Epstein Secrets

nt. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as well as Scott Rothstein. Edwards' former law partner. ee infra. Kam incorrectly states that "Imlore recent cases" in this Circuit and District have demoted the showing req

more so in light of Epstein's admission in his lawsuit against M. and others that he that he was "one of M's many `Johns.— See Complaint Epstein v. Rothstein, Edwards & M s, No. 50 2009 CA0 40800 (Cir. Ct., 15th Jud. Cir., Palm Beach Co.. Dec. 7, 2009) at 146(a), pertinent pages annexed as Ex. E to the C

d, counsel offered to provide an affidavit from Rush confirming that he conducted a phone interview of Epstein, but that offer was flatly rejected. (Carroll Reply Dec1.19.) - 13 - EFTA00728026 completely misconstrues the third prong of the test. There is nothing relevant, material or necessary to her

nt. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as well as Scott Rothstein. Edwards' former law partner. ee infra. 1° Doe incorrectly states that "Imlore recent cases" in this Circuit and District have demoted the showing

ges in his complaint against M. 13 12 The document is available online at http://www.scribd.com/doc/23947743/121009-epstein. "Complaint, Epstein v. Rothstein et al., II 42(h)(i) ("M. testified that she ... worked at various strip clubs; is an admitted prostitute and call girl; has a history of illegal dru

d, counsel offered to provide an affidavit from Rush confirming that he conducted a phone interview of Epstein, but that offer was flatly rejected. (Carroll Reply Dec1.19.) - 13 - EFTA00207349 completely misconstrues the third prong of the test. There is nothing relevant, material or necessary to her

and other documents in the Trustee's possession, respecting the subject matter of the subpoena previously served upon the Trustee related to L.M., Scott Rothstein, Brad Edwards and Jeffrey Epstein. . . Contemporaneous with the service and filing of the privilege log, Fanner Jaffe shall provide to a reputable

RICT OF FLORIDA Fort Lauderdale Division In re ROTHSTEIN ROSENFELDT ADLER, P.A. Debtor. Chapter 11 Case

lear and convincing is a higher standard and requires a high probability of success"). Importantly, the burden to prove contempt is on the Movants. Carroll v. TheStreetcom, Inc., II-CV-81173, 2014 WL 5474048, at *9 (S.D. Fla. Apr. 10, 2014). Fowler White is "not tasked with the affirmative responsibili

‘opportunity to‘even hear Epstein’ s voice utter any. ‘substantive words other than (in essence} “I take the Fifth.” ~ As part of our discussion, Ms. Carroll told me'thatitwasa° 4 “stupid move” for Mr. Rush to play the tape or disclose the tape. to other people as he likely waived any © ne pan privilege.

at I had filed on behalf of my clients against Epstein and that it has been alleged that these lawsuits were used to fraudulently lure investors into Rothstein’s Ponzi scheme. I never met a single investor, had no part in any such presentations and had no knowledge any such fraud was occurring. If these alle

information to prove the cases against Jeffrey Epstein and accordingly I pursued them in discovery. In approximately November 2009, the existence of Scott Rothstein’s Ponzi scheme became public knowledge. It was at that time that I, along with many other reputable attorneys at RRA, first became aware of Rothstein c