Epstein Secrets

tions at a Mar. 8, 2010, deposition, id. at 10 & Ex. D. 8. Annexed hereto as Exhibit E is a copy of pertinent pages of the Complaint in Epstein v. Rothstein, Edwards No. 50 2009 CAO 40800 (Cir. Ct., 15th Jud. Cir., Palm Beach Co., Dec. 7, 2009), as downloaded from http://www.scribd.com/doc/23947743/121

NTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, ilr DLEY J. EDWARDS, individually, and ., individually, Defendants. 50 2009 cAo 03 (JUI0X04B COMPLAINT COPY RECEIVED FOR FILING

(p. 8 - FBI). Yet at her September, 2009 deposition now represented by EDWARDS and RRA,■. told a very different story: Q: My question was what did Carolyn tell you to tell Mr. Epstein about your age? A: She said it didn't matter. Q: That's your recollection about what she said? A: Yes, she said — I

(RRA is currently a debtor in bankruptcy. RRA is not named as a Defendant). FACTUAL ALLEGATIONS 9. The United States in United States of America'. Scott W. Rothstein, Case No. 09-60331CR-Cohn, United States District Court, Southern District of Florida, has brought an action for Racketeering Conspiracy, 18 U.S.C.

d L.M., individually. Accordingly, EPSTEIN states: SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A. for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and prof

8 - FBI). Yet at her September, 2009 deposition now represented by EDWARDS and RRA, L.M. told a very different story: Q: My question was what did Carolyn tell you to tell Mr. Epstein about your age? A: She said it didn't matter. Q: That's your recollection about what she said? A: Yes, she said — I

ability Company, by its manager, Bahia Property Management, LLC, a Delaware Limited Liability Company, by its co-manager, Scott W. Rothstein; (312) Scott W. Rothstein's equity interest in QTask; (B13) Scott W. Rothstein's equity interest in Broward Bank of Commerce; (1314) Scott W. Rothstein's equity interest in Bo

d L.M., individually. Accordingly, EPSTEIN states: SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A. for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and prof

8 - FBI). Yet at her September, 2009 deposition now represented by EDWARDS and RRA, L.M. told a very different story: Q: My question was what did Carolyn tell you to tell Mr. Epstein about your age? A: She said it didn't matter. Q: That's your recollection about what she said? A: Yes, she said — I

protected by privacy rights 26570 08/13/2009 Scott Rothstein Marc Nurik Discussions about Epstein Work pro

ected by privacy rights 26570 08/13/2009 Scott Rothstein Marc Nurik Discussions about Epstein Work pro

t reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05440-05441 04/01/2009 Bradley Edwards Carolyn (Legal Asst. to Jay Howell, Co- Counsel) CW Personal information Work product; attorney/client privilege; irrelevant and not reasonably

protected by privacy rights 26570 08/13/2009 Scott Rothstein Marc Nurik Discussions about Epstein Work pro

ected by privacy rights 26570 08/13/2009 Scott Rothstein Marc Nurik Discussions about Epstein Work pro

t reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05440-05441 04/01/2009 Bradley Edwards Carolyn (Legal Asst. to Jay Howell, Co- Counsel) CW Personal information Work product; attorney/client privilege; irrelevant and not reasonably

ngers of the 6 false information. 7 And it was important for me to also remind 12:27:43 8 the public that Bradley Edwards was a partner of 9 Rothstein, a man who is spending 50 years in jail 10 for fraudulently creating a Ponzi scheme to sell 11 Jeffrey Epstein cases that didn't exist. Yes, it

with me. 24 I hate traveling alone. I almost never do 16:01:51 25 it unless there is an absolutely essential reason EFTA00601316 164 1 for Carolyn to be somewhere else, such as taking 2 care of her 96-year-old mother. But it is true, I 3 travel with my wife. 4 Q. In fact, the airplane man

latives reserve 64:6 second 12:25 30:14 85:12 65:3 ROSENFELDT 41:16 76:25 64:18 88:16 release reserved 2:2 see sexually 68:21 4:8,11 ROTHSTEIN 21:19,19 28:4 29:21 relevance residents 2:2 25:17,17 40:11 41:2 15:24 18:7 Rule 33:14 46:23 share relevant respective 4:18 46:24 48:8

3:6 burning 15:11 burnt 36:7,10,14 business 20:25 21:2 27:5,6 30:23 38:3 39:24 43:15 97:4 captioned 97:10 car 89:16 care 47:19 60:11 Carolyn 3:3 5:19 8:14 case 98:3,5,6,8 98:9,11,12 98:14,15,17 98:18,20 changed 81:11,15,18 changes 81:3 97:11 characterize 46:7 charge 56:5 cl

sefsberg Beth Williamson Paralegal RRA Bradley Edwards Attorney RRA Cara Holmes Attorney RRA Carl Linder Attorney RRA Carla Martinez Law Clerk at RRA Carolyn (Legal Asst. to Jay Howell, Co-Counsel) Carolyn Edwards (Legal Asst. to Jay Howell, Co-Counsel) Confidential Source Christina Fitch Staff RRA | Deni

ictims Robin T. Kempner Ronald Wise RRA Personnel Russell Adler RRA Staff Forensics (Epstein Case) Attorney RRA | Scott Goldstein Attorney RRA Scott Rothstein Attorney RRA Seth Lehrman Attorney RRA Shawn Gilbert Prior Legal Assistant to Brad Edwards Sid Garcia Counsel for other Epstein Victims Counsel

orney RRA | Scott Goldstein Attorney RRA Scott Rothstein Attorney RRA Seth Lehrman Attorney RRA Shawn