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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
.: 09-34791-BKC-RBR Marianella Morales, Esquire Authorized Agent For Joining Creditors Avenida Francisco de Miranda Torre Provincial "A" Piso 8 Caracas, Venezuela (VIA CM/ECF and EMAIL) John H. Genovese, Esq. Robert F. Elgidely, Esq. Theresa M.B. Van Vliet, Esq. Genovese Joblove & Battista, PA
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
BEC-RBR Marianella Morales, Esquire (VIA EMAIL) Authorized Agent For Joining Creditors Avenida Francisco de Miranda Torre Provincial "A" Piso 8 Caracas, Venezuela John H. Genovese, Esq. (VIA CM/ECF) Robert F. Elgidely, Esq. Theresa M.B. Van Vliet, Esq. Genovese Joblove & Battista, PA Bank Of Ame
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
Blvd., # 1000 Ft. Lauderdale, FL 33301 (Via CM/ECF and email) Marianella Morales, Esq. Avenida Francisco de Miranda Torre Provincial "A", Piso 8 Caracas, Venezuela (Via CM/ECF) John H. Genovese, Esq. Bank of America Tower at International Place 100 S.E. 2nd Street, # 4400 Miami, FL 33131 (Via CM
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
(561) 835-8691 Fort Marianella Morales, Esquire Authorized Agent For Joining Creditors Avenida Francisco de Miranda Tone Provincial "A" Piso 8 Caracas, Venezuela (VIA CM/ECF and EMAIL) John H. Genovese, Esq. Robert F idely, Esq. Theresa M. Van Vliet, Esq. Genovese Joblove & Battista, PA Bank O
Edelman Florian Eder Richard Edgar Agustin E. Edwards Robert Edwards John Ehara Felix Ehrat Barry E
ining of Mongolia Columnist Chairman and Chief Executive Officer President and Chief Executive Officer, CAF - Development Bank of Latin America, Caracas Founder. Start-up, USA Chief Executive Officer and Chief Investment Officer Chairman Editor Mist and Director, Arts and Public Life Initiative
behalf of I maestcd Pam Farmer, Jafre, Weissing. Edwards, Fistos & Lehrman. P L. [email protected]
l/ 866 South Dixie Highway Coral Gables, FL 33146 Blue Oaks Limited O0 Mariam/1a Morales AvenidaFranciace de Miranda Tone Provincial 'A' Poo 8 Caracas, 1060 Robert B Carney An Castro EBroward BM 8905 Fort Lauderdale. FL 33301 AM CriStina Chamberlain 520 SE S Ave 83304 Ft Lauderdale, FL 33301
behalf of I maestcd Pam Farmer, Jafre, Weissing. Edwards, Fistos & Lehrman. P L. [email protected]
l/ 866 South Dixie Highway Coral Gables, FL 33146 Blue Oaks Limited O0 Mariam/1a Morales AvenidaFranciace de Miranda Tone Provincial 'A' Poo 8 Caracas, 1060 Robert B Carney An Castro EBroward BM 8905 Fort Lauderdale. FL 33301 AM CriStina Chamberlain 520 SE S Ave 83304 Ft Lauderdale, FL 33301
Entities connected to both Bradley Edwards and Caracas

Jeffrey Epstein
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSONMaria Farmer
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
United States
LOCATIONSouthern District
LOCATIONRobert D. Critton
PERSON
Prince Andrew
PERSONLeon Black
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Salt Lake City
LOCATION
Department of Justice
ORGANIZATIONMartin Weinberg
PERSON
Bill Clinton
PERSON
Virginia Giuffre
PERSON