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

argain are important components of this country's criminal justice system. Properly administered, they can benefit all concerned." Bordenkircher v. Hayes, 434 U.S. 357, 361-62 (1978), quoting Blackledge v. Allison, 431 U.S. 63, 71 (1977). To encourage defendants to participate in the plea negotiation

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

argain are important components of this country's criminal justice system. Properly administered, they can benefit all concerned." Bordenkircher v. Hayes, 434 U.S. 357, 361-62 (1978), quoting Blackledge v. Allison, 431 U.S. 63, 71 (1977). To encourage defendants to participate in the plea negotiation

fic items: [a]II e-mails, data, correspondence, and similar documents dated April 1, 2008 through August 1, 2010 by and between Bradley J. Edwards. Scott W. Rothstein, Marc hlurik, Cam Holmes, Mike Fisten and any one of the following regarding or mentioning Jeffrey Epstein in any way: (a) the U.S. Attorney's Offi

EDWARDS. In addition, the Motion seeks authority to direct a subpoena to the Bankruptcy Trustee of the former law firm of the Defendants EDWARDS and ROTHSTEIN. The Court finds that the Amended Request for Production and request for subpoena, does request documents which the Court finds are either relevant

such, when a party fails to comply with a pretrial order, a court has broad discretion in determining sanctions. First Republic Corp. of America v. Hayes, 431 So. 2d 624 (Fla. 3d DCA 1983). Accordingly, Defendant Edwards' inapposite and patent disregard for this Court's Order mandates sanctions. Fina

NTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPO

EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individua

ase law." Thigpen v. United Parcel Servs., Inc., 990 So. 2d 639, 645 (Fla. 4th DCA 2008) (citing Johnson v. State, 863 So. 2d 271, 278 (Fla. 2003)); Hayes v. Wal- Man Stores, Inc., 933 So. 2d 124, 126 (Fla. 4th DCA 2006); DeVille v. State, 917 So. 2d 1058, 1059 (Fla. 4`h DCA 2006); Dixon v. State, 911

3. In late 2009, Epstein sued Edwards for purportedly improperly representing his clients who were Epstein's sex abuse victims. Jeffrey Epstein v. Scott Rothstein, Bradley J. Edwards, and LM., Fifteenth Judicial Circuit, in and for Palm Beach County, Florida Case No. 50-2009 CA 040800XXXX MB AG (hereinafter "

e No. 50-2009 CA 040800XXXX MB AG (hereinafter "the Epstein lawsuit"). 4. On April 17, 2010, Epstein served a subpoena in the Epstein lawsuit upon Rothstein Rosenfeldt Adler, PA ("RRA") Bankruptcy Trustee Howard Stettin, seeking to obtain documents from the Trustee, which included documents from attorne

on-compliance with orders of the Court constitutes civil contempt if the party has not in good faith made all reasonable efforts to comply. U.S. v. Hayes. 722 F.2d 723, 725 (11th Cir. 1984). However, "if the court finds the defendant acted willfully or maliciously in disregarding the injunction, then

ifferent litigation in which he himself — not Jane Doc — is a party. Specifically, in January 2010 the managing partner of Edwards' former law firm, Scott Rothstein, pled guilty and was sentenced to 50 years in prison for a massive "Ponzi" scheme in which he defrauded investors of $1.2 billion by convincing the

brought a civil lawsuit against Edwards in Florida state court in which he alleges that Edwards was involved in, or knew or should have known about, Rothstein's Ponzi scheme, and pleads claims against Edwards for fraud and violation of Florida's racketeering statute as well as an abuse of process claim al

Cir. 1994) 13 Baxter v. Palmigiano, 425 U.S. 308 (1976) 21 Buttner v. Berg & Dorf, 138 ad 439, 525 MI.2d 858 (2d Dep't 1988) 19 Branzburg v. Hayes, 408 U.S. 665 (1972) 23 Brown & Williamson Tobacco CS E. v. Wigand, 1996 WL 350827 (Sup. Ct. OS Co. Feb. 28, 1996), affd, 228 ..2r1187, 643 92 (

ENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, vs. Plaintiff/Counter-Defendant, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OMNI

EFTA00585430 142. All pleadings filed by Epstein in the Rothstein Bankruptcy Proceeding. 143. All submissions by Epstein in connection with the Rothstein deposition. 144. All Settlement Agreements between Epstein and victims of his sexual molestations. 145. Phone journal taken from Epstein's home a

case law." Thigpen v. United Parcel Servs., Inc., 990 So. 2d 639, 645 (Fla. 4th DCA 2008) (citing Johnston v. State, 863 So.2d 271, 278 (Fla.2003); Hayes v. Wal- Mart Stores, Inc., 933 So. 2d 124, 126 (Fla. 4th DCA 2006); Deville v. State, 917 So. 2d 1058, 1059 (Fla. 4th DCA 2006); Dixon v. State, 911