Epstein Secrets

cum for Deposition, dated November 5, 2009, upon Bradley J. Edwards, Esq.; Rothstein Rosenfeldt Adler, PA; Stuart Rosenfel

1 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08-80811 [email protected] Jack Scarola, Esq. Jack P. Hill, Esq. Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 Phone: 954-522-3456 Fax: 954-527-8663 bedwar

which were entered into by an investor relating to any plaintiff's case with Jeffrey Epstein and any of the following: a. Scott W. Rothstein b. Bradley J. Edwards C. RRA e. any entity formed by RRA or Bradley J. Edwards or Scott W. Rothstein to create investment opportunities for third party investors to inv

and proper. Rule 7 .1 A. 3. Certification of Pre-Filing Conference Counsel for Defendant in good faith conferred with Plaintiff's counsel, Bradley Edwards, by telephone and Mr. Edwards does not oppose the entry of an order. Counsel for Defendant wrote and enclosed copies of this motion and proposed ag

nfeldt, individually, and Rothstein Rosenfeldt Adler, P.A., Coffey Burlington, 2699 South Bayshore Drive, Penthouse, Miami, Florida 33133, and Paul Singerman, Esq., counsel for Herbert Stettin, Esq. as Court Appointed Receiver, Berger Singerman, 2000 South Biscayne Blvd., Suite 1000, Miami, FL 33131. Res

th Bayshore Drive, Penthouse, Miami, Florida 33133, and Paul Singerman, Esq., counsel for Herbert Stettin, Esq. as Court Appointed Receiver, Berger Singerman, 2000 South Biscayne Blvd., Suite 1000, Miami, FL 33131. Respectfully submitted, By: s/Robert D. Critton ROBERT D. CRITTON, JR., Florida Bar No.

this order, Berger Singerman, as counsel for the Trustee, Herbert Stettin ("Trustee"), shall deliver to Gary Farmer at the Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. law firm ("Farmer Jaffe), a copy of the CD produced pursuant to Order 888 to Judge Robert Carney as Special Master and whic

nts in the Trustee's possession, respecting the subject matter of the subpoena previously served upon the Trustee related to L.M., Scott Rothstein, Brad Edwards and Jeffrey Epstein. b. Farmer Jaffe shall review all documents contained on the CD and prepare a detailed privilege log within thirty (30) days o

ollows: EFTA00724361 Case 09-34791-RBR Doc 1068 Filed 10/15/10 Page 2 of 3 a. Within two business days following receipt of this order, Berger Singerman, as counsel for the Trustee, Herbert Stettin ("Trustee"), shall deliver to Gary Farmer at the Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.

o their position on the motion and as to whether they agree to the relief sought or intend to file a response in opposition, only one attorney, Mr. Bradley Edwards, could definitively state that he had no EFTA00728637 Case 9:08-cv-80119-KAM Document 408 Entered on FLSD Docket 11/16/2009 Page 2 of 2 oppositio

se in opposition, only one attorney, Mr. Bradley Edwards, could definitively state that he had no EFTA007

ocument 408 Entered on FLSD Docket 11/16/2009 Page 2 of 2 opposition to the relief sought in the Motion. The other two attorneys involved, Mr. Paul Singerman and Mr. Kendall Coffee, have requested until Monday, November 16, 2009, in which to state either their non-objection to the relief sought, or to fil

22 pertains to MS Capital, and on and on 23 So, in any event, what we realized is 24 the cue with respect to the Epstein vs. Scott 25 Rothstein, Bradley Edwards case, is this is 6 (Pages 21 10 24 OUELLETTE & MAULDIN COURT REPORTERS, MC. EFTA00235306 Case 9:08-cv-80893-KAM Document 214-3 Entered on FLSD

or 5 the interested party, LM, also on behalf of 6 it, whether ifs a special master or whether it's 6 Brad Edwards and I'm sorry, your Honor, Mr. Edwards 7 a contract attorney, if they need to do that, but 7 is here with me. I neglected to Introduce him to S 8 1 don't think wo even need to reach th

22 the trustee. That left us in a quandary. n 23 We had a subpoena pending in State 73 24 24 Court. We had correspondence from Berger 75 25 Singerman on behalf of the trustee dist they had OUELLETTE & MAULDIN COURT REPORTERS, EFTA00235301 Case 9:08-cv-80893-KAM Document 214-3 Entered on FLSD D

to their position on the motion and as to whether they agree to the relief sought or intend to file a response in opposition, only one attorney, Mr. Bradley Edwards, could definitively state that he had no Case 9:08-cv-80119-KAM Document 408 Entered on FLSD Docket 11/16/2009 Page 1 of 2 opposition to the

nt 408 Entered on FLSD Docket 11/16/2009 Page 1 of 2 opposition to the relief sought in the Motion. The other two attorneys involved, Mr. Paul Singerman and Mr. Kendall Coffee, have requested until Monday, November 16, 2009, in which to state either their non-objection to the relief sought, or to file