Epstein Secrets

nt prosecution agreement with Edwards' counsel, whereby both parties agreed to share information relative to their claims and/or defenses related to Scott Rothstein without waiving privilege as to their communications or documents shared." Edwards' Supp. Resp. to Epstein's Mot. to Declare Relevance, July 26, 201

in (e.g., victims of) Rothstein Rosenfeldt & Adler's Ponzi scheme, in the Razorback litigation. These investors were unquestionably adverse to both Rothstein and Edwards' law firm of which he was a partner. Despite this, Edwards voluntarily produced documents that he now claims are privileged to Mr. Scher

are foreign to the objectives underlying the work-product doctrine."). 9 EFTA00805375 Similarly, in In re Subpoenas Duces Tecum, 738 F.2d 1367 (D.C. Cir. 1984), a law firm performed an investigation of a corporation on the subject of whether improper payments had been made to domestic or foreign off

nsel, s/ Bradley J. Edwards Bradley J. Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre Fort Laud

ries Inflicted by Epstein. In general, "The compensation and remedy due a civil plaintiff should not be delayed? Gordon v. FDIC, 427 F.2d 578, 560 (D.C. Cir. 1970). Epstein has not discussed Jane Doe's interest in prompt compensation — much less demonstrated that his alleged interests• in a stay somehow

sexual abuse by Epstein. In a telephone interview conducted on April 7, 2011, by Jack Scarola, Esq., representing Brad Edwards, Esq. in Epstein'. Rothstein. Edwards. and L.M. Case No. 502009CA040800XXXXMBAG (Circuit Court, Palm Beach County, Fla.), Jane Doe #3 stated she was first contacted by the FBI

s period in section 2401(a) "applies to all civil actions whether legal, equitable, or mixed." Spannaus U.S. Department of Justice 824 F.2d 52, 55 (D.C. Cir. I987)(citations omitted). Moreover, the Eleventh Circuit has recognized that, "[u]nlike an ordinary statute of limitations, § 2401(a) is a jurisdi