Epstein Secrets

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

siness (e.g., physicians) wherein the records themselves have assumed public aspects which render them analogous to public documents. ,ate In re Dr. John Doe, 97 F.R.D. 640, 641- 643 (S.D.N.Y. 1982). Usually, these documents are known to more than the filer and the agency in which the document(s) were fil

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

usiness (e.g., physicians) wherein the records themselves have assumed public aspects which render them analogous to public documents. See In re Dr. John Doe, 97 F.R.D. 640, 641- 643 (S.D.N.Y. 1982). Usually, these documents are known to more than the filer and the agency in which the document(s) were fil

te 404 Lake Worth, FL 33461 Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Su

d 1188, 1192 (Fla. 4th DCA 1985); and Doherty v. John Doe No. 22, 957 So.2d 1267 (4th DCA 2007). A reading

01 19 20 21 22 Jennifer DiLorenzo, court reporter 23 24 25 EFTA00776366 2 1 APPEARANCES OF COUNSEL 2 3 On behalf of the Plaintiff: 4 ROTHSTEIN, ROSENFELDT & ADLER BY: WILLIAM J. BERGER, ESQ., 5 Mizner Park Office Tower Suite 675 6 225 NE Mizner Boulevard Boca Raton, FL 33432 7 8 RO

thin the bounds of reasonableness, 11 the Defendant is entitled to the information 12 contained in Interrogatory 19. 13 Now, with regard to the John Doe issue 14 relative to partners or Jane Doe, whoever may be 15 involved, I will permit, as did Judge Lewis in 16 her analysis, anyone who is name