Epstein Secrets

se Management Report and would state as follows: A. BRIEF FACTUAL STATEMENT The Plaintiff seeks damages against the Defendants, Scott Rothstein and Bradley J. Edwards, based on an illegal Ponzi scheme by the Defendants, and the Plaintiff believes others as well, to market investments to outside investors in the la

se lawsuits were transferred to a newly formed firm of Farmer, Jaffee, Weissing, Edwards, Fistos & Lehrman, LP ("Farmer Jaffee"), of which Defendant Edwards is a member. EFTA00722377 Epstein v Rothstein, et al. 2 Case No. 502009CA0408003OOC3CMBAG The Plaintiff has alleged and believes that the Defen

Defendant, Scott Rothstein Marc Nurik, Esq. G. NECESSITY FOR A PROTECTIVE ORDER TO FACILITATE DISCOVERY Unknown at this time. .1 EFTA00722379 Epstein v Rothstein, et al. I 4 Case No. 502009CA040800XXXXMBAG H. PROPOSAL FOR TILE FORMULATION AND SIMPLIFICATION OF ISSUES/ TIMING OF MOTIONS FOR SUMMARY JUDGMENT

se Management Report and would state as follows: A. BRIEF FACTUAL STATEMENT The Plaintiff seeks damages against the Defendants, Scott Rothstein and Bradley J. Edwards, based on an illegal Ponzi scheme in which the Defendants and others are alleged to have participated. The Plaintiff contends that the scheme involv

for a period of time first by Bradley J. Edwards, individually, and them by the now defunct Law Firm of Rothstein, Rosenfeldt & Adler, ("RRA") when Edwards joined that firm. Some of these lawsuits were transferred to a newly formed firm of Farmer, Jaffee, Weissing, Edwards, Fistos & Lehrman, LP ("Farme

(iii) To identify any non-parties: 30 days after the production of the records from RRA by the bankruptcy trustee/special master; EFTA00722474 Epstein v Rothstein, et al. I 4 Case No. 502009CA040800XXXXMBAG (iv) To disclose expert witnesses: 60 days before calendar call, deadline is November 29, 2010; F. N

, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. NOTICE OF HEARING (Specially Set- 15 min.) PLEASE TAKE NOTICE that the undersigned has set down for hearing before the

BURNETT PA. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA00606606 Epstein v Rothstein, Edwards CASE NO. 502009CA040800XXXXMBAG Notice of Hearing PLEASE GOVERN YOURSELVES ACCORDINGLY. In accordance with the Americans With Disabilities Act of

- 2 - FOWLER WHITE BURNETT P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER MOVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA00606609 Epstein v Rothstein, Edwards CASE NO. 502009CA040800XXXXMBAG 9. Paragraph 18 seeks records similar to those described in Paragraphs 9 and 10. Defendant Edwards has n

FLORIDA CIVIL DIVISION CASE NO. 502009CA040800X.XXXMB-AG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. SECOND AMENDED COMPLAINT The Plaintiff, Jeffrey Epstein, ("Epstein"), by and through his undersigned attorneys, files

tein"), by and through his undersigned attorneys, files this action against the Defendants, Scott Rothstein, ("Rothstein") and Bradley J. Edwards ("Edwards") (collectively referred to as "Defendants") and alleges: INTRODUCTION This litigation has at its core a law firm that has been described by a Unit

10 - FOWLER WHITE BURNETT P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLF.R DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA00584204 Epstein v Rothstein, Edwards Case No.: 502009CA040800XXXXMBAG Second Amended Complaint last name so as not to alert the defendant that the case had been filed. Each o