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ned herein including, but not limited to, the discovery abuses and bad faith litigation tactics that Epstein has been the subject of at the hands of Scott Rothstein and his-co-conspirators, any tax returns must be redacted to preserve confidently and to prevent further abuses. See supra. Further, Epstein's com
ermore, as set forth in a Civil Complaint attached hereto as Exhibit ar attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A., deliberately engaged in a pattern of racketeering that involved a staggering series of gravely serious obstructions o
of $506,847.78 for 5 years of sexual harassment and sexual touching was reasonable). Unfortunately, the parties were unable to reach a agreement. Myers clearly demonstrates that Epstein's offer to agree to a net worth in excess of $50,000,00 is reasonable in light of the allegations made by Jane Doe
offer to agree to a net worth in excess of $50,000,00 is reasonable in light of the allegations made by Jane Doe as compared to the allegations in Myers. Moreover, allowing such discovery at this juncture goes against the grain and the law in that Plaintiff has not made a reasonable showing establish
ned herein including, but not limited to, the discovery abuses and bad faith litigation tactics that Epstein has been the subject of at the hands of Scott Rothstein and his-co-conspirators, any tax returns must be redacted to preserve confidently and to prevent further abuses. See supra. Further, Epstein's com
us civil litigation abuses that resulted in profoundly serious injury to Jeffrey Epstein, including substantial attorneys' fees and costs. In short, Rothstein and his co-conspirators forged Federal court orders and opinions and, among other things, staged a series of depositions that were unrelated to any
ures. Such a stipulation more than satisfies any necessity for the disclosure of the tax returns or any additional net worth information. See e.g., Myers v. Central Florida Investments, Inc., 592 F.3d 1201 (I Ith Cir. 2010)(reasoning that a compensatory award of $103,622.09 and a punitive damage award
of $506,847.78 for 5 years of sexual harassment and sexual touching was reasonable). Unfortunately, the parties were unable to reach a agreement. Myers clearly demonstrates that Epstein's offer to agree to a net worth in excess of $50,000,00 is reasonable in light of the allegations made by Jane Doe
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
ar-old Jason Roden of Loxahatchee. "He was a wonderful boy, and he did a lot for 111 ;29.9.3 • Absolut Vodka I Three Olives • -- '24.99 Myers Platinum Rum $1659 $ Chivas — Regal '49.99 The I $ , Macallan J‘. • 39.99 g Early lime • Canadian Mist .. 46.99 Wild Turkey '29
Entities connected to both Scott Rothstein and Myers

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
Kenneth Marra
PERSONRobert D. Critton
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSONSpencer Kuvin
PERSON
Salt Lake City
LOCATIONMichael J. Pike
PERSONLeon Black
PERSON
Scarlett Johansson
PERSON