Epstein Secrets

rives or any other electronic format and any written transcriptions) 13. 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

ated third party litigation, such as this one. 6. While the Trustee has indicated in a different lawsuit his willingness to try to product to Mr. Epstein the documents he needs, in order that the Trustee's responsibility for winding-up the affairs of the Estate is not impeded and because of the limite

Civ. P. 1.201 Case No. 50 2009CA040800XVOCMB AG JEFFREY EPSTEIN, Plaintiff, V. SCOTT ROTHSTEIN, indivi

ent lawsuit his willingness to try to product to Mr. Epstein the documents he needs, in order that the Trustee

with this Warrant, and to serve copies of said Claim and Answer upon the United States Attorney, 99 NE 4th Street, Miami, Florida 33132, Attention: Alison W. Lehr, Assistant United States Attorney, and that upon failure of the owner, possessor or any party claiming an interest in the defendant properties to do

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

M. Mulli, Esquire Tripp Scott 110 Southeast Sixth Street Fifteenth Floor Fort Lauderdale, Fl. 33301 jgb®trippscott.com (VIA CM/ECF and EMAIL) Alison W. Lehr, Esq. Grisel Alonso, Esq. Assistant United States Attorney 99 N.E. 4th Street, 7th Floor Miami, Florida 33132 Alison.Lehr®usdoj.gov Grisel.alon

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

cayne Blvd. Miami, FL 33131 (Via U.S. Mail and email) John G. Bianco, Esq. Tripp Scott 110 S.E. Sixth Street, 15th FL Ft. Lauderdale, FL 33301 Alison W. Lehr, 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 Bro

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

q. (VIA CM/ECF) John M. Mulli, Esquire Tripp Scott 110 Southeast Sixth Street Fifteenth Floor Fort Lauderdale, Fl. 33301 [email protected] 7 Alison W. Lehr (VIA EMAIL) Assistant United States Attorney 99 N.E. 4th Street 7th Floor Miami, Florida 33132 Phone: (305) 961-9176 Fax: (305) 536-7599 Aliso

, 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

Fax: (561) 802-9976 The Honorable Herbert M. Stettin, Trustee One Biscayne Tower Suite 3700 Two South Biscayne Boulevard Miami, Florida 33131 Alison W. Lehr, Esq. Grisel Alonso, Esq. Assistant United States Attorney 99 E. 4th Street, 7th Floor Miami, Florida 33132 [email protected] Grisel.alonso