Epstein Secrets

IllOAPX L STANK WACO,' A. ITINLI VT A PAY ANTI MAIL March 11, 2011 Joseph.. Ackerman, Jr., Esquire Fowler White Burnett. P.A. Re: Epstein v. Rothstein, et al Our File No.: 291874 Dear Mr. Ackerman: I TALLAHANNErop Aria Enclosed please find Edwards' Motion for Protective Order, together with a No

ack Scarola, Searcy Denney Scarola Barnhart & Shipley, Attorneys for Bradley L Edwa rds, Marc S. Nurik, Law Offices of Marc S. Nurik, Attorneys for Scott Rothstein, taMM EM Respectfully submitted, oseph Ackerman, Jr. Fla. Bar o. 235954 Christopher E. Knight Fla. Bar No. 607363 FOWLER WHITE BURNETT P.A. c

rnett, P.A. M: S. Nurik, Esquire 3 EFTA00616179 03/11/2011 18:00 FAS SEARCY DENNEY 12 005 #291874/mep Jt —FREY EPSTEIN, Plaintiff(s), vs. SCIOTT ROTHSTEIN, individually, LEY 5. EDWARDS, individually, and ., Defendant(s). N THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH

ly submitted, oseph Ackerman, Jr. Fla. Bar o. 235954 Christopher E. Knight Fla. Bar No. 607363 FOWLER WHITE BURNETT P.A. cc: ISSIo I rting c Charles Lichtman, Esquire (w/enclosures) 2 aliment:err. P A.. MILLIPSPOrta EFTA00616183 03/11/2011 16:02 FAX SEARCY DENNEY Case No. 50 2009CA040800XXXXNUEt AG

MBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually,

T OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). I NOTICE OF SERVING ANSWERS TO INTERROGATORIES PROPOUNDE

DESCRIPTION OF WITNESSES the various sexual abuse cases being prosecuted by Edwards at the time, including on the issue of punitive damages. 13 Charles Lichtman, Esquire 350 East Las Olas Boulevard I Suite 1000 Fort Lauderdale, FL 33301 2-3 Expected to testify about the malicious prosecution elements of ab

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individu

IAL WITNESSES Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") hereby files his Amended Trial Witness List as follows: TRIAL WITNESSES I. Scott W. Rothstein do Marc Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 2. Ken Jenne do Broward County Sheri

akes Blvd. West Palm Beach, FL 33409 43. Jeffrey Epstein c/o Tonja Haddad, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 44. Charles Lichtman 350 East Las Olas Boulevard Fort Lauderdale, FL 33301 45. Robert Critton 5 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301• 9

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individu

IAL WITNESSES Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") hereby files his Amended Trial Witness List as follows: TRIAL WITNESSES I. Scott W. Rothstein do Marc Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 2. Ken Jenne do Broward County Sheri

Lakes Blvd. West Palm Beach, FL 33409 44. Jeffrey Epstein do Tonja Haddad, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 45. Charles Lichtman 350 East Las Olas Boulevard 5 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301• 954.467.1223 EFTA00799464 Fort Lauderdale, FL

TRIAL WITNESSES I. Scott W. Rothstein do Marc Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301 He is expected to testify regarding th

s lack of damages. 22. Marc Nurik Law Offices of Marc S. Nurik 1075 Broken Sound Pkwy NW Suite 102 Boca Raton, FL 33487-3541 Partner at RRA and Rothstein's attorney; expected to testify regarding the Ponzi scheme, the use of the "Epstein Cases" to defraud investors in the furtherance thereof and work

ef, Epstein may testify as to the information about which he was aware, and upon which he relied in filing suit against Edwards and Rothstein. 44. Charles Lichtman Trustee to RRA Bankruptcy, and will testify to the lack of access to documents suffered by Epstein during the pendency of this lawsuit and regardin

orney client communication privileges. Epstein has absolutely no proof, nor any reasonable basis to allege, that Edwards was in any way involved in Scott Rothstein's Ponzi scheme, yet he continues wage the instant litigation. This incredibly voluminous fishing expedition discovery is clearly intended to harass, a

: Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman. PL Fort La • FL 33301 Pho c: Fax: Marc S. Nurik, Esq. Law Offices of Marc S. Nurik 1 Rothstein Fort Lauderdale, FL 33301 Phone Fax: Joseph L. Ackerman, Jr., Esquire Fowler White Burnett, P.A. Attorney For: Jeffrey Epstein West P B h FL

f the subject deposition was not coordinated with or communicated to Defendant's counsel. 4. On February 16, 2011 at 10:20 a.m., Trustee's counsel Charles Lichtman sent an email to Plaintiff's counsel, Defendant's counsel and Special Master Robert Carney stating that the Trustee would produce 10,214 pages of e

From: To: jeevacationgginail.corn Subject: Rothstein Date: Fri, 28 Oct 2011 15:12:24 +0000 Rothstein's general counsel sued for $37.8 million Investors threatened to "go public" months before the Pon

illion Investors threatened to "go public" months before the Ponzi scheme unraveled By Jon Burstein Sun Sentinel 6:30 p.m. EDT, October 27, 2011 Scott Rothstein's Ponzi scheme was almost exposed eight months before it spectacularly imploded in October 2009, according to a $37.8 million lawsuit filed Thursday a

thstein, Boden crafted a deal that "included representations from the Brausers that they had not gone to the authorities," wrote bankruptcy attorney Charles Lichtman. Gerald Brauser could not be reached for comment Thursday, despite an attempt by phone. Boden also did nothing when Rothstein was ripped off in a d

llion Investors threatened to "go public" months before the Ponzi scheme unraveled By Jon Burstein, Sun Sentinel 6:30 p.m. EDT, October 27, 2011 Scott Rothstein's Ponzi scheme was almost exposed eight months before it spectacularly imploded in October 2009, according to a $37.8 million lawsuit filed Thursday a

ed eight months before it spectacularly imploded in October 2009, according to a $37.8 million lawsuit filed Thursday against the general counsel of Rothstein's law finn. Two investors threatened in February 2009 to "go public" with questions about Rothstein's investment scheme, prompting Rothstein to ins

hstein, Roden crafted a deal that "included representations from the Brausers that they had not gone to the authorities," wrote bankruptcy attorney Charles Lichtman. Gerald Brauser could not be reached for comment Thursday, despite an attempt by phone. Boden also did nothing when Rothstein was ripped off in a d

/mep JEFFREY EPSTErN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually,

orney client communication privileges. Epstein has absolutely no proof, nor any reasonable basis to allege, that Edwards was in any way involved in Scott Rothstein's Ponzi scheme, yet he continues wage the instant litigation. This incredibly voluminous fishing expedition discovery is clearly intended to harass, a

f the subject deposition was not coordinated with or communicated to Defendant's counsel. 4. On February 16, 2011 at 10:20 a.m., Trustee's counsel Charles Lichtman sent an email to Plaintiff's counsel, Defendant's counsel and Special Master Robert Carney stating that the Trustee would produce 10,214 pages of e

ENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, vs. Plaintiff/Counter-Defendant, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OMNI

EFTA00585430 142. All pleadings filed by Epstein in the Rothstein Bankruptcy Proceeding. 143. All submissions by Epstein in connection with the Rothstein deposition. 144. All Settlement Agreements between Epstein and victims of his sexual molestations. 145. Phone journal taken from Epstein's home a

Street, Fort Lauderdale, FL 33301 EFTA00585440 3. 4. 5. 6. 7. • 8. Detective Joseph Recarey 9. Chief Michael Reiter 10. John Connolly II. Charles Lichtman, Esquire 12. Antonio Figueroa (Tony) 13. Records Custodian of Palm Beach Police Department 14. Records Custodian of United States Attorney's Offic