Epstein Secrets

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

09-34791-RBR Doc 1120 Filed 11/02/10 Page 5 of 11 MASTER SERVICE LIST CASE NO.: 09-34791-BKC-RBR Marianella Morales, Esquire Authorized Agent For Joining Creditors Avenida Francisco de Miranda Torre Provincial "A" Piso 8 Caracas, Venezuela (VIA CM/ECF and EMAIL) John H. Genovese, Esq. Robert F. Elgidely,

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

4791-RBR Doc 818 riled 07/19/10 Page 7 of 10 SERVICE LIST CASE NO.: 09-34791-BEC-RBR Marianella Morales, Esquire (VIA EMAIL) Authorized Agent For Joining Creditors Avenida Francisco de Miranda Torre Provincial "A" Piso 8 Caracas, Venezuela John H. Genovese, Esq. (VIA CM/ECF) Robert F. Elgidely, Esq. There

, 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

nue South, Suite 1400 West Palm Beach, FL 33401 Phone: (561) 659-8300 Fax: (561) 835-8691 Fort Marianella Morales, Esquire Authorized Agent For Joining Creditors Avenida Francisco de Miranda Tone Provincial "A" Piso 8 Caracas, Venezuela (VIA CM/ECF and EMAIL) John H. Genovese, Esq. Robert F idely, Esq.