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

or attorney for any plaintiff and/or any other person acting for or on behalf of any plaintiff, or under her authority and control. D. "RRA" means Rothstein Rosenfeldt & Adler, P.A. E. "Money" means any tangible thing of value. REQUESTED ITEMS 1. For the time period from January 1, 2008, to present, any and all docwnents re

JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro.1201 Plaintiff, v. Case No. 50 2009 CA 040800XXXXMB AG SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants. / SUBPOENA DUCES TECUM FOR DEPOSITION THE STATE OF FLORIDA: Ms. a TO: YOU ARE COMMANDED to appear before a person

to be outside its scope. 5. "Epstein" refers to Jeffrey Epstein, the Plaintiff in the captioned lawsuit. 6. " , "you" or "yours" refers to 7. "Edwards" means Bradley J. Edwards, a defendant in the captioned lawsuit. 8. "Rothstein" means Scott W. Rothstein, a defendant in the captioned lawsuit. 3

aptioned lawsuit. 8. "Rothstein" means Scott W. Rothstein, a defendant in the captioned lawsuit. 3 EFTA00600175 9. "RRA" means the law firm of Rothstein Rosenfeldt & Adler, P.A., and any of its past or present employees, independent contractors, attorneys, partners, shareholders, investigators, agents or other representativ

JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro.1201 Plaintiff, v. Case No. 50 2009 CA 040800XXXXMB AG SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants. SUBPOENA DUCES TECUM FOR DEPOSITION THE STATE OF FLORIDA: TO: YOU ARE COMMANDED to appear before a person authorized

ch might otherwise be construed to be outside its scope. 5. "Epstein" refers to Jeffrey Epstein, the Plaintiff in the captioned lawsuit. 6. 7. "Edwards" means Bradley J. Edwards, a defendant in the captioned lawsuit. 8. "Rothstein" means Scott W. Rothstein, a defendant in the captioned lawsuit. 3

aptioned lawsuit. 8. "Rothstein" means Scott W. Rothstein, a defendant in the captioned lawsuit. 3 EFTA00656513 9. "RRA" means the law firm of Rothstein Rosenfeldt & Adler, P.A., and any of its past or present employees, independent contractors, attorneys, partners, shareholders, investigators, agents or other representativ