Epstein Secrets

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M., i

VED FOR HUNG DEC u ( 2008 sriesnoN Ii poCK COMPLAINT pLefitt Elk COMPTRQw-liti CIRCUIT CIVIL olvisiON Plaintiff, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually,

■ EPSTEIN and like other RRA clients, sought tens of millions of dollars. a. For example, in her sworn statement to the FBI, was insistent that "Jeffrey is an awesome man." (p. 21 — FBI); At the conclusion of she stated: "I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it

hat the evidence is really going to show is that Mr. Epstein — at least dating back as EFTA00729419 Epstein

onymous females were represented by RRA, with the potential for hundreds of millions of dollars in settlements, and that RRA and its attorneys would El Epstein unless he paid exorbitant-settlement amounts to protect his high-profile friends. 26. Upon information and belief, EDWARDS knew or should have kno

Iguana, Pembroke Pines, Florida; (B18) Scott W. Rothstein's equity interest in Cart Shield USA, LLC; (819) Scott W. Rothstein's equity interest in Renato Watches; (BI10) Scott W. Rothstein's equity interest in Edify LLC; (BM) Scott W. Rothstein's equity interest in V Georgio Vodka; (BI12) Scott W. Rothstein

• IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, v. cor.50.2929aufactigIVP111, CASE NO. • A Aq SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and .M., individu

OTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and .M., individually, Defendants. COMPL CO Plaintiff, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually,

ases and thus by using the deposition sell the cases (or a part of them) to third parties. #4S 37. Because of these facts, ROTHSTEIN claimed that Epste wanted to make certain none of these individuals would be deposed and therefoie he had offered $200,000,000.00 to settle the claims of RRA female

EPSTEIN and like other RRA clients, sought tens of millions of dollars. a. For example, in her sworn statement to the FBI, L.M. was insistent that "Jeffrey is an awesome man." (p. 21 — FBI); At the conclusion of she stated: "I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it

hat the evidence is really going to show is that Mr. Epstein — at least dating back as completely irrelevant

uity y4rest af6 Iguana, Pembroke Pines, Florida; (BI8) Scott W. Rothstein's e (BI9) Scott W. Rothst interrst in Cart Shield USA, LLC; nterest in Renato Watches; (8110) Scott W. Rot Equity interest in Edify LLC; (B111) Scott W. Rothstein's equity interest in V Georgio Vodka; (B112) ott W. Rothstein's equi

EXHIBIT A EFTA00596488 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M.,

RECEIVED FOR FILING oic 0 1Mg EMIVION It PUCK COMPLAINT GlAilit QQMPTR966011 PINWIT CIVIk,P1\11algi Plaintiff, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually,

EPSTEIN and like other RRA clients, sought tens of millions of dollars. a. For example, in her sworn statement to the FBI, L.M. was insistent that "Jeffrey is an awesome man." (p. 21 — FBI); At the conclusion of she stated: "I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it

hat the evidence is really going to show is that Mr. Epstein — at least dating back as EFTA00596504 Epstein

Iguana, Pembroke Pines, Florida; (BI8) Scott W. Rothstein's equity interest in Cart Shield USA, LLC; (B19) Scott W. Rothstein's equity interest in Renato Watches; (8110) Scott W. Rothstein's equity interest in Edify LLC; (BD I) Scott W. Rothstein's equity interest in V Georgio Vodka; (B112) Scott W. Rothste

te that the Non-Prosecution Agreement "called for Mr. Epstein to serve eighteen months in county jail followed

able through Tide 28, United States Code, Section 2461; and the procedures outlined at Title 21, United States Code, Section 853. .1 04 , 044 Co' JEFFREY a SLOMAN ACTING UNITED STATES ATTORNEY PAUL F. SCHWARTZ ASSISTANT UNITED STATES ATTORNEY JEFFRE N. KAPLAN ASSIS ANT UNITED STATES ATTORNEY CE D

