Epstein Secrets

FROM AMENDED ORDER ID.E. 1068t AND TO COMPEL JEFFREY EPSTEIN TO PAY FOR THE PRODUCTION OF ALL DOCUMENTS IN RESPONSE TO HIS REOUEST Movants, LM and Bradley J. Edwards, move this Court for relief from Amended Order [D.E. 1068] related to the production of documents requested by Jeffrey Epstein and to Compel Jeffre

in and to Compel Jeffrey Epstein to Pay for the Production of all Documents which he has requested, and in support thereof, states as follows: 1. Brad Edwards, an attorney employed by Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. ("Farmer Jaffe Weissing"), has represented LM and other women who

all Documents which he has requested, and in support thereof, states as follows: 1. Brad Edwards, an attorney employed by Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, P.L. ("Farmer Jaffe Weissing"), has represented LM and other women who allege that they were sexually exploited, sexually abused

s. 2. Epstein filed a frivolous lawsuit against Attorney Edwards and his client LM, who is one of Epstein's forme

P Four Seasons Tower 15th Floor 1441 Brickell Avenue Miami, Florida 33131-3407 [email protected] (VIA CM/ECF and EMAIL) Conrad & Scherer, LLP 633 South Federal Highway Fort Lauderdale, FL 33301 [email protected] JSilven@conradscherencom (VIA CM/ECF and EMAIL) EFTA00724500 Case 09-34791-RBR Doc 1120 Filed

ulted her when she was a minors. The parties recently reached a confidential settlement of this lawsuit on the eve of trial. 4. Movant's counsel, Brad Edwards was employed by RRA. During this time Attorney Edwards securely and confidentially maintained hard-copies of certain file materials and maintained

d a confidential settlement of this lawsuit on the eve of trial. 4. Movant's counsel, Brad Edwards was employed by RRA. During this time Attorney Edwards securely and confidentially maintained hard-copies of certain file materials and maintained substantial parts of client case files and investigative

eeking production from Trustee Herbert Stettin of Attorney Edwards case files and investigative files which relate

1-3407 tt(4)tewlaw.com [email protected] EFTA00780313 Case 09-34791-RBR Doc 818 Filed 07/19/10 Page 8 of 10 Conrad & Scherer, LLP (VIA EMAIL) 633 South Federal Highway Fort Lauderdale, FL 33301 Tel: 954-462-5500 [email protected] [email protected] Michael D. Seese, Esq. (VIA EMAIL) Hinshaw & Culbert

, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell A

frey Epstein; e. Payments made by RRA to or on behalf of any Plaintiff. 2. All e-mails, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell Adler and/or any attorney or representative of RRA and any Investor or third party (person or entity

stify at the taking of a deposition in the above case. (Documents may be produced in lieu of attendance) PLACE OF DTTOSITION Conrad & Scherer 633 South Federal Highway 8th Floor Fort Lauderdale, FL 33301 DATE AND TIME. November 12,2010 at 10: [ X ] YOU ARE COMMANDED to produce and permit inspection and copying

, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell A

frey Epstein; e. Payments made by RRA to or on behalf of any Plaintiff. 2. All e-mails, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell Adler and/or any attorney or representative of RRA and any Investor or third party (person or entity

ember 12, 2011) at 10:00 a.m.. EFTA00731271 Case 09-34791-RBR Doc 1063 Filed 10/13/10 Page 2 of 8 at the offices of Conrad & Scherer, LLP, 633 South Federal Highway, Fort Lauderdale, FL 33301. The examination may continue from day to day until completed. If the examinee receives this notice less than 14 days pr

the following: a. Any Plaintiff and Bradley J. Edwards or any entity with which he has been associated;

hich he has been associated; b. Any Plaintiff and the law firm of RRA. 3. All e-mails, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell Adler and/or any attorney or representative of RRA and any Investor or third party (person or entity

2/11 Page 2 of 8 Bankruptcy for Rothstein Rosenfeldt Adler, under oath on March 2, 2011 at 10:00 M., at the offices of Conrad & Scherer, LLP, 633 South Federal Highway, Fort Lauderdale, FL 33301. The examination may continue from day to day until completed. If the examinee receives this notice less than 14 days pr

ed by the Farmer, Jaffe firm on behalf of Bradley Edwards, Esq. and LM relating to various Jeffrey Epstein

ey Epstein, Plaintiff v. 2 EFTA_R 1_00020909 EFTA01736113 Case 09-34791-RBR Doc 1554 Filed 03/18/11 Page 3 of 5 Scott Rothstein, individually, Bradley J. Edwards, individually and L.M., individually, bearing case number 50-2009 CA 040800XXXX MB AG. The subpoena was directed to the Trustee in this case as the

54 [email protected] JAMES D. SILVER Florida Bar No. 373702 [email protected] CONRAD & SCHERER, LLP Counsel for Creditors 633 South Federal Highway Fort Lauderdale, FL 33301 Tel: (954) 847-3324 Fax: (954) 463-9244 CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true copy of the foregoing has

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

w-Cardenas, LLP Four Seasons Tower 15th Floor 1441 Brickell Avenue Miami. Florida 33131-3407 (VIA CM/ECF and EMAIL) Conrad & Scherer, LLP 633 South Federal Highway Fort Lauderdale. FL 33301 (VIA CM/ECF and EMAIL) Honorable Jeffrey H. Sloman Acting U.S. Attorney 99 NE 4th Street Miami, Fl 33132 (Via U.S. M