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19 THE COURT: Okay. 20 MR. SCAROLA: Your Honor may recall that the /I law firm of Rothstein Rosenfeldt & Adler imploded as a 22 consequence of Scott Rothstein's involvement in a massive 23 Ponzi scheme. 24 That firm became the subject of bankruptcy 25 proceedings. A special master was appointed. The speci
robably very obvious to the Court. 16 Mr. Scarola suggested that upon the bankruptcy the Special 17 Master took possession of all of the records of Rothstein. 18 Of course what he meant by that was the bankruptcy 19 trustee. 20 MR. SCAROLA: Yes, I'm sorry, the Special 21 Master had them as an agent of
OUELLETTE & MA LDIN RT REPORTERS, INC. EFTA00787710 Page 29 Page 31 1 provisions of Title 11. I order. That is by definition in the In Re: McClean case, 2 Courts have held, and we've cited them in 2 and countless other 11th Circuit cases, and lower court 3 our motion, that Bankruptcy Courts
for the Court. THE COURT: Okay. MR. SCAROLA: Your Honor may recall that the law firm of Rothstein Rosenfeldt & Adler imploded as a consequence of Scott Rothstein's involvement in a massive Ponzi scheme. That firm became the subject of bankruptcy proceedings. A special master was appointed. The special OUELLE
m is probably very obvious to the Court. Mr. Scarola suggested that upon the bankruptcy the Special Master took possession of all of the records of Rothstein. Of course what he meant by that was the bankruptcy trustee. MR. SCAROLA: Yes, I'm sorry, the Special Master had them as an agent of the bankrupt
laid out, I don't think there could ever be a basis for it, but this also gets to the discovery point, and even though the 11th Circuit in In Re: McClean, they affirm a finding of punitive damages, which are by definition criminal, because it's punishment, as opposed to purely compensatory damages,
3,5 47:1 48:8 rights 29:18 rise 3: I RMR 1:23 50:8,19 ROBINSON 2:10 Rockenbach 10:18,19 13:22 15:15,24 17:7 20:18 Rosenfeldt 1:5 3:7 11:21 Rothstein 1:5 3:7 11:21 24:17,23 25:4 Rothstein's 11:22 RPR 1:23 50:8,19 rule 15:10 32:1,7 ruled 23:16 ruling 25:24 Run 41:4 S same 13:25 17:7 23:16
0 16:21 18:2025:17,17 27:7 33:9 38:18,18,20 38:20,22,22 42:15,18 43:12 45:7 47:9,19 48:9,13 maybe 23:3 24:2 27:9 38:23 42:15 ma'am 4:18 6:21 McClean 29:8,22 31:1 McLACHLAN 24:11 24:12,25 25:9 McLAUCHLAN 2:13 4:6,7 7:14 8:22 10:21 10:25 11:9 25:6 mean 39:7 40:10 42:19 means 32:18 meant 24:1
Entities connected to both Scott Rothstein and McClean

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJack Scarola
PERSONJane Doe
PERSON
George W. Bush
PERSONMaria Farmer
PERSON
Paul Cassell
PERSONthe Southern District
LOCATIONE.W.
PERSONDonald W. Hafele
PERSON
Fowler
PERSONFowler White's
ORGANIZATION
Broward County
LOCATIONChambers
PERSON
Michael Cohen
PERSONBates
PERSON
Condoleezza Rice
PERSONCarney
PERSONRothstein Rosenfeldt & Adler
ORGANIZATION