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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
tein 08-CV80119 Page No. 23 from any disclosures and are therefore different than a regulated/public record that can be accessed by the public. In Trudeau v. New York State Consumer Protection Bd., 237 F.R.D. 325 (N.D.N.Y. 2006), the court maintained that "[r]outine discovery of tax returns is not the
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
tein 08-CV80119 Page No. 23 from any disclosures and are therefore different than a regulated/public record that can be accessed by the public. In Trudeau v. New York State Consumer Protection Bd., 237 F.R.D. 325 (N.D.N.Y. 2006), the court maintained that "[r]outine discovery of tax returns is not the
& Brown" *sutinfirm.com Pete! w/2 Schoenberg "Rothstein Donatelli" *rothsteinlaw.corn Frank w/2 Bond J
arten Steptoe *steptoe.com Michael w/2 Miller Justin w/2 Chu Michael w/2 Rips Paul w/2 Hoffman "Sch
ntiff, /env Doe: 3 BRAD J. ED WARDS. ESQ1.7IRE ROTHSTEIN ROSIDIPELDT ADLER Las Oles City Cant, Stitt 1650
t. Are aware that E.W. had a sexual 14 relationship, as did..., with both Justin Sprague and 15 Cory Sprague? 16 A. I knew that E.W. had dated Justin before 17 did. 18 Q. Okay. Were you aware that she had a — had 19 sexual activity, both with — or with Justin Sprague? 20 A. No. 21 Q. Did
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
as Jessica Sullivan. a Boca cry on the other end." said Sul- Raton 911 dispatcher who helped livan, who lives in Port St. Lucie. Haupert deliver son Justin, who After receiving her award, Sul- ; weighed 6 pounds, 14 ounces. livan cradled Justin in her arm. "Without her I would have "lie is absolutely
oburn it Associated with Other Companies EXECUTIVE 44. Peteka, Richard L CHIEF FINANCIAL OFFICER (06/2007) 45. Press, Eric L EXECUTIVE 46. Rothstein, Stuart A it Associated with Other Companies CHIEF FINANCIAL OFFICER 47. Rowan. Marc ../ Moderate Risk * Associated with Other Companies EXECU
ated with Other Companies EXECUTIVE 57. Stein. Elliot Jr. / Moderate Risk it Associated with Other Companies DIRECTOR (06/2007) 58. Stevens, Justin EXECUTIVE 59. Stone. Aaron J PARTNER 60. Strong. Geoffrey D EXECUTIVE 61. Suydam, John J it Associated with Other Companies EXECUTIVE 62.
0012613 EFTA01734442 March 2, 2010 EPSTEIN V. ROTHSTEIN TRIAL DATE: None DISCOVERY CUTOFF: None • Im
SR reset for 3/11/10 depo completion 4. D se Justin Vanover 5. 6. Justin Sprague and 7. usta 8.
Privilege Terms - Search Warrant Returns Term "Rothstein Donatelli' aSchonbrun Seplow Harris & Hoffman°
ydam 478 658 448 June w/2 Hoffman 27 49 0 Justin w/2 Chu 924 1,289 6 kirkland.com 8,894 11,3
0 0 °Riley Safer Holmes & Cencila" 0 0 0 "Rothstein Donatelli" 2 2 0 °Schonlmun Seplow Harris &
lege Terms_02.14.2020 Term Documents with hits Justin w/2 Chu 212 Lilly w/2 Sanchez 5,282 Margot w1
Entities connected to both Scott Rothstein and Justin Trudeau

Jeffrey Epstein
PERSON
Bradley Edwards
PERSON
George W. Bush
PERSON
Lesley Groff
PERSONJack Goldberger
PERSONJack Scarola
PERSONJane Doe
PERSONLeon Black
PERSON
Donald Trump
PERSON
Prince Andrew
PERSON
Alan Dershowitz
PERSON
Marc Rich
PERSONMaria Farmer
PERSON
Bill Clinton
PERSON
JPMorgan Chase
ORGANIZATION
Paul Cassell
PERSONDarren Indyke
PERSON
Lawrence Krauss
PERSON
Julie K. Brown
PERSON
Ghislaine Maxwell
PERSON