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

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

sult in criminal prosecution. See generally Hoffman v United States, 341 U.S. at 486; United States v. Hubbell, 530 U.S. at 36 and United States v. Apfelbaum, 445 U.S. at 128. The Court's order seems to hone in on the "required records" exception for the proposition that, as a matter of law, Epstein's pe

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

o Plaintiffs discovery requests. United States v. Apfelbaum, 445 U.S. 115, 128 (1980). The Fifth Amendment

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

he claimant must [also] be 'confronted by substantial and 'real,' and not merely trifling or imaginary, hazards of incrimination." United States v. Apfelbaum, 445 U.S. 115, 128 (1980). Accordingly, responses to the requests propounded upon Epstein would provide information which is protected by the privi

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

o Plaintiffs discovery requests. United States v. Apfelbaum, 445 U.S. 115, 128 (1980). The Fifth Amendment s

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

7)). "The claimant must be 'confronted by substantial and 'real,' and not merely trifling or imaginary, hazards of incrimination." United States v. Apfelbaum, 445 U.S. 115, 128 (1980). Accordingly, for these reasons, Epstein's objections to the Magistrate's Order should be sustained, and this Court shoul

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

nary, hazards of incrimination." United States v. Apfelbaum, 445 U.S. 115, 128 (1980). Accordingly, response