Epstein Secrets

2010 seeking the similar relief. The grounds for this motion are: 1. Late last year, Epstein filed this action to recover damages from Defendants, Scott Rothstein ("Rothstein") and Edwards, based on Epstein's well founded belief that the two, and possibly others, had perpetrated an illegal pyramid scheme direc

WLER WHITE BURNETT P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA00606624 Epstein v Rothstein, Edwards CASE NO. 502009CA040800=OCMBAG Notice of Hearing PLEASE GOVERN YOURSELVES ACCORDINGLY. In accordance with the Americans With Disabilitie

s to confidential communications made in the rendition of legal services to the client. Section 90.502, Fla. Stat.; Southern Bell Tel. & TeL Co. v. Deason, 632 So. 2d 1377 (Fla.1994). Section 90.502 codifies the attorney-client privilege which protects those confidential communications between attorney

of whether they pertain to confidential communications between attorney and client. F1a.R.Civ.P. 1.280(b)(2). See Southern Bell TeL & Tel. Co. v. Deason, 632 So. 2d 1377 (Fla. 1994). The privilege may also protect an attorney's mental impressions which may be disclosed through testimony. Hamilton v.

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH C

. The topic of the examination next turned to Scott Rothstein and his involvement in the Epstein cases. Counsel for Epstein asks Edwards to discuss Rothstein's general knowledge regarding the Epstein cases, specifically a meeting he attended in Rothstein's office with Russell Adler: Q: Was a question po

e the same or similar information is available through ordinary investigative techniques and discovery procedures.'" Southern Bell TeL & TeL Co. v. Deason, 632 So. 2d 1377, 1384 (Fla. 1994). Here, the information sought by Epstein from Edwards in deposition is not "available through ordinary investiga

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 result of being sued by Mr. Epstein in 2009 and not by being partners with Scott Rothstein, we are entitled to pursue that. We're entitled to the discovery to show how much money he made while he was working at RRA, before he was working

e, Judge, if the Court looks to the specific complaint filed by Mr. Epstein against Mr. Edwards, the allegation that we are stuck to defend here, Rothstein and the litigation team knew or should have known that the three filed cases were weak and had minimal value for the following reasons. Judge, LM

ng this 518 Southern And again, the was quoted by the Florida Supreme Court in 1994 in the Southern Bell Telephone and Telegraph Company versus Deason. Frankly, Judge, if the Court wants me to go through the other objections that were raised in deposition that have no basis in law in a depositio

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 JEFFREY EPSTEIN'S MOTION TO COMPEL PRODUCTION OF

eral orders entered by Judge Raymond Ray in the Bankruptcy Court, filed a one hundred and fifty-nine (159) page privilege EFTA00582857 Epstein v. Rothstein and Edwards DRAFT 2/3/12 4:26 PM Case No. 502009CA040800XXXXMB/Div. AG log, claiming that over two thousand (2000) documents are privileged.' Th

f whether they pertain to confidential communications between attorney and client. Fla. R. Civ. P. 1.280(b)(2). See Southern Bell Tel. & TeL Co. v. Deason, 632 So. 2d 1377 (Fla. 1994). Work product is a qualified immunity from discovery. See DeBartolo-Aventura, Inc. v. Hernandez, 638 So. 2d 988 (Fla.

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH C

. The topic of the examination next turned to Scott Rothstein and his involvement in the Epstein cases. Counsel for Epstein asks Edwards to discuss Rothstein's general knowledge regarding the Epstein cases, specifically a meeting he attended in Rothstein's office with Russell Adler: Q: Was a question po

ques and 19 Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301 EFTA00585412 discovery procedures.'" Southern Bell TeL & TeL Co. v. Deason, 632 So. 2d 1377, 1384 (Fla. 1994). Here, the information sought by Epstein from Edwards in deposition is not "available through ordinary investiga