Epstein Secrets

ned herein including, but not limited to, the discovery abuses and bad faith litigation tactics that Epstein has been the subject of at the hands of Scott Rothstein and his-co-conspirators, any tax returns must be redacted to preserve confidently and to prevent further abuses. See supra. Further, Epstein's com

ermore, as set forth in a Civil Complaint attached hereto as Exhibit ar attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A., deliberately engaged in a pattern of racketeering that involved a staggering series of gravely serious obstructions o

Doe v. Epstein 08-CV80119 Page No. 26 also Fed.R.Civ.P. 26(b)(1) and Fla. Stat. 768.72; Gallina v. Commerce And Industry, Ins., 2008 WL 3895918 (S.D. Ha. 2009)(unless liability for punitive damages is established at trial, the discovery sought is not relevant). In Gallina, the court held that in lig

Barnhart & Shipley, P.A. F Brad Edwards, Esq. Rothstein Rosenfeldt Adler Counsel for Plaintiff in Relate

lative to their past medical and psychiatric histories and conduct. See Exhibits "B-G." 21. Cherenfant v. Nationwide Credit, Inc. 2004 WL 5315889 (S.D. Ha. 2004) allows for the discovery sought in Sections II. a-g above and in Defendant's Motion to Identify. See also Fed.R.Civ.Pro. 26; Oppenheimer Fun

otion to Intervene and Petition for Access to certain court records in this case. It is our understanding that Bradley Edwards and William Berger of Rothstein Rosenfeldt Adler have filed a similar motion on behalf of a non-party known as "E. W.," and that E.W.'s motion is set for hearing on June 10,2009.

. v. Epstein, Case No. 08-80232 (S.D. Fla. 2008); Doe No. 4._vinstein, Case No. 08-80380 (S.D. Fla. 2008); Doe No. 5 v, Epstein, Case No. 08- 80381 (S.D. Ha. 2008); C.M.A. v. Epstein Case No. 08-80811 (S.D. Fla. 2008); Doe v. Epstein, Case No. 08-80893 (S.D. Fla. 2008); Doe No, 7 v. Epstein, Case No. 08-

st Palm Beach, FL 33401, William J Berger, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas Blvd., Suite

oe No. 71. Epstein, Case No. 08-80993 (S.D. Fla. 2008); Doe No. 6'. Epstein, Case No. 08-80994 (S.D. Fla. 2008); Doe II Epstein, Case No. 09-80469 (S.D. Ha. 2009); Doe No. 101 Epstein, Case No. 09-80591 (S.D. Fla. 2009); Doe No. 102'. Epstein, Case No. 09-80656 (S.D. Fla. 2009); Doe No. 81. Epstein, C