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

FL 33409 (fax) By: Jack Scarola, Esq. Florida Bar No. 169440 Law Offices of Marc S. Nurik Attorneys for Scott Rothstein One E. Broward Blvd., Ste 700 Fort Lauderdale. FL 33301 fax) By: Marc S. Nurik, Esq. Florida Bar No. 272817 EFTA00722382

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

-6300 (954) 745-5849 (561) 383-9451 (fax) (954) 745-3556 (fax) Law Offices of Marc S. Nurik Attorneys for Scott Rothstein One E. Broward Blvd., Ste 700 Fort Lauderdale, FL 33301 By: Jack Scarola, Esq. Florida Bar No. 169440 By: Marc S. Nurik, Esq. Florida Bar No. 272817 EFTA00722477 Epstein

RIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro.120 I Plaintiff, Case No. 50 2009CA040800XXXXMB AG v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. AMENDED AND SUPPLEMENTAL MOTION OF PLAINTIFF TO OVERRULE OBJECTIONS AND COMPEL DEFENDANT EDWAR

on Friday, April 1, at 9:00 a.m., the following: EPSTEIN'S AMENDED AND SUPPLEMENTAL MOTION OF PLAINTIFF TO OVERRULE OBJECTIONS AND COMPEL DEFENDANT EDWARDS TO ANSWER QUESTIONS AND APPEAR FOR FURTHER DEPOSITION The following procedures must be noted on all specially set hearing notices in Division AG:

Beach Lakes Boulevard West Palm Beach, FL 33409 Marc S. Nurik, Law Offices of Marc S. Nurik Attorneys for Scott Rothstein One E. Broward Blvd., Ste 700 Fort Lauderdale, FL 33301 w-.1807431MOTCompel.docx K. Luny 097C) l~eph L. Ackerman, Jr. Florida Bar #235954 Christopher Knight Florida Bar #

COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and •., individually, Defendants. Complex Litigation, Fla. R. Civ. Pro.1201 Case No. 50 2009CA040800XXXXMB AG NOTICE OF TAKING D

ight otherwise be construed to be outside its scope. 5. "Epstein" means the Plaintiff. 6. "Holmes" "You" or "Yours" refers to Cara Holmes. 7. "Edwards" means Defendant Bradley J. Edwards. "Rothstein" means Defendant Scott Rothstein. "RRA" or the "Firm" means Rothstein Rosenfeldt Adler, •. 5 EFTA0

th, Suite 1400, West Palm Beach, FL 33401-5012 and Marc S. Nurik, Law Offices of Marc S. Nurik, Attorneys for Scott Rothstein, One E. Broward Blvd., Ste 700, Fort Lauderdale, FL 33301. Joseph L. Ackerman, Jr. Fla. Bar No. 235954 FOWLER WHITE BURNETT •. Phillips Point 777 South Flagler, Suite 901 We