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nt prosecution agreement with Edwards' counsel, whereby both parties agreed to share information relative to their claims and/or defenses related to Scott Rothstein without waiving privilege as to their communications or documents shared." Edwards' Supp. Resp. to Epstein's Mot. to Declare Relevance, July 26, 201
in (e.g., victims of) Rothstein Rosenfeldt & Adler's Ponzi scheme, in the Razorback litigation. These investors were unquestionably adverse to both Rothstein and Edwards' law firm of which he was a partner. Despite this, Edwards voluntarily produced documents that he now claims are privileged to Mr. Scher
edly privileged documents to a government agency, as part of efforts at cooperation. For example, in Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414 (3d Cir. 1991), the Court addressed "whether a party that discloses information protected by the attorney-client privilege and the wo
TEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / COUNTER-DEFENDANT JEFFREY EPSTEIN'S NOTICE OF SUPPLEMENTA
roduct protection as to grand jury materials). Exhibit B, at 36 n.13. Epstein also files as Exhibit C the August 4, 2010, hearing transcript; In re Rothstein Rosenfeldt Adler, P.A., United States Bankruptcy Court, Southern District of Florida, Case No. 09- 34791-BKC-RBR, The following are statements made
xhibit B, at 35-36. Edwards supported this last statement with the following authorities: See, e.g., Westinghouse Electric Corp. v. Republic of the Philippines, 951 F.2d 1414, 1429 (3d Cir. 1991) (Westinghouse's disclosure of work product materials to the Justice Department during an investigation "waived
re: Morgan Stanley Fund Services (Bermuda) Ltd. Rothstein Kass Domestic: Bingham McCutchen LLP Offshore:
(Asia). Major Asian utility and infrastructure focus covered the following countries: China, Korea, India, Thailand, Malaysia, Singapore, Indonesia, Philippines, Japan and Pakistan. Before moving to Asia, Jos was a Team Leader in UBS' global project finance group in New York (1989 -1995) where he advised/ar
TEIN & liOROWIT2, P.A. BY: ADAI4HORownt ESQ. 4 6 7 8 9 10 11 12 13 14 15 16 12 18 19 20 21 22 23 24 25 la y , .,„ 6, and 7. ROTHSTEIN ROSENfELOT ADLER BY: BRAD J. EDWARDS, ESQ., and PODHURST ORSECK SQ. Attorney for lane Doe 101 and 102. Palm Bead, Gardens, Florida 33410 Attorn
in Paris, good friend of mine 9 from Brazil. And the people in New York give me 10 the briefing when I came aboard. There is a 11 couple from the Philippines. And I talked to the 12 couple that used to own the Island -- I mean who 13 used to manage the Island, a couple from South 14 African. Balsone was
ywood. Me- morial service Saturday. Rodriguez, Eugenio, 64, of West Palm Beach. died June 2. All County Funeral Home and Cre- matory. Like Worth. Rothstein, Violet, 86, of Boca Raton, died Tuesday. Levitt- Weinstein Memorial Chapel, West Palm Beach. Service Friday. Rulz,Mada 1,83, of Boca Raton, die
00, is an archipelago of eight main islands plus more than 250 islets that is best known for diving and tourism. It's about 500 miles east of the Philippines in the Pa- cific Ocean. -ii ,---- , INCREDIBLE SAVINGS FOR 30%-85% OFF STOREWIDE PLUS WOMEN'S, MEN'S & KIDS' APPAREL ETERNITY SUMMER FOR HIM&
Florida 33410 21 Attorney for 22 23 24 25 ROTHSTEIN ROSPMFELDT ADLER BY: BRAD J. EDWARDS, ESQ., and
good friend of mine 8 9 from Brazil. And the people in New York give me 9 10 the briefing when I came aboard. There is a 10 11 couple from the Philippines. And I talked to the 11 12 couple that used to own the Island -- I mean who 12 13 used to manage the Island, a couple from South 13 14 Africa
LEY J. EDWARDS, ESQUIRE CARA L. HOLMES, ESQUIRE ROTHSTEIN ROSENFELDT ADLER 401 E. Las Olas Boulevard, Suit
t, you traveled to New York. When was the next time afLeL Lecover.ed fLum lies sulyety Uiat you went to New York? A I think when she went to the Philippines. O Okay. She went for like a vacation to go to visit her family? A No. I'm not really good. There was time I went there because I think I somet
oduction 188:11,14 192:18 173:3 174:19,20 217:15 189:10 ROSENFELDT 180:14,15 179:16 resign 191:7 133:9 184:1 182:3,4,14 186:3 192:25 ROTHSTEIN saying ESQUIRE u•Aleusin Gab•Compass Toll Free: 866.709.8777 Facsimile: 501.394.3621 Suite 600 4440 PGA Boulevard Palm Beach Gardens, FL 3341
194:19 195:2,15 196:3,6 pool 148:22 149:6 page 220:18 persons piece 149:10,13 134:18 201:4 party 167:2 157:24 149:23,25 215.12 143:19 Philippines place 150:2 218:11 145:14 145:6 146:6 174:6 175:9 151:17 220:6 146:3,20,23 phone 178:24 152:4,12 pages 217:12 132:23 133:5 196:11 Pop
Entities connected to both Scott Rothstein and Philippines

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJack Scarola
PERSON
George W. Bush
PERSONJane Doe
PERSONMaria Farmer
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSON
Donald Trump
PERSON
United States
LOCATION
Prince Andrew
PERSON
Marc Rich
PERSON
Kenneth Marra
PERSONLeon Black
PERSONPalm Beach Lakes Boulevard
LOCATIONRobert D. Critton
PERSON
Bill Clinton
PERSONSpencer Kuvin
PERSON
Ghislaine Maxwell
PERSON