Epstein Secrets

HE STATE OF FLORIDA FOURTH DISTRICT Appellate Case No. 4D18-0787 LT Case No. 502009CA040800XXXXMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants.1 REPLY TO RESPONSE TO PETITION FOR WRIT OF CERTIORARI On Review of a

d Not Wait for a Favorable Disposition of Epstein's Claims Against Him Before Filing His Malicious Prosecution Counterclaim Epstein's claim against Rothstein (originally filed as a claim against both Rothstein and Edwards) in connection with the use of Epstein case materials, which were improperly utiliz

ounsel for Plaintiff/Counter-Defendant Jeffrey Epstein CERTIFICATE OF TYPE SIZE & STYLE I certify that the type, size, and style utilized in this Petition is 14-point Times New Roman. Is/ Kara Berard Rockenbach 15 EFTA00808470

IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, -VS- SCOTT individually, Intervenors.' ROTHSTEIN, BRADLEY J. individually, and and JANE DOE, Respondents CASE NO. 4D18-0762 RESPONSE TO EMERGENCY PETITION FOR WRIT OF MANDAMUS SEARCY DENNY S

ember 7, 2009, while Edwards was pursuing the cases noted above on behalf of his clients, Epstein filed the original Complaint here against Edwards, Scott Rothstein ("Rothstein"), and one of Edwards' clients, designated as ".." (App. 1). The gravamen of the Complaint was that after Edwards had filed those cases

Railroad Avenue, Suite 350 West Palm Beach, FL 33401 Attorneys for Res ondents ' Petitioner did not include , or Jane Doe in the caption of the Petition, however, they have been granted leave to appear in the trial court as Intervenor. i EFTA00808515 TABLE OF CONTENTS PAGE TABLE OF CONTENTS ii

EAL OF THE STATE OF FLORIDA FOURTH DISTRICT Appellate Case No.: LT Case No: 502009CA0408003OOOCMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants. PETITION FOR WRIT OF CERTIORARI On Review of a Non-Final Order of th

underlying all counts were interrelated). BACKGROUNDS This unique and complex case arose from the 2009 implosion of the Fort Lauderdale law firm Rothstein, Rosenfeldt & Adler, where defendant/counter- plaintiff Bradley Edwards worked and held himself out as a partner. The principal of the firm, defenda

ff/Counter-Defendant Jeffrey Epstein 23 EFTA00793715 CERTIFICATE OF TYPE SIZE & STYLE I certify that the type, size, and style utilized in this Petition is 14-point Times New Roman. 1st Kara Berard Rockenbach Kara Berard Rockenbach 24 EFTA00793716

EAL OF THE STATE OF FLORIDA FOURTH DISTRICT Appellate Case No.: LT Case No: 502009CA0408003OOOCMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants. EMERGENCY PETITION FOR WRIT OF MANDAMUS On Review of a Non-Final Ord

Epstein filed his initial Complaint in this action against Scott Rothstein, Bradley Edwards and L.M.'- Epstein alleged the following counts against Rothstein: a. (1) Violation of § 772,101 — Florida Civil Remedies for Criminal Practices Act b. (2) Violation of § 895.01 — Florida's RICO Act c. (3) Abuse

conda Counsel for Petitioner/Plaintiff Jeffrey Epstein CERTIFICATE OF TYPE SIZE & STYLE I certify that the type, size, and style utilized in this Petition is 14-point Times New Roman. Is! Kara Berard Rockenbach Kara Berard Rockenbach 19 EFTA00793748

e foregoing references. References (i) and (iii) do not add to the lack of consideration argument and may inadvertently trigger a second look at the Rothstein case and the State's willingness to follow Rev. Rule 85-13 instead of Rothstein (which is still good Federal law for NY State tax purposes). If tha

in the ruling. I worry that it opens the door for a fishing expedition if NY ever looks into such a reacquisition. If still want it included in the Petition and it does become a determinative factor to issuing the opinion, it means that a grantor will only be able to substitute art for which he or she ca

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

ency Requet: 19-011 SDNY_GM_00331615 EFTA 00204341 EFTA02729327 CERTIFICATE OF TYPE, SIZE AND STYLE Counsel for Petitioners certifies that this Petition is typed in 14 point (proportionately spaced) Times New Roman. 09/12/2019 27 CONFPITTENTIAL Agency to Agency Requet: 19-411 SDNY_GM_00331616 E

st Palm Beach, FL 33401, William J Berger, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas Blvd., Suite

L 33394 on this 10th day of July, 2009. Att ey 26 EFTA00183991 CERTIFICATE OF TYPE. SIZE AND STYLE Counsel for Petitioners certifies that this Petition is typed in 14 point (proportionately spaced) Times New Roman. , 27 EFTA00183992 - Not an Official Document Page 1 of II ReporLSeJection Crit

illiam J. Berger, Esq. Bradley J. Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard., S

t without her participation and knowledge. WHEREFORE, for the reasons outlined above, the Petitioner respectfully requests this Court to grant her Petition, and to order the United States Attorney to comply with the provisions of the CVRA prior to and including any plea or other agreement with the Defen

illiam J. Berger, Esq. Bradley J. Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard., S

t without her participation and knowledge. WHEREFORE, for the reasons outlined above, the Petitioner respectfully requests this Court to grant her Petition, and to order the United States Attorney to comply with the provisions of the CVRA prior to and including any plea or other agreement with the Defen

illiam J. Berger, Esq. Bradley J. Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard., S

t without her participation and knowledge. WHEREFORE, for the reasons outlined above, the Petitioner respectfully requests this Court to grant her Petition, and to order the United States Attorney to comply with the provisions of the CVRA prior to and including any plea or other agreement with the Defen