Epstein Secrets

ten and Mr. Fandrey regarding their knowledge of Scott Rothstein's Ponzi scheme, the Court nevertheless entered a

Also, 111 the related matter of Epstein v. Rothstein, Case No. 502009CA040800XXXXMBAG, Judge Crow e

r conversations with hei· supervising partner as the questions invaded the attorney-client privilege). 14. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Wi

rn. Union, 103 F.3d 1007, 1012-13 (C.A. D.C. 1997) (string cite omitted)." (Emphasis added). 15. Also, in the related matter of Epstein v. Rothstein, Case No. 502009CA040800)OOOCMBAG, Judge Crow entered an order on April 19, 2010 (attached as Exhibit H), in which he granted a protective order

nted Jane Doe prior to its implosion. 5 EFTA00728108 16. While Epstein sought to depose Mr. Fisten and Mr. Fandrey regarding their knowledge of Scott Rothstein's Ponzi scheme, the Court nevertheless entered a protective order prohibiting their depositions until Epstein can "establish the relevance and discove

er conversations with her supervising partner as the questions invaded the attorney-client privilege). 14. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it is not without limits. Washington v. & William

Esq. Brad Edwards, Esq. Adam D. Horowitz, Esq. Rothstein Rosenfeldt Adler Mermelstein & Horowitz, P.A. 4

d beyond September of 2005. Therefore whatever information Mr. Zinoview may have, postdates that time. 5. Regarding the scope of discovery, Judge Linnea Johnson noted in her October 28, 2009 Omnibus Order (DE #377), "[w]hile the scope of discovery is broad, it is not without limits. Washington v. Brown & Wi