Epstein Secrets

of Undisputed Facts. • Complaint ¶38(iv): With regard to former Sony Record executive Tommy Mottola, Edwards was not the attorney that noticed Mr. Mottola's deposition. See Statement of Undisputed Facts. • Complaint ¶38(v): With regard to illusionist David Copperfield, Edwards had sound legal basis

ton had relevant and discoverable information. See Statement of Undisputed Facts. • Complaint ¶38(iv): With regard to former Sony Record executive Tommy Mottola, Edwards was not the attorney that noticed Mr. Mottola's deposition. See Statement of Undisputed Facts. • Complaint ¶38(v): With regard to illusi

by Scott Rothstein. For example, Epstein alleges generally that "Edwards's... actions constitute a fraud upon Epstein as [Rothstein, Rosenfeldt, and Adler], [Scott] Rothstein and the Litigation Team represented themselves to be acting in good faith and with the best interests of their clients in mind

or, constitutional attorney and one of EPSTEIN'S criminal defense attorneys); (iii)Bill Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (v) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTE

ton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (v) David

an attorney admitted to practice law in Florida. Defendant Rothstein was the Chief Executive Officer (CEO) and Chairman of Rothstein, Rosenfeldt and Adler, PA. 2. Rothstein, Rosenfeldt and Adler, P.A. was a law firm with offices located at 401 East Las Olas Boulevard, Fort Lauderdale, Florida and el

or, constitutional attorney and one of EPSTEIN'S criminal defense attorneys); (iii)Bill Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (v) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTE

ton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and (v) David

an attorney admitted to practice law in Florida. Defendant Rothstein was the Chief Executive Officer (CEO) and Chairman of Rothstein, Rosenfeldt and Adler, P.A. 2. Rothstein, Rosenfeldt and Adler, P.A. was a law firm with offices located at 401 East Las Olas Boulevard, Fort Lauderdale, Florida and e

confident that once we do, I will be able to answer your questions with more specificity. Id. at 83; lines 11-22. Q. Have you ever socialized with Tommy Mottola? A. This is the type of questions where people who have nothing to do with this case whatsoever have been brought into the case by Mr. Edwards in a

ess by Mr. Edwards, his partners, Scott Rothstein, who sits in jail, in an attempt to imperil my friendships. But, yes, I have socialized with Mr. Mottola. Id. at 91; lines 11-19. Q. Have you had a social relationship with David Copperfield? A. As a reaction to, once again, the abusive discovery proc

Scherer's Complaint, it is the partners and people who held themselves out to be partners of the Roth -- Scott Rothstein, including Mr. Berger, Mr. Adler, Mr. Edwards and other people associated with the firm like Mr. Fisten, Diane Villegas, if that's how you pronounce her name, Russell Adler, and ma

ton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and J) David

professor, constitutional attorney . and one of EPSTEIN'S criminal defense attorneys); Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and J) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTEI

is Information are realleged and expressly incorporated herein as if set forth in full. THE ENTERPRISE 2. The law firm, Rothstein, Rosenfeldt and Adler, Y.A. (hereinafter referred to as RRA) was a legal entity organized under the laws of the State of Florida and constituted an Enterprise as that te

onstitutional attorney . • and one of EPSTEIN'S criminal defense attorneys); (iii)Bill Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and 1) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTEI

ton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); and 1) David

ingly, EPSTEIN states: SUMMARY OF ACTION Attorney Scott ROthateirtalded by.other lawyerS and employees:at the firth of Rothstein, Rosenfeldt, and Adler,. P.A. for personal greed and enrichment, In betrayal of the ethical, legal and fiduciary duties' o their 6wn debts and professional dbligatibna to

rd Law professor, constitutional attorney and one of EPSTEIN'S criminal defense attorneys); ill Clinton (Former President of the United States); T mmy Mottola (former President of Sony Record); and (v) David Copperfield (illusionist). 39. The above-named individuals were friends and acquaintances of EPSTE

s an attorney admitted to practice law in Florida. Defendant Rothstein wilt& Chief Executive Officer (CEO) and Chairman of Rothstein, Rosenfeldt and Adler, CR-COHN 14.6.alS1 RA ! c, 1U1D{ 6WCZARI • - FILED by DEC 0 1 2009; STEVEN M. LARIMORE CLERK U. S. DIST. CT. S. D. of FLA. - FT. LAUD. Roth