Epstein Secrets

nt. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as well as Scott Rothstein. Edwards' former law partner. ee infra. Kam incorrectly states that "Imlore recent cases" in this Circuit and District have demoted the showing req

more so in light of Epstein's admission in his lawsuit against M. and others that he that he was "one of M's many `Johns.— See Complaint Epstein v. Rothstein, Edwards & M s, No. 50 2009 CA0 40800 (Cir. Ct., 15th Jud. Cir., Palm Beach Co.. Dec. 7, 2009) at 146(a), pertinent pages annexed as Ex. E to the C

beyond the power of evidence to controvert them.") (citation omitted). accord Chick-Fil-A, Inc. v. CFT Development. LLC, 652 F. Supp. 2d 1252. 1260 (M.D. Ha. 2009), aff'd, No. 09- 15066, 2010 WL 1006661 (11th Cir. Mar. 19,2010): Bellefonte Re Ins. Co. v. Argonaut Ins. Co. 757 F.2d 523, 528-29 (2d Cir. 19

nt. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as well as Scott Rothstein. Edwards' former law partner. ee infra. 1° Doe incorrectly states that "Imlore recent cases" in this Circuit and District have demoted the showing

ges in his complaint against M. 13 12 The document is available online at http://www.scribd.com/doc/23947743/121009-epstein. "Complaint, Epstein v. Rothstein et al., II 42(h)(i) ("M. testified that she ... worked at various strip clubs; is an admitted prostitute and call girl; has a history of illegal dru

beyond the power of evidence to controvert them.") (citation omitted)• accord Chick-Fil-A, Inc. v. CFT Development. LLC, 652 F. Supp. 2d 1252. 1260 (M.D. Ha. 2009), aff'd, No. 09- 15066, 2010 WL 1006661 (11th Cir. Mar. 19,2010): Bellefonte Re Ins. Co. v. Argonaut Ins. Co. 757 F.2d 523, 528-29 (2d Cir. 19

Esq. Brad Edwards, Esq. Adam D. Horowitz, Esq. Rothstein Rosenfeldt Adler Mermelstein & Horowitz, P.A. C

fore or shortly after a substantial debt was incurred. See In re Ramsurat, 361 B.R. at 254; In re Dealers Agency Services, Inc., 380 B.R. 608, 613 (M.D. Ha. 2007) (recognizing that the Eleventh Circuit adopted the "badges of fraud" to determine fraudulent intent); Fla. Stat. §726.105(2). Moreover, Ha.

33401 William Berger, Esq. Attorney For: E. W. Rothstein Rosenfeldt Adler 401 E. Las Olas Blvd., Suite 16

1 F. Supp. 1299 (M.D. Fla. 1977)15 L.S. v. State, 805 So. 2d 1004 (Fla. 1st DCA 2001) 9 Lockhead Martin Corp. v. Boeing Co., 393 F. Supp. 2d 1276 (M.D. Ha. 2005)... 15 Martin-Johnson, Inc. v. Savage, 509 So. 2d 1097 (Fla. 1987) 8 Pisciotti v. Stephens, 940 So. 2d 1217 (Fla. 4th DCA 2006) 16 Sabo!

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

gate suspected crimes without inhibition and engage in unrestricted deliberations." Lockhead Martin Corp... Boeing Co., 393 F. Supp. 2d 1276, 1279 (M.D. Ha. 2005). The rule aims to "prevent disclosure of the way in which information was presented to the grand jury, the specific questions and inquiries