Epstein Secrets

LD NOT BE HELD IN CONTEMPT OF COURT, TO PERMIT DISCOVERY, TO ASSESS SANCTIONS AND COSTS, AND FOR OTHER APPROPRIATE RELIEF Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. ("Farmer Jaffe"), through counsel, hereby moves this honorable Court for an Order to Show Cause Why Fowler White and Jeffre

bankruptcy proceedings, in 2010, Epstein served a broad subpoena attempting to secure thousands of attorney communications by Fanner Jaffe attorney Bradley J. Edwards, Esq., who while previously employed as an attorney at Rothstein Rosenfeldt Adler ("RRA") had represented a number of Epstein's victims in their civ

ained images or copies of the subject documents on its computer or otherwise, the Court retains jurisdiction to award sanctions in favor of Farmer, Brad Edwards or his client." [DE 1194]. Remarkably, in clear and intentional defiance of this Court's order, Fanner Jaffe recently discovered that Fowler White

's files." Letter of transmittal attached hereto as Exhibit A. The subject flash drive contained three separate PDF files respectively titled: (I) "Bradley Edwards.pdf' containing 8,507 pages of emails; (2) "Epstein Searches.pdf' containing 17,348 pages of emails; and (3) "Scott Rothstein.pdf" containing 1,687 page

from the Trustee, which included documents from attorney Edwards related to Edwards' representation of the sex ab

The Order provided this Court with jurisdiction over all discovery sought from the RRA Trustee. 6. On August 13, 2010, this Court appointed former Broward County Circuit Judge Robert Carney as Special Master, who was directed to work with counsel for the Trustee to obtain documents responsive to the subpoena served

inor females, including 3. In about April 2008, Bradley J. Edwards, Esq., was a licensed attorney in Florida, practicing

RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor. CASE NO.: 09-34791-RBR CHAPTER 11 RESPONSE OF= BRADLEY J. EDWARDS. AND FARMER. JAFFE. WEISSING, EDWARDS. FISTOS & LEHRMAN. P.L TO CREDITORS MOTION TO CLARIFY PRIOR ORDERS (a minor victim of sex offenses), Bradley J. Edwards, and Fanner, Jaffe, Weissin

ral statute providing for compensation to victims of child sexual abuse, 18 U.S.C. § 2255. 7. On September 11, 2008, at the request of his client Brad Edwards filed a civil suit against Jeffrey Epstein to recover damages for his sexual assault on Around the same time, he also filed suits for 8. At abou

ile they were minor girls. 4. On June 13, 2008, attorney Edwards agreed to represent on July 2, 2008, attorney E

ence. 31. On August 13, 2010, this Court entered an Order regarding production of documents regarding Jeffrey Epstein. This Court appointed former Broward County Circuit Judge Robert Carney as a special master to work with counsel for the Trustee regarding privileged documents (doc. #888). 32. On September 20, 201

D MOTION FOR SUMMARY JUDGMENT Plaintiff, Jeffrey Epstein ("Plaintiff" or "Epstein"), hereby files the following Response in Opposition to Defendant Bradley J. Edwards' ("Edwards") Renewed Motion for Summary Judgment ("Motion") and states as follows:' SUMMARY OF ARGUMENT Edwards' Renewed Motion for Summary Judgmen

OTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT EDWARDS' RENEWED MOTION FOR SUMMARY JUDGMENT Plaintiff, Jeffrey Epstein ("Plaintiff" or "Epstein"), hereby files the following Response in Opposition to De

On August 4, 2010, the Bankruptcy Court conducted a hearing on Plaintiffs Motion to Compel and entered an Order on August 13, 2010 appointing former Broward County Circuit Court Judge Robert Carney as Special Master to review the documents responsive to the Plaintiff's subpoena served on the Trustee, to determine the

t Production Protocol, as established by D.E. #672 (D.B. #807); (ii) Motion for Protective Order filed by Interested Party Fanner, Jaffe, Weissing, Edwards, Fistos and Lefunzan, P.L. ("Painter, Jaffe") (D.E. #81 8) and its related amendment (D.E. #819). The Court heard argument of all counsel present at

Qtask data for purposes of determining the applicability of the attorney/client and work product privileges that may inure to the benefit of L.M., Brad Edwards, and other current or former clients of Fanner, Jaffe; (ii) segregate any such privileged documents; and (iii) prepare a privilege log in accordanc

ered on FLSD Docket 09/02/2010 Page 2 of 3 Case 09-34791-RBR Doc 888 Filed 08/13/10 Page 2 of 3 DOES HEREBY ORDER: f. The Court appoints former Broward County Circuit Judge Robert Carney as Special Master who shall work with counsel for the Trustee to obtain documents responsive to the subpoena served upon the Tr

t Production Protocol, as established by D.E. #672 (D.B. #807); (ii) Motion for Protective Order filed by Interested Party Fanner, Jaffe, Weissing, Edwards, Fistos and Lefunzan, P.L. ("Painter, Jaffe") (D.E. #81 8) and its related amendment (D.E. #819). The Court heard argument of all counsel present at

Qtask data for purposes of determining the applicability of the attorney/client and work product privileges that may inure to the benefit of L.M., Brad Edwards, and other current or former clients of Fanner, Jaffe; (ii) segregate any such privileged documents; and (iii) prepare a privilege log in accordanc

ered on FLSD Docket 09/02/2010 Page 2 of 3 Case 09-34791-RBR Doc 888 Filed 08/13/10 Page 2 of 3 DOES HEREBY ORDER: f. The Court appoints former Broward County Circuit Judge Robert Carney as Special Master who shall work with counsel for the Trustee to obtain documents responsive to the subpoena served upon the Tr

t Production Protocol, as established by D.E. #672 (D.B. #807); (ii) Motion for Protective Order filed by Interested Party Fanner, Jaffe, Weissing, Edwards, Fistos and Lefunzan, P.L. ("Painter, Jaffe") (D.E. #81 8) and its related amendment (D.E. #819). The Court heard argument of all counsel present at

Qtask data for purposes of determining the applicability of the attorney/client and work product privileges that may inure to the benefit of L.M., Brad Edwards, and other current or former clients of Fanner, Jaffe; (ii) segregate any such privileged documents; and (iii) prepare a privilege log in accordanc

ered on FLSD Docket 09/02/2010 Page 2 of 3 Case 09-34791-RBR Doc 888 Filed 08/13/10 Page 2 of 3 DOES HEREBY ORDER: f. The Court appoints former Broward County Circuit Judge Robert Carney as Special Master who shall work with counsel for the Trustee to obtain documents responsive to the subpoena served upon the Tr

hearing before December 28, 2010 and moves to briefly stay enforcement of its Order [DE 1068] compelling LM and her counsel Fanner, Jaffe, Weissing, Edwards, Fistos, & Lehrman, P.L. ("FJW") to produce a privilege log in order to permit the state court: (1) to first rule on the pending motions for summar

of his alleged victims, ■ as well as attorney, Bradley J. Edwards, Esq.', in Florida state court for conduct that allege

eing overseen by the bankruptcy court [DE 672]. This filing sparked a series of motions for protective orders [DE's 818, 819, 1022]; appointment of Broward County Circuit Judge Robert Carney as special master to take all materials responsive to the subpoena from Stettin and to prepare a privilege log [DE 888]; filings