Epstein Secrets

FTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, vs. SCOTT ROTHSTEIN, individually; BRADLEY EDWARDS, individually, Defendants/Counter-Plaintiffs. / VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN Saturday, 9:07 a.m.

/18 Page 25 of 97 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 in the bankruptcy for the law firm Rothstein, Rosenfeldt & Adler had been subpoenaed to produce emails contained on the server of that law firm? A I don't recall. Q Did it ever come to you

14 15 16 17 18 19 20 21 22 23 24 25 APPEARANCES: For Plaintiff/Counter-Defendant: T,TNK 4 ROCKFNRArN P A By SCOTT J. LINK, ESQUIRE By KARA BERARD ROCKENBACH, ESQUIRE For Plaintiff/Counter-Defendant: ATTERBURY, GOLDBERGER & WEISS, P.A. By JACK A. GOLDBERGER, ESQUIRE For Defendants/Counter-Plaintiffs:

at has JEFFREY EPSTEIN, S transpired is of extreme consternation to Plaintiff/Counter-Defendant, vs. 4 the court. It has caused me to have to SCOTT ROTHSTEIN, individually; 7 engage in an inordinate amount of time to BRADLEY EDWARDS, individually, 8 the exclusion of other natters that needed Defendan

ion for trial on May 24th, 2017. There is no dispute. And Mr. Edwards has actually pointed it out, Mr. Epstein did not have a default against Mr. Rothstein. Contrary to what Mr. Edwards' suggestion is, is to cure this issue -- 10 THE COURT: Mr. Epstein did not have a 11 default against Mr. Rothstein

laintiff/Counter-Defendant: 4 LINK 4 ROCKENBACH P.A. , So it's against that backdrop we will • proceed. WO will hear the motion filed by 5 By KARA BERARD ROCKENBACH, ESQUIRE Epstein to remove the case from the trial 6 By SCOTT J. LINK, ESQUIRE ^ docket relative to Florida Rule of Civil 9 For Defendant/Coun

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

ached to the 3 LINK a ROCKEIIBACH, P.A. pretrial stipulation on December 22, 2017. And 4 4 then for the first tine on March 5th of 2010 the By KARA BERARD ROCKENBACH, ESQUIRE 5 new exhibit list was filed. If you compare the S By SCOTT J. LINK, ESQUIRE 6 For Defendant/Counter-Plaintiff: SEARCY, DENNEY, SCARO

KR. LINK: I understand. Your Honor, may I respected coach and former coach of the Heat -- a have one ninute to confer with appellate counsel to Scott Rothstein wan sitting on thin stuff. That's 7 ado sure there's nothing I need to do to preserve i not what happened hero. That's the point that I'm • this

an agreement. And 19 THE COUR?: I nay have font you. ?he 74,000 in our agreement, your court order says no 20 pages wore self-generated from the Rothstein firm: additional exhibits unless the parties agree. In 21 MR. LINK: Yes. And delivered by the trustee the pretrial stip Kr. scarola and I agree

1 APPEARANCES: For Plaintiff/counter-Defendant: LINK 4 ROCKENBACH, P.A. 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, FL 33401 By KARA BERARD ROCKENBACH, ESQUIRE By SCOTT J. LINK, ESQUIRE For Defendant/counter-Plaintiff: SEARCY, DENNEY, SCAROLA, BARNHART 4 SHIPLEY, P.A. 2139 Palm Beach Lakes Boul

communications concerning or containing information derived from documents or data over which a claim of privilege was asserted by or on behalf of Rothstein, Rosenfeldt, Adler PA; Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L.; or Bradley J. Edwards? MR. LINK: I think -- which subpoena duces

FTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, vs. SCOTT ROTHSTEIN, individually; BRADLEY EDWARDS, individually, Defendants/Counter-Plaintiffs. / VIDEOTAPED DEPOSITION OF JEFFREY EPSTEIN Saturday, 9:07 a.m.

4 15 16 17 18 19 20 21 22 23 24 25 APPEARANCES: For Plaintiff/Counter-Defendant: LINK & ROCKENBACH, P.A. By SCOTT J. LINK, ESQUIRE By KARA BERARD ROCKENBACH, ESQUIRE For Plaintiff/Counter-Defendant: ATTERBURY, GOLDBERGER & WEISS, P.A. By JACK A. GOLDBERGER, ESQUIRE For Defendants/Counter-Plaintiffs:

c/o SCOTT J. LINK, ESQUIRE LINK & ROCKENBACH, P.A. 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, FL 33401 RE: JEFFREY EPSTEIN vs. SCOTT ROTHSTEIN, INDIVIDUALLY; BRADLEY EDWARDS, INDIVIDUALLY At the conclusion of your deposition given in the above-styled cause you indicated you wished to rea

RDALE Case No. 09-34791-RBR Chapter 11 IN RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor / VIDEOTAPED

For Jeffrey Epstein: LINK & ROCKENBACH, P.A. 1555 Palm Beach Lakes Boulevard, Suite 301 West Palm Beach, FL 33401 By SCOTT J. LINK, ESQUIRE By KARA BERARD ROCKENBACH, ESQUIRE For Jeffrey Epstein: ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Ave. South, Suite 1400 West Palm Beach, FL 33401 By JACK A. GOL

CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, ) ) ) Petitioner/Counter-Defendant, ) ) vs. No. 50-2009CA040800XXXXMBAG ) SCOTT ROTHSTEIN, individually, ) and BRADLEY J. EDWARDS, ) individually, ) ) Defendants/Counter-Plaintiff. ) ) West Palm Beach, Florida November 2nd, 2018

. So in looking at the Binger analysis, there are three categories. Category number one are emails that are from Brad Edwards and his team at the Rothstein firm, which they voluntarily produced, which are not the 47 on the privileged log, and which they can have no prejudice to because they were writ

Counter-Defendant: LINK & ROCKENBACH, PA 1555 Palm Beach Lakes Boulevard, Suite 930 West Palm Beach, Florida 33401 By SCOTT J. LINK, ESQUIRE and KARA BERARD ROCKENBACH, ESQUIRE For The Defendant/Counter-Plaintiff: SEARCY DENNEY SCAROLA BARNHART & SHIPLEY, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, Florid