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

(Via U.S. Mail) Honorable Jeffrey H. Sloman Acting U.S. Attorney 99 NE 4th Street Miami, Fl 33132 (Via U.S. Mall) Daniel Mink Ovadia Levy do Renato Watches, Inc 14051 NW 14th Street Sunrise, Florida 33323 (Via U.S. Mail) William George Salim, Jr. Moskowitz Mandell & Salim 800 Corporate Dr Ste 510

AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, v. cor.50.2929aufactigIVP111, CASE NO. • A Aq SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and .M., individually, Defendants. COMPL CO Plaintiff, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned

ant, ROTHSTEIN and Stuall osenfeldt, are and were the principal owners of equity in RRA and each co-founded RRA. 6. Defendant, BRADLEY J. EDWARDS ("EDWARDS"), is an individual residing in Broward County, Florida and is licensed to practice law in the State of Florida. At all times relevant hereto, EDWA

etoric directed to cases against EPSTEIN used by Attorney EDWARDS and Berger changed dramatically in addressing th

at ROTHSTEIN was utilizing RRA as a front for the mass selling an alleged interest or investment in the Ci • Epstein. 27. Further evidencing that EDWARDA possibly other attorneys of RRA) knew or should have known and participated in the continuation of the massive Ponzi scheme, a front-page Palm Beac

uity y4rest af6 Iguana, Pembroke Pines, Florida; (BI8) Scott W. Rothstein's e (BI9) Scott W. Rothst interrst in Cart Shield USA, LLC; nterest in Renato Watches; (8110) Scott W. Rot Equity interest in Edify LLC; (B111) Scott W. Rothstein's equity interest in V Georgio Vodka; (B112) ott W. Rothstein's equi

spiracy created and run by Scott Rothstein has been exposed. On Monday, Mr. Epstein filed a state civil RICO lawsuit charging Rothstein, his partner Brad Edwards, and others with tortuous and fraudulent abuses of process that resulted in serious injury to Mr. Epstein. A copy of the Complaint is enclosed with

Rothstein crimes, is now demanding over $2 million in legal fees. As a lawsuit brought by some of the investors' claims, Rothstein and his partner Edwards used Jeffrey Epstein as bait. The litigation strategy, media pronouncements, and investigatory initiatives of Rothstein and Edwards were calculated

FLORIDA &WHEYSett* Plaintiff; v. Complex Litigation, Fla: k cht Pro. 1201 CASE NO. pn 50 2009CAO' -1Oe)"4B SCOTT ROTHSTEIN, indliricluallYt BRADLEY J. EDWARDS, Individually, and L;,M;,. Individually, Defendants. COPY RECEIVED FOR FPLING DEC Ti itgag orfArt6N M. POCK COMPLAINT 0Ingfil% ciPMPTROIVIR

etoric directed to cases against EPSTEIN used by Attorney EDWARDS and Berger changed dramatically in addressing th

Iguana, Pembroke Pines, Florida; (1318) Scott W. Rothstein's equity interest in Cart Shield USA, LLC; (B19) Scott W. Rothstein's equity interest in Renato Watches; (3110) Scott W. Rothstein's equity interest in Edify LLC; (B111) Scott W. Rothstein's equity interest in, Georgio Vodka; (3112) Scott W. Rothstei

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

Via U.S. Mail) Honorable Jeffrey H. Sloman, Acting U.S. Attorney 99 NE 4th Street Miami, Fl 33132 (Via U.S. Mall) Daniel Mink Ovadia Levy c/o Renato Watches, Inc 14051 NW 14th Street Sunrise, Florida 33323 (Via U.S. Mail) William George Salim, Jr. (VIA CM/ECF) Moskowitz Mandell & Salim 800 Corporate

PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. 50 2009 CA 0 h 03 \MCCOMB COPY RECEIVED FOR FILING oic 0 1Mg EMIVION It PUCK COMPLAINT Gl

nt, ROTHSTEIN and Stuart Rosenfeldt, are and were the principal owners of equity in RRA and each co-founded RRA. 6. Defendant, BRADLEY J. EDWARDS ("EDWARDS"), is an individual residing in Broward County, Florida and is licensed to practice law in the State of Florida. At all times relevant hereto, EDWA

etoric directed to cases against EPSTEIN used by Attorney EDWARDS and Berger changed dramatically in addressing th

Iguana, Pembroke Pines, Florida; (BI8) Scott W. Rothstein's equity interest in Cart Shield USA, LLC; (B19) Scott W. Rothstein's equity interest in Renato Watches; (8110) Scott W. Rothstein's equity interest in Edify LLC; (BD I) Scott W. Rothstein's equity interest in V Georgio Vodka; (B112) Scott W. Rothste

PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M., individually, Defendants. 50 2009 CA 0 b 0 3 MOUE 4) COPY RECEIVED FOR HUNG DEC u ( 2008 sriesnoN Ii poCK COMPLAINT p

nt, ROTHSTEIN and Stuart Rosenfeldt, are and were the principal owners of equity in RRA and each co-founded RRA. 6. Defendant, BRADLEY J. EDWARDS ("EDWARDS"), is an individual residing in Broward County, Florida and is licensed to practice law in the State of Florida. At all times relevant hereto, EDWA

etoric directed to cases against EPSTEIN used by Attorney EDWARDS and Berger changed dramatically in addressing th

Iguana, Pembroke Pines, Florida; (B18) Scott W. Rothstein's equity interest in Cart Shield USA, LLC; (819) Scott W. Rothstein's equity interest in Renato Watches; (BI10) Scott W. Rothstein's equity interest in Edify LLC; (BM) Scott W. Rothstein's equity interest in V Georgio Vodka; (BI12) Scott W. Rothstein

m Beach County, Florida, Case No. 50-2009 CA 040800XXXX MB AG. The action is entitled Jeffrey Epstein, Plaintiff vs. Scott Rothstein, individually, Bradley J. Edwards, individually, and L.M., individually. 5. On or about April 17, 2010, counsel for EPSTEIN in the state court had served a Subpoena Duces Tecum for

ff vs. Scott Rothstein, individually, Bradley J. Edwards, individually, and L.M., individually. 5. On or

. Mail) Internal Revenue Service Centralized Insolvency Operations POB 21126 Philadelphia, PA 19114 (Via U.S. Mail Daniel Mink Ovadia Levy do Renato Watches, Inc. 14051 N.W. 14 Street Sunrise, FL 33323 (Via U.S. Mail) EFTA00727975 USI Ann: Anthony Gruppo 200 West Cypress Creek Road, # 500 Case No

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

M/ECF and EMAIL) Honorable Jeffrey H. Sloman Acting U.S. Attorney 99 NE 4th Street Miami, Fl 33132 (Via U.S. Mail) Daniel Mink Ovadia Levy do Renato Watches, Inc 14051 NW 14th Street Sunrise, Florida 33323 (Via U.S. Mail) William George Salim, Jr. Moskowitz Mandell & Salim 800 Corporate Dr Ste 510