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

and EMAIL) Rogers, Morris & Ziegler, LLP 1401 East Broward Blvd Suite 300 Fort Lauderdale, FL 33301 [email protected] (VIA CM/ECF and EMAIL) Arthur C. Neiwirth, Esq. One E. Broward Blvd., Suite 1400 Ft. Lauderdale, FL 33301 [email protected] (VIA CM/ECF and EMAIL) 7 The Florida Bar Adria E. Quint°

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

ler, LLP (VIA EMAIL) 1401 East Broward Blvd Suite 300 9 Fort Lauderdale, FL 33301 Tel: (954) 462-1431 Fax: (954) 763-2692 [email protected] Arthur C. Neiwirth, Esq. (VIA CM/ECF) One E. Broward Blvd., Suite 1400 Ft. Lauderdale, FL 33301 Tel: (954)523-7008 Fax: (954) 523-7009 aneiwirtb(giqpwblaw.com The

, 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

Fl 33146 (VIA CM/ECF and EMAIL) Rogers, Morris & Ziegler, LLP 1401 East Broward Blvd Suite 300 Fort Lauderdale, FL 33301 (VIA CM/ECF and EMAIL) Arthur C. Neiwirth, Esq. One E. Broward Blvd., Suite 1400 Ft. Lauderdale, FL 33301 (VIA CM/ECF and EMAIL) Marc Nurik, Esq. 1 East Broward Blvd Suite 700 Fort Lau