Epstein Secrets

ached to this Notice as Exhibit A, and Edwards' clients' Appellee Brief filed in that case, attached to this Notice as Exhibit B. In Jane Doe No. 1, the United States Court of Appeals for the Eleventh Circuit held that Epstein's former counsel had waived the work- product privilege with respect to documents sought by Ed

F.2d 844, 846 (8th Cir. 1988); In re Doe, 662 F.2d 1073, 1081-82 (4th Cir. 1981). Even if it shared the common goal of reaching a quick settlement, the United States was undoubtedly adverse to Epstein during its investigation of him for federal offenses, and the intervenors' disclosure of their work product waiv

Bradley J. Edwards Bradley J. Edwards Edwards Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 Philip M. Burlington Nichole J. Segal Burlington & Rockenbach, P.A. Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 Co-Counsel for Defendant1Counter-

e months before trial, Epstein filed the underlying Motion to Continue and indicated that he would be moving to stay these proceedings until Doe v. United States is resolved. Thus, after assuming the burden of proof for three years, Epstein now claims that he cannot defend this case and will "be force

• uire Atterbury Goldberger & Weiss, C. 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Pho Fax: Attorneys for Jeffrey Epstein Nichole J. Segal, Esquire n LA llateLaw.com• Burlington & Rockenbach, 444 W Railroad Avenue, Suite 350 West Palm Beach FL 33401 Phone: Attorneys for Bradley J

dmission and requires Epstein to substantively answer, Epstein would consistently assert his Fifth, Sixth and Fourteenth Amendment rights. Fisher v. United States, 425 U.S. 391, 410 (1976); Hoffman v. United States, 341 U.S. 479, 486 (1951). 4 EFTA00808722 Florida Statutes section 90.901 provides: Requirem

a, Barnhart & Shipley, M. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel Jro DeJendan&Counter-Plaintiff Bradley J. Edwards Nichole J. Segal Burlington & Rockenbach, Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 Co-Counsel for Defendant/Counter-Plain

mate, including but not limited to, eligibility for gain time credit based on standard rules and regulations that apply in the State of Florida. At the United States' request, Epstein agrees to provide an accounting of the gain time he earned during his period of incarceration. 13. The parties anticipate that t

21-33 4. Defendant Rothstein's Motion to Set Aside Default, dated A34-36 February17, 2010 Attorneys filing appendix: Philip M. Burlington, Esq. Nichole J. Segal, Esq. BURLINGTON & ROCICENBACH, P.A. 444 West Railroad Avenue, Suite 350 West Palm Beach, FL 33401 1 EFTA00798167 CERTIFICATE OF SERVICE I HE

has changed tactics and asserted a new position: he cannot defend the malicious prosecution claims at the upcoming trial because of the 2008 Doe v. United States proceeding, which was filed before Epstein initiated this litigation. If that is true, how did Epstein intend to prove his claims against Mr. Edward

ce.com Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, FL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Nichole J. Segal, Esq. [email protected]; [email protected] Burlington & Rockenbach, P.A. Courthouse Commons/Suite 350 444 West Railroad Avenue West Pa