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

1 Boca Raton, FL 33432 rfc®colemanattorneys.com (VIA CM/ECF and EMAIL) Mark S. Heitman, Esq. Lamm Rubenstone, LLC 3600 Horizon Blvd, Suite 200 Trevose, PA 19053 [email protected] (VIA CM/ECF and EMAIL) Robert C. Buschel, Esq. 100 S.E. Third Ave, Suite 1300 Fort Lauderdale, FL 33394

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

n, Esq. Roderick F. Coleman, Esq. Lamm Rubenstone, LLC 400 S. Dixie Highway, # 121 3600 Horizon Blvd., # 200 Boca Raton, FL 33432 (Via CM/ECF) Trevose, PA 19053 (Via email and Robert C. Buschel, Esq. U.S. Mail) 100 S.E. Third Avenue, # 1300 Ft. Lauderdale, FL 33394 (Via email and U.S. Mail) 6

, 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

h Dixie Highway, Suite 121 Boca Raton. FL 33432 (VIA CM/ECF and EMAIL) Mark S. Haltzman, Esq. Lamm Rubenstone, LLC 3600 Horizon Blvd, Suite 200 Trevose, PA 19053 (VIA CM/ECF and EMAIL) Robert C. Buschel, Esq. 100 S.E. Third Ave, Suite 1300 Fort Lauderdale, FL 33394 (VIA CM/ECF and EMAIL) Berkow