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2010 seeking the similar relief. The grounds for this motion are: 1. Late last year, Epstein filed this action to recover damages from Defendants, Scott Rothstein ("Rothstein") and Edwards, based on Epstein's well founded belief that the two, and possibly others, had perpetrated an illegal pyramid scheme direc
WLER WHITE BURNETT P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA00606624 Epstein v Rothstein, Edwards CASE NO. 502009CA040800=OCMBAG Notice of Hearing PLEASE GOVERN YOURSELVES ACCORDINGLY. In accordance with the Americans With Disabilitie
a good faith job hunt in order to receive benefits for lost wages, was not a confidential communication within the ambit of the privilege; see also Watkins v. State, 516 So. 2d 1043 (Fla. 1st DCA 1987), rev. denied, 523 So.2d 579 (Fla. 1988) (defendant's former attorney not barred 13 EFTA00606638 fr
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
9-34791-RBR Doc 6323 Filed 03/19/18 Page 16 of 23 with their lawful orders through civil contempt remedies. Citronelle-Mobile Gathering, Inc. v. Watkins, 943 F.3d 1297. 1301 (11th Cir. 1991). Courts also have the inherent power to sanction a party for misconduct. Chambers v. Nasco, 501 U.S. 32, 42 (1
ALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. / PLAINTIFF JEFFREY EPSTEIN'S MOTION TO COMPEL PRODUCTION OF
eral orders entered by Judge Raymond Ray in the Bankruptcy Court, filed a one hundred and fifty-nine (159) page privilege EFTA00582857 Epstein v. Rothstein and Edwards DRAFT 2/3/12 4:26 PM Case No. 502009CA040800XXXXMB/Div. AG log, claiming that over two thousand (2000) documents are privileged.' Th
tions were intended to be disclosed to third parties or did not involve the giving of legal advice, in which case there is no privilege. See, e.g., Watkins v. State, 516 So. 2d 1043, 1046 (Fla. 1g DCA 1987). VI. THE WORK-PRODUCT PRIVILEGE CANNOT BE DETERMINED FROM EDWARDS' PRIVILEGE LOG 9 EFTA005828
Entities connected to both Scott Rothstein and Watkins

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJack Scarola
PERSONJane Doe
PERSON
George W. Bush
PERSONMaria Farmer
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Alan Dershowitz
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Paul Cassell
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Donald Trump
PERSONPalm Beach Lakes Boulevard
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Searcy Denney Scarola Barnhart & Shipley
ORGANIZATIONMarc S. Nurik
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Prince Andrew
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United States
LOCATION
Ghislaine Maxwell
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Weissing
PERSONLeon Black
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Scarlett Johansson
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Bill Clinton
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