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 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

escribe the type of document for which the privilege is claimed. See, e.g., Ex. B, Bates 01514, 16777-16786, 07619, 00017, 06409-06415, 3 See also Evans v. United Fire & Cas. Ins. Co., 2007 U.S. Dist. LEXIS 58578, at *9 (E.D. La. Aug. 9, 2007) ("United has provided a privilege log, but it is insuffic

al assistants. T EXHIBIT B-30 EFTA00225783 A. Villafaria, Esq. December 9, 2009 Page 3 our part would constitute a breach of the NPA. So the Rothstein lawyers, once again, are using the power of the federal government to perpetrate and further their fraud. And the expense of litigating these cases

letter because other matters have consumed our time and effort. Over the past five weeks, the massive billion-dollar conspiracy created and run by Scott Rothstein has been exposed. On Monday, Mr. Epstein filed a state civil RICO lawsuit charging Rothstein, his partner Brad Edwards, and others with tortuous an

t in question has been accurately characterized by a d jury as solicitation of prostitution, a quintessential State law concern. See United States Evans, 476 F.3d 1176, n.1 (11th Cir. 2007) (federal law "does not criminalize all acts of prostitution (a vice traditionally governed by state regulation

ounsel for Plaintiff, C.M.A. Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Su

-cv-80119-KAM Document 149 Entered on FLSD Docket 06/09/2009 Page 7 of 13 Doe 101 v. Epstein Page? must be shown with specificity. See Doe v. Evans, 202 F.R.D. 173, 176 (E.D. P.A. 2001). Thus, Plaintiffs have not met their burden of persuasion. Id. Plaintiffs fail to show good cause in that the

C.M.A. Bruce Reinhart, Esq. Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Su

to rely on the following case as supplemental authority in connection with the above referenced Motions to Compel and Replies thereto: 1. Doe v. Evans, 202 F.R.D. 173, 176 (E.D. P.A. 2001) (denying protective order where alleged sexual assault victim did not demonstrate a serious specific injury a

C.M.A. Bruce Reinhart, Esq. Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Su

tions to Compel and Replies thereto: 1. Doe v. Evans, 202 F.R.D. 173, 176 (E.D. P.A. 2001) (denying pr