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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
thers third-party privacy rights in that certain names may be mentioned in correspondence, including those on the "list." As noted in Eisenstadt v. Baird, 405 U.S. 438, 454, 92 S.Ct. 1029, 1038, at fn. 10 (1972): In 5tanley, 394 U.S., at 564, 89 S.Ct, at 1247, the Court stated:`(A)lso fundamental is
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
thers third-party privacy rights in that certain names may be mentioned in correspondence, including those on the "list." As noted in Eisenstadt v. Baird, 405 U.S. 438,454, 92 S.Ct. 1029, 1038, at fn. 10 (1972): In Stanley, 394 U.S., at 564, 89 S.Ct., at 1247, the Court stated:'(A)lso fundamental is
ential investor in August of 2009, but became suspicious. He stated "I was convinced it was all a Ponzi scheme and I notified the FBI in detail how Scotty ROTHSTEIN was hiding behind a legitimate law firm to peddle fake investments." Attorney Sakowitz was also quoted as saying ROTHSTEIN had sophisticated eavesd
ey claim a lack of knowledge when: a. The firm had 24 hour security in the form of Broward County Sheriff's officers on each floor of the offices; b. ROTHSTEIN had 24 hour (firm paid) security at his home; c. Partners/attorneys/staff could not directly access ROTHSTEIN without going through extensive secur
ist, Dr. Leonard Bard in Massachusetts; when the alleged police report reflected that EPSTEIN had only seen a chiropractor in Palm Beach named Dr. Baird. Obviously, no records existed for this alleged sex therapist, Dr. Bard, and the alleged subpoena for records was just another mechanism to "pump"
ential investor in August of 2009, but became suspicious. He stated "I was convinced it was all a Ponzi scheme and I notified the FBI in detail how Scotty ROTHSTEIN was hiding behind a legitimate law firm to peddle fake investments." Attorney Sakowitz was also quoted as saying ROTHSTEIN had sophisticated eavesd
problems with the firm existed when: a. RRA had 24 hour security in the form of Broward County Sheriffs officers on each floor of the law offices; b. ROTHSTEIN had 24 hour (firm paid) security at his home; c. Partners/attorneys/staff could not directly access ROTHSTEIN without going through extensive secur
ist, Dr. Leonard Bard in Massachusetts; when the alleged police report reflected that EPSTEIN had only seen a chiropractor in Palm Beach named Dr. Baird. Obviously, no records existed for this alleged sex therapist, Dr. Bard, and the alleged subpoena for records was just another mechanism to "pump"
UIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800X.XXXMB-AG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. SECOND AMENDED COMPLAINT The Plaintiff, Jeffrey Epstein, ("Epstein"), by and thro
The Plaintiff, Jeffrey Epstein, ("Epstein"), by and through his undersigned attorneys, files this action against the Defendants, Scott Rothstein, ("Rothstein") and Bradley J. Edwards ("Edwards") (collectively referred to as "Defendants") and alleges: INTRODUCTION This litigation has at its core a law fi
eged sex therapist, Dr. Leonard Baird in Massachusetts, when issues relating to Epstein's mental and emotional states were not at issue and when Dr. Baird had never even treated the Plaintiff (6) Directing and filing of Notices for the following health care professionals to produce medical records o
UIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800X.XXXMB-AG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. SECOND AMENDED COMPLAINT The Plaintiff, Jeffrey Epstein, ("Epstein"), by and thro
The Plaintiff, Jeffrey Epstein, ("Epstein"), by and through his undersigned attorneys, files this action against the Defendants, Scott Rothstein, ("Rothstein") and Bradley J. Edwards ("Edwards") (collectively referred to as "Defendants") and alleges: INTRODUCTION This litigation has at its core a law fi
eged sex therapist, Dr. Leonard Baird in Massachusetts, when issues relating to Epstein's mental and emotional states were not at issue and when Dr. Baird had never even treated the Plaintiff; (6) Directing and filing of Notices for the following health care professionals to produce medical records
Scarola Barnhart & Shipley, Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Su
the United States Supreme Court in Eisenstadt v. Baird, 405 U.S. 438,454, 92 S.Ct. 1029, 1038, at fn. 10
te 404 Lake Worth, FL 33461 Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Su
the United States Supreme Court in Eisenstadt v. Baird, 405 U.S. 438, 454, 92 S.Ct. 1029, 1038, at fn.
Entities connected to both Scott Rothstein and Baird

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJack Scarola
PERSONJane Doe
PERSON
George W. Bush
PERSONMaria Farmer
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSONRobert D. Critton
PERSON
Donald Trump
PERSONSpencer Kuvin
PERSON
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATIONMichael J. Pike
PERSONAtterbury Goldberger & Weiss
ORGANIZATIONMarc S. Nurik
PERSON
Salt Lake City
LOCATIONRobert C. Josefsberg
PERSON
Prince Andrew
PERSON