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

iami, Florida 33129 pjm@pjmlawiniamicom (VIA CM/ECF and EMAIL) Robert P. Avolio, Esq. Crossroads Corporate Center 3150 Brunswick Pike, Ste. 120 Lawrenceville, NJ 08648 ravel io@avol iohanlon.com (Via Email and U.S. Mail) Mark S. Shipman, Esq. 20 Batterson Park Road, Suite 120 Farmington, CT 06032 mar

, 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

2840 S.W. Third Ave Miami Florida 3312 (VIA CM/ECF and EMAIL) Robert P. Avolio, Esq. Crossroads Corporate Center 3150 Brunswick Pike, Ste. 120 Lawrenceville. NJ 08648 (Via Email and U.S. Mail) Mark S. Shipman, Esq. 20 Batterson Park Road, Suite 120 Farmington. CT 06032 13 (Via Email and U.S. Mail) E

" < To:' "4 Subject: Your Trip to Paris Date: Mon, 04 Mar 2013 13:45:38 +0000 Good Morning Lesley, I notice that the flight reservation for Mr. Epstein were cancelled. Please let me know if anything changes and you would like to rebook. I would be more than happy to assist you. Wannest Regards, Jo

Lesley, I notice that the flight reservation for Mr. Epstein were cancelled. Please let me know if anything ch

happy to assist you. Wannest Regards, Jodine Hepburn American Express Consumer Travel Network Premium Service Travel Counselor 1755 N Brown Rd. Lawrenceville, GA 30043 t HOPE you WERE SD PLEASED WITH- YOUR SERVICE THAT you WOULD REFER AMERICAN EXPRESS TRAVEL TO A FRIEND. American Express made the follow

trip! But thank you! Lesley On Mar 4, 2013, at 8:45 AM, Jodine D Hepburn wrote: Good Morning Lesley, I notice that the flight reservation for Mr. Epstein were cancelled. Please let me know if anything changes and you would like to rebook. I would be more than happy to assist you. Warmest Regards, Jo

Lesley, I notice that the flight reservation for Mr. Epstein were cancelled. Please let me know if anything ch

you. Warmest Regards, Jodine Hepburn American Express Consumer Travel Network EFTA00394386 Premium Service Travel Counselor 1755 N Brown Rd. Lawrenceville, GA 30043 I HOPE you WERE SO PLEASED WITI-t youRSERWCE n-tAr you WO“LD REFER AMERICAN EXPRESS TRAVEL TO A FRIEND. American Express made the follow

trip! But thank you! Lesley On Mar 4, 2013, at 8:45 AM, Jodine D Hepburn wrote: Good Morning Lesley, I notice that the flight reservation for Mr. Epstein were cancelled. Please let me know if anything changes and you would like to rebook. I would be more than happy to assist you. Warmest Regards, Jo

Lesley, I notice that the flight reservation for Mr. Epstein were cancelled. Please let me know if anything ch

happy to assist you. Warmest Regards, Jodine Hepburn American Express Consumer Travel Network Premium Service Travel Counselor 1755 N Brown Rd. Lawrenceville, GA 30043 I HOPE you WERE SO PLEASED WITI-t youiz SERVICE rttAr you WOI4LD REFER AMERICAN EXPRESS TRAVEL roA FRIEND. American Express made the fol