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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
9 Fort Lauderdale, Florida 33301 jslatkin®slatkinreynolds.com (VIA CM/ECF and EMAIL) ASSOULINE & BERLOWE, P.A. 213 East Sheridan Street, Ste. 3 Dania Beach, FL 33004 Attn: Eric N. Assouline, Esq. [email protected] (VIA CM/ECF and EMAIL) Steven J. Reisman, Esq. CURTIS, MALLET-PREVOST, COLT &
, 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
ne East Broward Boulevard, Suite 609 Fort Lauderdale. Florida 33301 (VIA CM/ECF and EMAIL) ASSOULINE & BERLOWE, 213 East Sheridan Street, Ste. 3 Dania Beach, FL 33004 Attn: Eric N. Assouline, Esq. (VIA CM/ECF and EMAIL) Steven J. Reisman, Esq. CURTIS, MALLET-PREVOST, COLT & MOSLE LLP 101 Park Avenue
f engaging in illicit sexual conduct (§ 2423). 6. Beginning in October 2005, the City of Palm Beach Police Department ("PBPD") began investigating Jeffrey Epstein, a part-time resident of the City of Palm Beach, along with his personal assistant, Sarah Kellen. PBPD obtained information from a fourteen-year-old
rmed PBPD that she had been paid $300 by Jeffrey Epstein to perform a "sexual massage," which entailed providing a massage to Jeffrey Epstein while Epstein was naked and the fourteen-year-old was wearing only her thong panties. During the massage, Jeffrey Epstein masturbated himself and touched the fou
h Police Department ("PBPD") began investigating Jeffrey Epstein, a part-time resident of the City of Palm
a grand piano for $55,120 that was delivered to 912'MillCreek. • Drive, Palm Beach Gardens, Florida: Records and testimony provided bySQund,ildvice Dania Beach, Florida based stereo and televisicin retail store indicate that behveen•June • 2001 and June 2005 approximately $492,892.64 worth of consumer audio
of the space was reserved for this small wedding — greatly exceeding the per person square footage allowed by the order." The New York Times (10/8, Epstein, 18.61M) reports that the wedding, "first reported Thursday by The Atlanta Journal-Constitution," took "place early in the coronavirus pandemic, as
his arrest on July 31, in Sealy, Texas, by the FBI's Criminal Apprehension Team." FBI Seeks Florida Bank Robber. WFOR-TV Miami (10/8) reports from Dania Beach, Florida, "The FBI is releasing photographs of a female bank robber wanted for stealing money from a Dania Beach bank at gunpoint." According to WF
quare footage allowed by the order." The New York Times <https://www.nytimes.com/2020/10/08/us/elections/mark-meadows-daughter- wedding.html> (10/8, Epstein, 18.61M) reports that the wedding, "first reported Thursday by The Atlanta Journal-Constitution," took "place early in the coronavirus pandemic, as
Robber. WFOR-TV <https://miami.cbslocal.com/2020/10/08/fbi-seeks-bank-bandit-who-struck-coral-gables-wells-fargo- branch/> Miami (10/8) reports from Dania Beach, Florida, "The FBI is releasing photographs of a female bank robber wanted for stealing money from a Dania Beach bank at gunpoint." According to WFO
of the space was reserved for this small wedding — greatly exceeding the per person square footage allowed by the order." The New York Times (10/8, Epstein, 18.61M) reports that the wedding, "first reported Thursday by The Atlanta Journal-Constitution," took "place early in the coronavirus pandemic, as
his arrest on July 31, in Sealy, Texas, by the FBI's Criminal Apprehension Team." FBI Seeks Florida Bank Robber. WFOR-TV Miami (10/8) reports from Dania Beach, Florida, "The FBI is releasing photographs of a female bank robber wanted for stealing money from a Dania Beach bank at gunpoint." According to WF
of the space was reserved for this small wedding — greatly exceeding the per person square footage allowed by the order." The New York Times (10/8, Epstein, 18.61M) reports that the wedding, "first reported Thursday by The Atlanta Journal-Constitution," took "place early in the coronavirus pandemic, as
his arrest on July 31, in Sealy, Texas, by the FBI's Criminal Apprehension Team." FBI Seeks Florida Bank Robber. WFOR-TV Miami (10/8) reports from Dania Beach, Florida, "The FBI is releasing photographs of a female bank robber wanted for stealing money from a Dania Beach bank at gunpoint." According to WF
Entities connected to both Jeffrey Epstein and Dania Beach
Leon Black
PERSON
Prince Andrew
PERSON
Eric Trump
PERSON
George Mitchell
PERSON
Alan Dershowitz
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Lawrence Krauss
PERSON
Condoleezza Rice
PERSON
Glenn Dubin
PERSON
Newark
LOCATION
Stephen Hawking
PERSONJack Goldberger
PERSON
Sarah Kellen
PERSON
Joe Biden
PERSON
Prince Charles
PERSON
Barry Diller
PERSON
Department of Justice
ORGANIZATION