August 4, 2009 VIA ELECTRONIC MAIL Spencer T. Kuvin, Esq. Leopold—Kuvin, P.A. 2925 PGA Boulevard Suite 200 Palm Beach Gardens, FL 33410 Re: Jeffrey Epstein/B.B. — Requested Disclosure of Non-Prosecution Agreement Dear Mr. Kuvin: Thank you for your letter regarding the disclosure of the Non-Prosecution Agree

t is necessary to correct certain inaccuracies contained in that communication. First, you state that the Non-Prosecution Agreement "called for Mr. Epstein to serve eighteen months in county jail followed by twelve months of community control." In fact, the Non-Prosecution Agreement, at 1 2 (a) and (b)

rest in Café Iguana, Pembroke Pines, Florida; Scott W. Rothstein's equity interest in Cart Shield USA, LLC; Scott W. Rothstein's equity interest in Renato Watches; (BI10) Scott W. Rothstein's equity interest in Edify LLC; (BIl 1) Scott W. jtothstein's equity interest in I Georgio Vodka; (B112) Scott W. Roths

AARON ANTHON MARCOS BEATON, JR. MATTHEW P. O'BRIEN JENIPER J. SOULII0AS NOAH Fox E-Mail: You emailed me a letter on November 2, asking whether Jeffrey Epstein's place of employment remained constant. It has. I reviewed a Google map to confirm that the distance between that place of employment and the locati

ime and effort. Over the past five weeks, the massive billion-dollar conspiracy created and run by Scott Rothstein has been exposed. On Monday, Mr. Epstein filed a state civil RICO lawsuit charging Rothstein, his partner Brad Edwards, and others with tortuous and fraudulent abuses of process that result

sue EPSTEIN and like other RRA clients, sought tens of millions of dollars. a. For example, in her sworn statement to the FBI, was insistent that "Jeffrey is an awesome man." (p. 21 — FBI); At the conclusion of she stated: "I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it

by Scott Rothstein has been exposed. On Monday, Mr. Epstein filed a state civil RICO lawsuit charging Rothste

Iguana, Pembroke Pines, Florida; (1318) Scott W. Rothstein's equity interest in Cart Shield USA, LLC; (B19) Scott W. Rothstein's equity interest in Renato Watches; (3110) Scott W. Rothstein's equity interest in Edify LLC; (B111) Scott W. Rothstein's equity interest in, Georgio Vodka; (3112) Scott W. Rothstei

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

(Via U.S. Mail) Honorable Jeffrey H. Sloman Acting U.S. Attorney 99 NE 4th Street Miami, Fl 33132 (Via U.S. Mall) Daniel Mink Ovadia Levy do Renato Watches, Inc 14051 NW 14th Street Sunrise, Florida 33323 (Via U.S. Mail) William George Salim, Jr. Moskowitz Mandell & Salim 800 Corporate Dr Ste 510

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

. Mail) Internal Revenue Service Centralized Insolvency Operations POB 21126 Philadelphia, PA 19114 (Via U.S. Mail Daniel Mink Ovadia Levy do Renato Watches, Inc. 14051 N.W. 14 Street Sunrise, FL 33323 (Via U.S. Mail) EFTA00727975 USI Ann: Anthony Gruppo 200 West Cypress Creek Road, # 500 Case No

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

Via U.S. Mail) Honorable Jeffrey H. Sloman, Acting U.S. Attorney 99 NE 4th Street Miami, Fl 33132 (Via U.S. Mall) Daniel Mink Ovadia Levy c/o Renato Watches, Inc 14051 NW 14th Street Sunrise, Florida 33323 (Via U.S. Mail) William George Salim, Jr. (VIA CM/ECF) Moskowitz Mandell & Salim 800 Corporate

, 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

M/ECF and EMAIL) Honorable Jeffrey H. Sloman Acting U.S. Attorney 99 NE 4th Street Miami, Fl 33132 (Via U.S. Mail) Daniel Mink Ovadia Levy do Renato Watches, Inc 14051 NW 14th Street Sunrise, Florida 33323 (Via U.S. Mail) William George Salim, Jr. Moskowitz Mandell & Salim 800 Corporate Dr Ste 510

ounsel For The United Stales: Lawrence LaVecchio. Jeffrey Kaplan. and Paul Schwartz Coun Reporter: Tammy

Iguana, Pembroke Pines, Florida; (818) Scott W. Rothstein's equity interest in Cart Shield USA, LLC; (B19) Scott W. Rothstein's equity interest in Renato Watches; -10- EFTA00596601 Case 0:09-cr-60331-JIC Document 290 Entered on FLSD Docket 06/09)201n Page 21 of 29 (BII0) Scott W. Rothstein's equity intere