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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
dence and are communicated by one seeking legal advice from the attorney to whom the communication is made. Section 90.502 (2), Fla. Stat.; State v. Rabin, 475 So. 2d 257, 260 (Fla. 3d DCA 1986); see Hoch v. Rissman, Weisberg, Barrett, 742 So. 2d 451 (Fla. 5th DCA 1999. Therefore, if the answer was ev
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
pose of committing a crime or tort; and (4) the privilege has been (a) claimed and (b) not waived by the client. See § 90.502, Fla. Stat.; State v. Rabin, 495 So. 2d 257, 60 (Fla. 3d DCA 1986). The attorney-client privilege does not apply to communications between an attorney and a third party, or a
ability Company, by its manager, Bahia Property Management, LLC, a Delaware Limited Liability Company, by its co-manager, Scott W. Rothstein; (BI2) Scott W. Rothstein's equity interest in QTask; (313) Scott W. Rothstein's equity interest in Broward Bank of Commerce; (B14) Scott W. Rothstein's equity interest in Bov
ive 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 and fraudulent abuses of process that resulted in serious injury to Mr. Epstein. A copy of the
fered to settle the cases for $200 million, when there have been no such discussions about any settlement at any price. And it does not stop thre. Rabin, latners, and his employees investigated and litigated the , and cases with funds derived from their criminal enterprise and their fraud and mis
Entities connected to both Scott Rothstein and Rabin

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJack Scarola
PERSONJane Doe
PERSON
George W. Bush
PERSONMaria Farmer
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
Kenneth Marra
PERSONMarc S. Nurik
PERSON
Prince Andrew
PERSON
Salt Lake City
LOCATION
United States
LOCATION
Bill Clinton
PERSONLeon Black
PERSON
Ghislaine Maxwell
PERSON
Scarlett Johansson
PERSON
Marc Rich
PERSONthe Southern District
LOCATION