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

enue Fort Lauderdale, Florida 33301 (Via US Marl) Carpenter & Berger, PL 6400 N. Andrew Ave, suite 370 Fort Lauderdale, FL 33309 (Via US Mail) Frank F. McGinn, Esq. Bartlett Hackett Feinberg, P.C. 155 Federal Street, 9th Floor Boston, MA 02110 [email protected] (VIA CM/ECF and EMAIL) Darol H.

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

d Avenue, # 1440 Plantation, FL 33324-3906 (Via U.S. Mail) Miami, FL 33131 (Via CM/ECF) Leon County Tax Collector 315 S. Calhoun Street, # 210 Frank F. McGinn, Esq. Tallahassee, FL 32301 (Via U.S. Mail) Barlett Hackett Feinberg, P.C. 155 Federal Street, 0 FL Miami-Dade County Tax Collector Boston, MA

, 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

enue Fort Lauderdale, Florida 33301 (Via US Mail) Carpenter & Berger, PL 6400 N. Andrew Ave, suite 370 Fort Lauderdale, FL 33309 (Via US Mail) Frank F. McGinn, Esq. Bartlett Hackett Feinberg, ■. 155 Federal Street, 9th Floor Boston, MA 02110 (VIA CM/ECF and EMAIL) Darol H. M. Carr, Esq. 99 Nesbit Stre