Epstein Secrets

ten and Mr. Fandrey regarding their knowledge of Scott Rothstein's Ponzi scheme, the Court nevertheless entered a

Also, 111 the related matter of Epstein v. Rothstein, Case No. 502009CA040800XXXXMBAG, Judge Crow e

committing a crime or tort; and (4) the privilege has been (a) claimed and (b) not waived by the client. Id. at *2 (emphasis added), citing U.S. v. Noriega, 917 F.2d 1543, 1550 (11th Cir. 1990). 13. In Seeback, the court granted a protective order where a party sought to discover information from a pa

rn. Union, 103 F.3d 1007, 1012-13 (C.A. D.C. 1997) (string cite omitted)." (Emphasis added). 15. Also, in the related matter of Epstein v. Rothstein, Case No. 502009CA040800)OOOCMBAG, Judge Crow entered an order on April 19, 2010 (attached as Exhibit H), in which he granted a protective order

nted Jane Doe prior to its implosion. 5 EFTA00728108 16. While Epstein sought to depose Mr. Fisten and Mr. Fandrey regarding their knowledge of Scott Rothstein's Ponzi scheme, the Court nevertheless entered a protective order prohibiting their depositions until Epstein can "establish the relevance and discove

of committing a crime or tort; and (4) the privilege has been (a) claimed and (b) not waived by the client. Id. at *2 (emphasis added), agi U.S. v. Noriega, 917 F.2d 1543, 1550 (1 I th Cir. 1990). 13. In Seeback the court granted a protective order where a party sought to discover information from a p

BE NOTICED represented by Bradley James Edwards Rothstein Rosenfeldt Adler 401 East Las Olas Blvd Suite 1

access creates a presumption in favor of openness of court records, which "must be balanced against any competing interest advanced." United States Noriega, 752 F. Supp. 1037, 1040 (S.D. Fla.1990). For example, courts may look to see whether the records sought are for illegitimate purposes. Ma 696 F.2d