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

as production of same would reveal Mr. Goldberger's mental impressions, thought processes and strategy relative to the defense of Epstein. Smith v. Florida Power & Light Company 632 Sold 696, 698 (Fla. 3 rd DCA 1994Xeven if individual documents are not work- product, "the selection process itself represents defense c

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

as production of same would reveal Mr. Goldberger's mental impressions, thought processes and strategy relative to the defense of Epstein. Smith v. Florida Power & Light Company, 632 So.2d 696, 698 (Fla. 3rd DCA 1994)(even if individual documents are not work- product, "the selection process itself represents defense

ley J. Edwards, Esq. and William J. Berger, Esq., Rothstein Rosenfeldt Adler, 401 East Las Olas Blvd., Suite

Miami, Keith E. Saxe, David C. Shilton and Ellen J. Durkee, Dept. of Justice, Washington. D.C., for arnicus/ U.S. PER CURIAM. AFFIRMED. Wait v. Florida Power & Light Co.. 372 So.2d 420 (Fla.1979). MINER, ALLEN and ICAHN. 33., concur. END OF DOCUMENT 09112/2019 Copr. ° West 1995 No claim to wig. U.S. govt. wor