFFREY EPSTEIN'S MOTION TO STRIKE INTERVENORS E.W.'S AND JANE DOE'S ALLEGED DAMAGES AND REOUESTS FOR RELIEF BASED ON THEIR LACK OF STANDING f ECF 6456 AND 64571 TH
09-34791-RBR CHAPTER 11 ORDER GRANTING JEFFREY EPSTEIN'S MOTION TO STRIKE INTERVENORS E.W.'S AND JANE D
CASE NO. 09-34791-RBR CHAPTER 11 ORDER GRANTING JEFFREY EPSTEIN'S MOTION TO STRIKE INTERVENORS E.W.'S AN
resulting from alleged violations of this Court's November 30, 2010, Order which forms the basis of the Order to Show Cause herein. Submitted by: Chad P. Pugatch, Esq. Rice Pugatch Robinson Storfer & Cohen, PLLC 101 N.E. Third Avenue, Suite 1800 Ft. Lauderdale, FL 33301 Telephone: (954) 462-8000 Telefax:
issing Edwards Fistos & Lehrman, Bradley J. Edwards and Intervenors L.M., E.W. and Jane Doe, voluntarily dismiss their Motions for Contempt against Jeffrey Epstein with prejudice and all causes of action which have or could have been asserted in this action and all claims for all forms of damages, including co
compensatory damages, sanctions, punitive damages, prejudgment interest, costs and attorneys' fees. Farmer Jaffe, Edwards, L.M., E.W., Jane Doe and Epstein will each bear their own attorneys' fees and costs. Dated: , 2018. Respectfully submitted, EDWARDS POTTINGER LLC Bradley J. Edwards FLBN Britt
arily dismiss their Motions for Contempt against Jeffrey Epstein with prejudice and all causes of action
rickell Avenue, Suite 1900 Miami, FL 33131 Miami, FL 33131 Counsel for Fowler White Burnett, P.A. Counsel for Liquidating Trustee Scott J. Link Chad P. Pugatch Kara Berard Rockenbach Link & Rockenbach, PA Rice Pugatch Robinson Storfer & Cohen, PLLC 101 N.E. Third Avenue, Suite 1800 1555 Palm Beach Lakes
ne in this action, and having participated in the Court's hearings on these matters, and pursuant to this Court's order of August 16, 2018, denying Epstein's motion to strike the victims' previously filed list of requested relief (DE 6427), now file this summary of their damages. The factual background
hen, PLLC Ft. Lauderdale FL 33301 Attorneys for Jeffrey Epstein EFTA00809902 Niall T. McLachlan Carlton Field
hen, PLLC Ft. Lauderdale FL 33301 Attorneys for Jeffrey Epstein EFTA00809902 Niall T. McLachlan Carlt
, Florida 33409 Phone: Fax: Attorneys for Bradley J. Edwards Scott J. Link, Esq. Link &Rockenbach P.A. West Palm Beach. FL 33401 Phone: Fax: Chad P. Pugatch, Esq. Rice Pu atch Robinson Storfer & Cohen, PLLC Ft. Lauderdale FL 33301 Attorneys for Jeffrey Epstein EFTA00809902 Niall T. McLachlan Carlto
tor. INTERVENOR-VICTIMS M., M.. AND RESPONSE TO JEFFREY EPSTEIN'S MOTION TO TAKE THEIR DEPOSITIONS AND T
lsb.uscourts.gov IN RE: CASE NO.: 09-34791-RBR ROTHSTEIN ROSENFELDT ADLER, P.A., CHAPTER 11 Debtor. INTERVENOR-VICTIMS M., M.. AND RESPONSE TO JEFFREY EPSTEIN'S MOTION TO TAKE THEIR DEPOSITIONS AND TO COMPEL THEIR MENTAL EXAMINATIONS Intervenors M., and " " (hereinafter collectively "the Victims"), procee
mously, having previously been allowed to intervene in this action, and having participated in the Court's hearings on these matters, now respond to Epstein's motion to compel their depositions and to compel their mental examinations. Epstein's motion, filed by a man who repeatedly sexually abused the v
h, Florida 33409 Phone: Fax: Attorneys for Bradley J. Edwards Scott J. Link, Esq. Link &Rockenbach P.A. West Palm Beach FL 33401 Phone: Fax: Chad P. Pugatch, Esq. Rice Pu atch Robinson Storfer & Cohen, PLLC Ft. Lauderdale. FL 33301 Attorneys for Jeffrey Epstein 11 EFTA00810612 Niall T. McLachlan C
Entities connected to both Jeffrey Epstein and Chad P. Pugatch
Darren Indyke
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
Condoleezza Rice
PERSONJack Goldberger
PERSONJane Doe
PERSON
Michael Cohen
PERSONMaria Farmer
PERSONthe Southern District
LOCATION
Paul Cassell
PERSON
New York
LOCATIONScott Rothstein
PERSONJack Scarola
PERSONTonja Haddad Coleman
PERSONGoldberger & Weiss
ORGANIZATIONFISTOS & LEHRMAN
ORGANIZATION
Weissing
PERSONJaffe
PERSONPalm Beach Lakes Boulevard
LOCATION
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATION