Epstein Secrets

ALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR CLARI

also expressed the need to get the pleadings at issue before addressing discovery objections and other discovery issues. EFTA00613622 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Division AG 3. At the hearing on September 28, 2011 on Edwards' Motion to Dismiss the Second Amended Co

vileged communication other than "Confidential Source," "RRA Staff," and "RRA Personnel." Such identifications violate the requirements set forth in TIG Insurance Corporation of America - 2 - EFTA00613623 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Division AG (TIG) v. Johnson, 799 So.2d 339 (Fla. 4'h DCA 200

y Plaintiffs case. 7. All documents made available to any investor or potential investor by Bradley J. Edwards, RRA, Scott W. Rothstein or any of Scott W. Rothstein's entitles to solicit "investors" for any case involving Jeffrey Epstein. B. All document reflecting the names and addresses of all individuals or

OWLER WHITE BURNETT PA. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA00606606 Epstein v Rothstein, Edwards CASE NO. 502009CA040800XXXXMBAG Notice of Hearing PLEASE GOVERN YOURSELVES ACCORDINGLY. In accordance with the Americans With Disabiliti

g to Mr. Epstein. The objections are based on attorney-client work product privilege and no privilege log has been prepared. 14. Under the case of TIG Insurance Corporation of America v. Johnson, 799 So. 2d 339 (Fla. 4111 DCA 2001) and its progeny, states that the failure to timely provide a privilege log may be grounds to determ

rect (56i) 472.6395 Fax lackermandpfowler-white.corn Robert B. Carney, Special Master 2281 Saratoga Lane West Palm Beach, FL 33409 Re: In re: Rothstein, Rosenfeldt Adler. U.S. Bankruptcy Court, Southern District of Florida, Fort Lauderdale Division; Case No. 09-34791-BKC-RBR Our File NO. 80743 De

Dear Judge Carney: We have the following objections to the form of the Privilege Log produced by Farmer, Jaffe based on the standards set forth in TIG Insurance Corporation of America, 799 So. 2d 339, (Fla. 4th DCA 2001). We request until the close of business on Tuesday, March 1, 2011 to supplement these objections, if necessar