Epstein Secrets

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

ber 2017 Motion to Continue] said, "We have heard the Court loud and clear, now we" — Link and Rockenbach — "are on the case, with support from the Gunster firm, and we will not allow the same type of conduct that transpired earlier, which the Court was critical of, [to] happen again." That pledge to

T OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN. Plaintiff(s), vs. SCOTT ROTIISTEIN. individually, BRADLEY J. EDWARDS, individually, and EL, individually. Dcfendant(s). EXHIBIT b ORDER ON MOTION TO RECONFIRM EXISTING PRETRIAL D

s Motion to Amend Exhibit List. was not at issue as a result of Epstein's own dilatory conduct in failing to know what pleading was pending against Rothstein and failing to know whether a default had been entered. At the hearing on March 8, 2018, Epstein's trial counsel nonetheless repeatedly claimed tha

ber 13, 2017, Plaintiff retained new trial counsel, who appeared in the case on November I, 2017. Plaintiff also retained a team of lawyers from the Gunster law firm as trial support. None of the things Plaintiff is asking for in this Motion is based on lack of manpower. Even using all of these resource

KR. SCAROLA: May I now to this podium now? JEFFREY EPSTEIN, biaintirs/countor -Defendant, vs 4 THE CO1RT: Sure. 'at. SCAROLA: Thank you, sir. SCOTT ROTHSTEIN, individually; • Your 110nOr, have we decided what notions were BRADLEY EDWARDS, individually, , going to hoar? boranciants/countor -Plaintiffs

ng CO your Honor that 12 during a very CUTUICUOUSI period of CIAO these would I) the first notice we got of an Intent CO attempt. to to be the Rothstein fines, erployee. 14 use chose documents was March S. The first notice 14 KR. SMOLA: Yes, air. Let ne go through IS wo got of an intent CO attem

49:19 74:8 119:25 greatest 17:20 group 43:24 111:17 115:6,7,9 groups 6:19 grudge 89:15 guess 109:7 guessing 38:19 guilt 99:21 guilty 99:13 Gunster 63:6 guys 111:8 H Hafele 1:16 half 52:22 65:18 82:3 band 21:16 56:8 74:18 91:14 118:14 121:14 handed 7:18 43:17 51:12 94:25 handing 23:17

KR. SCAROLA: May I now to this podium now? JEFFREY EPSTEIN, biaintirs/countor -Defendant, vs 4 THE CWRT: Sure. 'at. SCAROLA: Thank you, sir. SCOTT ROTHSTEIN, individually; • Your Honor, have we wowed what notions were BRADLEY EDWARDS, individually, boranciants/countor -Plaintiffs. , 10 going to hoa

ng CO your Honor that 12 during a very CUTUICUOUSI period of CIAO these would I) the first notice we got of an Intent CO attempt. to to be the Rothstein fines, erployee. 14 use chose documents was March S. The first notice 14 KR. SMOLA: Yes, air. Let ne go through IS wo got of an intent CO attem

49:19 74:8 119:25 greatest 17:20 group 43:24 111:17 115:6,7,9 groups 6:19 grudge 89:15 guess 109:7 guessing 38:19 guilt 99:21 guilty 99:13 Gunster 63:6 guys 111:8 H Hafele 1:16 half 52:22 65:18 82:3 band 21:16 56:8 74:18 91:14 118:14 121:14 handed 7:18 43:17 51:12 94:25 handing 23:17

Ill ceu 561.301.3800 ENGAGEMENT MEMORANDUM BY ELECTRONIC MAIL ONLY To: Gunster, Yoakley & Stewart P.A. do David R. Atkinson < RE: Epstein v. Rothstein, No. 502009CA040800XXXXMB (Fla. 15th Cir. Ct.) DATE: November 2, 2017 Thank you for engaging me on behalf of Mr. Epstein, Jeffrey Epstein, to serve

. 561.598.6800 Fax 561.598.6801 www.culversmithlaw.com D. Culver Smith Ill ceu 561.301.3800 ENGAGEMENT MEMORANDUM BY ELECTRONIC MAIL ONLY To: Gunster, Yoakley & Stewart P.A. do David R. Atkinson < RE: Epstein v. Rothstein, No. 502009CA040800XXXXMB (Fla. 15th Cir. Ct.) DATE: November 2, 2017 Th

ng factual and legal support for the opinions to which I may testify and in defining 5019-009.cngmtmcm.02 EFTA00795577 ENGAGEMENT MEMORANDUM TO: Gunster, Yoakley & Stewart, P.A. RE: Epstein v. Rothstein November 2, 2017 Page 2 of 5 potential areas for inquiry. My testimony will be as an objective

RT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, -VS- SCOTT individually, EDWARDS, L.M., E.W., Intervenors. ROTHSTEIN, BRADLEY J. individually, and and JANE DOE, Respondents CASE NO. 4D18-0762 APPENDIX TO RESPONSE TO PETITION FOR WRIT OF MANDAMUS PAGE 1. Non

40800 XXXXMB HONORABLE JUDGE DAVID F. CROW JEFFREY EPSTEIN, Plaintiff, vs. SCOTT RCTHSTEIN, BRADLEY J. EDWARDS, and LM, Defendants. DEFENDANT SCOTT ROTHSTEIN'S MOTI Defendant, SCOTT ROTHSTEIN ("R undersigned counsel and pursuant to Fla. R. Default entered against Defendant, and asserts as follows: ASIDE

er 13, 2017, Plaintiff retained new trial counsel, who appeared in the case on November I, 2017. Plaintiff also retained a team of lawyers from the Gunster law firm as trial support. None of the things Plaintiff is asking for in this Motion is based on lack of manpower. Even using all of these resources

3. In late 2009, Epstein sued Edwards for purportedly improperly representing his clients who were Epstein's sex abuse victims. Jeffrey Epstein v. Scott Rothstein, Bradley J. Edwards, and LM., Fifteenth Judicial Circuit, in and for Palm Beach County, Florida Case No. 50-2009 CA 040800XXXX MB AG (hereinafter "

e No. 50-2009 CA 040800XXXX MB AG (hereinafter "the Epstein lawsuit"). 4. On April 17, 2010, Epstein served a subpoena in the Epstein lawsuit upon Rothstein Rosenfeldt Adler, PA ("RRA") Bankruptcy Trustee Howard Stettin, seeking to obtain documents from the Trustee, which included documents from attorne

Kara Rockenbach, and the currently unidentified attorneys that Mr. Link has represented are also working on this case on behalf of Epstein from the Gunster law firm. 7. Epstein will pay Fanner Jaffe reasonable attorneys' fees and expenses connected with Farmer Jaffe's efforts to determine the circumsta

11/8/17 hearing on Motion to Bifurcate based on 1.20 900.00 probable cause and overlapping facts of J. Epstein's abuse of process action against Rothstein in order to remove the "mini-trial" issue 750.00/hr AMM Analyze Volume I of II deposition transcript of B. Edwards (147 3.20 1,264.00 pages) da

nue Trial KBR Telephone call with J. Scarola re J. Epstein's request for continuation of trial and Pre-Trial Stipulation KBR Meet with trial team, Gunster counsel and J. Epstein at J. Goldberger's office to discuss trial strategies, client testifying at trial and probable cause at commencement of acti

UDERDALE DIVISION www.flsb.uscourts.gov IN RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor. CASE NO.: 09-34

Kara Rockenbach, and the currently unidentified attorneys that Mr. Link has represented are also working on this case on behalf of Epstein from the Gunster law firm. 7. Epstein will pay Fanner Jaffe reasonable attorneys' fees and expenses connected with Farmer Jaffe's efforts to determine the circumsta