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

et, 7th Floor Miami, Florida 33132 Alison.Lehr®usdoj.gov Grisel.alonso®usdoj.gov (VIA CM/ECF and EMAIL) Jeffrey It Sonn, Esq. Sonn & Erez, PLC Broward Financial Center 500 E. Broward Boulevard Suite 1600 Fort Lauderdale, Florida 33394 jsonn®sonnerez.com (VIA CM/ECF and EMAIL) Office of the US Trustee 51 South

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

ehr, Esq. Assistant U.S. Attorney 99 N.E. 4th Street, 7th FL Miami, FL 33132 (Via CM/ECF) (Via CM/ECF) Jeffrey S. Sonn, Esq. Sonn & Erez, PLC Broward Financial Center 500 E. Broward Blvd., # 1600 Ft. Lauderdale, FL 33394 (Via CM/ECF) Honorable Jeffrey H. Sloman Acting U.S. Attorney 99 N.E. 41h Street Miami,

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

01 East Las Olas Boulevard Suite 1650 Fort Lauderdale, Florida 33301 [email protected] Jeffrey R. Sonn, Esq. (VIA EMAIL) Sonn & Erez, PLC Broward Financial Center 500 E. Broward Boulevard Suite 1600 Fort Lauderdale, Florida 33394 Phone: (954) 763-4700 Fax (954) 763-1866 [email protected] Office of the

witnesses that Defendants have listed on their Witness List not objected to by Plaintiff, Jane Doe. 151. All rebuttal witnesses. 152. All People on Jeffrey Epstein's Inmate Visitor Log while he was in jail. WITNESS TESTIMONY EXPECTED TO BE PRESENTED BY MEANS OF DEPOSITION 153' Mark Epstein 30 VANDAM STREET NEW

s Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: 561-383-9451 Attorneys for Bradley J. Edwards EFTA00798039 EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories COUNSEL LIST William Chester Brewer, Esquire [email protected]; wcbla

OUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, in

n Provident, L.P. 717 5th Avenue #I2A New York, NY 10022 28 . Lawrence LaVecchio United States Attorney's Office Southern District of Florida Broward Financial Center Fort Lauderdale, Florida. Will also confirm the leadership role played by Edwards in the prosecution of civil claims t ainst Epstein and the propri

, 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

et, 7th Floor Miami, Florida 33132 [email protected] [email protected] (VIA CM/ECF and EMAIL) Jeffrey R. Sonn, Esq. Sonn & Erez, PLC Broward Financial Center 500 E. Broward Boulevard Suite 1600 Fort Lauderdale, Florida 33394 (VIA CM/ECF and EMAIL) Office of the US Trustee 51 Southwest First Avenue S