Epstein Secrets

ves or any other electronic format and any written transcriptions). 11. All conversations recorded from any telephones which purported to be from Jeffrey Epstein's attorneys including Roy Black, Alan Dershowitz or Jack Goldberger, that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives

, joint-venture or business enterprise involving RRA, Rothstein or a Rothstein-related entity that reference any claim (real or fabricated) against Epstein. 14. All emails exchanged between-any of the following individuals wherein Epstein, a Palm Beach billionaire or similar reference was mentioned:

n or agreement. C. "Plaintiff' means M. (I. v. Jeffrey Epstein, Palm Beach County Case #502008CA028051X

stify at the taking of a deposition in the above case. (Documents may be produced in lieu of attendance) PLACE OF DTTOSITION Conrad & Scherer 633 South Federal Highway 8th Floor Fort Lauderdale, FL 33301 DATE AND TIME. November 12,2010 at 10: [ X ] YOU ARE COMMANDED to produce and permit inspection and copying

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

P Four Seasons Tower 15th Floor 1441 Brickell Avenue Miami, Florida 33131-3407 [email protected] (VIA CM/ECF and EMAIL) Conrad & Scherer, LLP 633 South Federal Highway Fort Lauderdale, FL 33301 [email protected] JSilven@conradscherencom (VIA CM/ECF and EMAIL) EFTA00724500 Case 09-34791-RBR Doc 1120 Filed

ves or any other electronic format and any written transcriptions). II. All conversations recorded from any telephones which purported to be from Jeffrey Epstein's attorneys including Roy Black, Alan Dershowitz or Jack Goldberger, that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives

, joint-venture or business enterprise involving RRA, Rothstein or a Rothstein-related entity that reference any claim (real or fabricated) against Epstein. 14. All emails exchanged between-any of the following individuals wherein Epstein, a Palm Beach billionaire or similar reference was mentioned:

or agreement. C. "Plaintiff means L.M. (L.M. v. Jeffrey Epstein, Palm Beach County Case #502008CA028051X

ember 12, 2011) at 10:00 a.m.. EFTA00731271 Case 09-34791-RBR Doc 1063 Filed 10/13/10 Page 2 of 8 at the offices of Conrad & Scherer, LLP, 633 South Federal Highway, Fort Lauderdale, FL 33301. The examination may continue from day to day until completed. If the examinee receives this notice less than 14 days pr

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

1-3407 tt(4)tewlaw.com [email protected] EFTA00780313 Case 09-34791-RBR Doc 818 Filed 07/19/10 Page 8 of 10 Conrad & Scherer, LLP (VIA EMAIL) 633 South Federal Highway Fort Lauderdale, FL 33301 Tel: 954-462-5500 [email protected] [email protected] Michael D. Seese, Esq. (VIA EMAIL) Hinshaw & Culbert

, 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

w-Cardenas, LLP Four Seasons Tower 15th Floor 1441 Brickell Avenue Miami. Florida 33131-3407 (VIA CM/ECF and EMAIL) Conrad & Scherer, LLP 633 South Federal Highway Fort Lauderdale. FL 33301 (VIA CM/ECF and EMAIL) Honorable Jeffrey H. Sloman Acting U.S. Attorney 99 NE 4th Street Miami, Fl 33132 (Via U.S. M

ves or any other electronic format and any written transcriptions). 12. All conversations recorded from any telephones which purported to be from Jeffrey Epstein's attorneys including Roy Black, Alan Dershowitz or Jack Goldberger, that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives

93-Marra/Johnson), and any other person who is or was represented by Rothstein Rosenfeldt & Adler that has not yet filed an action against .leffre, Epstein, and any employee, agent or attorney for any plaintiff and/or any other person acting for or on behalf of any plaintiff, or under her authority and

n or agreement. C. "Plaintiff means =. (MI. v. Jeffrey Epstein, Palm Beach County Case #502008CA0280S1X

2/11 Page 2 of 8 Bankruptcy for Rothstein Rosenfeldt Adler, under oath on March 2, 2011 at 10:00 M., at the offices of Conrad & Scherer, LLP, 633 South Federal Highway, Fort Lauderdale, FL 33301. The examination may continue from day to day until completed. If the examinee receives this notice less than 14 days pr

., Debtor. CASE NO.: 09-34791-RBR CHAPTER I I MOTION TO CLARIFY PRIOR ORDERS REGARDING SPECIAL MASTER APPOINTED TO DETERMINE PRIVILEGE ISSUES RE EPSTEIN RELATED DOCUMENTS TO MAKE CLEAR THE RAZORBACK CREDITORS' RIGHT TO FULLY PARTICIPATE IN PROCESS, OR ALTERNATIVELY, TO AUTHORIZE THE RAZORBACK CREDI

cial master process. The special master process was put in place by this Court's August 13, 2010 Order Respecting Production of Documents Regarding Jeffrey Epstein (DE #8881, and subsequently clarified and amended by this Court's October 15, 2010 Amended Order Respecting Production of Documents Regarding Jeffre

der Respecting Production of Documents Regarding Jeffrey Epstein (DE #8881, and subsequently clarified and

54 [email protected] JAMES D. SILVER Florida Bar No. 373702 [email protected] CONRAD & SCHERER, LLP Counsel for Creditors 633 South Federal Highway Fort Lauderdale, FL 33301 Tel: (954) 847-3324 Fax: (954) 463-9244 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing has