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

ested documents, as to their authenticity, and as to the defendant's selection of them as meeting the requests for production. ate United States v. Hubbell, 530 U.S. 27, 35-36 (2000). Thus, where the existence or location of the requested documents are unknown, or where production would "implicitly auth

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

ested documents, as to their authenticity, and as to the defendant's selection of them as meeting the requests for production. See United States v. Hubbell, 530 U.S. 27, 35-36 (2000). Thus, where the existence or location of the requested documents are unknown, or where production would "implicitly auth

Scarola Barnhart & Shipley, Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Su

areas that could result in criminal prosecution. Hubbell, 530 U.S. at 35-36. Accordingly, any compelled te

A. 18205 Biscayne Boulevard Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Su

nd as well in areas that could result in criminal prosecution. See generally Hoffman v United States, 341 U.S. 479, 486 (1951) and United States v. Hubbell, 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000). Again, the information sought also relates to potential federal claims of violations. See DE 282 and

-383-9424 [email protected] Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Su

nd as well in areas that could result in criminal prosecution. See generally Hoffman v United States, 341 U.S. 479, 486 (1951) and United States v. Hubbell, 530 U.S. 27, 36, 120 S.Ct. 2037, 2043 (2000). 11. Therefore, Epstein is not required to produce any documents or responses to interrogatories. I

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

mpelled testimonial aspect. See United States v. Hubbell, 530 U.S. 27, 35-36 (2000). Thus, where the exis

ounsel for Plaintiff, C.M.A. Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Su

e act of production where, as here, it involves a self-incriminating testimonial communication or "a compelled testimonial aspect." United States v. Hubbell, 530 U.S. 27, 120 S.Ct. 2037 (2000); Fisher v. United States, 425 U.S. 391 (1976); McCormick on Evidence, Title 6, Chap. 13. The Privilege Against

iami, FL 33160 305-931-2200 Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Su

predictably used to bolster the criminal-related allegations against Epstein. See generally Hoffman v United States 341 US 479, 486 (1951), U.S. v Hubbell, 530 U.S. 27, 36 (2000). 11 Case 9:08-cv-80119-KAM Document 282 Entered on FLSD Docket 08/31/2009 Page 12 of 20 12 Case 9:08-cv-80119-KA

iami, FL 33160 305-931-2200 Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Su

a compelled testimonial aspect." United States v. Hubbell, 530 U.S. at 36; see also Fisher v. United State

Suite 2218 Miami, H., 33160 Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Su

e act of production where, as here, it involves a self-incriminating testimonial communication or "a compelled testimonial aspect." United States v. Hubbell, 530 U.S. 27, 120 S.Ct. 2037 (2000); Fisher v. United States, 425 U.S. 391 (1976)• McCormick on Evidence, Title 6, Chap. 13. The Privilege Against