Epstein Secrets

S.D. Fla. 2001); Case 9:08-cv-80119-KAM Document 545 Entered on FLSD Docket 05/12/2010 Page 25 of 37 Doe v. Epstein 08-CV80119 Page No. 25 Cooper v. Hallgarten & Co., 34 F.R.D. 482, 483-84 (S.D.N.Y. 1964). Thus, before the Court can order production of the requested returns in this matter, the

ng Service List in the manner specified by CM/ECF on thislZ day of April, 2010. Respectfully submitted, By I.Jlf,tE ROBERT '.cR.rfTON, JR., ESQ. Florida Bar No. 224162 [email protected] MICHAEL J. PIKE, ESQ. Florida Bar #617296 [email protected] BURMAN, CRITTON, LUTTIER & COLEMAN 515 N. Flagler Driv

845345v) 3970112-000042 EFTA00596451 Flores v. Cooper Tire & Rubber Co., 178 P.3d 1176 (Ariz. CI. App.

da confirming that — like the other attorneys at R.RA — he was a "victim" (not perpetrator) of Rothstein's Ponzi scheme, as well as a decision from the Florida Bar dismissing an ethics complaint in which Epstein similarly charged that Edwards was involved in Rothstein's wrongdoing. See SUF ¶¶ 91-92 . So too, e

. Rothstein, et at Complex Litigation Division - Case No.: 09-062943 (19) Third Amended Complaint 19. Plaintiff, COOPER MANAGEMENT (hereinafter, "Cooper"), is a Delaware corporation with its principal place of business in Palm Beach County, Florida. On August 4, 2009, Cooper invested $900,000.00 int

back Funding, LLC, et at, v. Scott W. Rothstein, et at Complex Litigation Division - Case No.: 09-062943 (19) Third Amended Complaint wired into a Florida Bar trust account with strict instructions to only release the funds in that account to the specified investment £under. 278. At some point during the

vincing investors--including the BIF Investor's, Cooper Management, and the Paley Family Investors--to i

n concocted a story about how Platinum's and Centurion's halt in funding caused a client settlement backlog and, as a result, he was facing imminent Florida Bar suspension and a total freeze on RRA's accounts. This was Rothstein cover story for why mounting scheduled settlement payments were not being made

distinguished from [the] ordinary insurance agent, who is employed by insurance com- panies to solicit and write iir ce by, in and the company."); Cooper . Berkshire Life Ins. Co., 148 Md.App. , 83, 810 A.2d 1045 (2002) ("[I]nsurance agents and brokers clearly owe a professionals duty to the insur

grievances against one another they are already embroiled in Judicial dissolution proceedings, and if complaints have not already been filed with the Florida Bar, they are likely to be." Rule 24(a) does not require interven- tion by Garfinkel and Katzman to protect themselves from Rosenbaum's complaints aga

ity — namely, the fad that it was negotiated in violation of the victims' rights. Other cases reach similar conclusions. See, e.g., United States v. Cooper, 70 F.3d 563, 567 (10°' Cir. 1995) (prosecutor agreed to recommend probation, but it later appeared that would be an illegal sentence in this case,

aintiffs. Without attempting to make any connection to the asserted violation of the CVRA, Paragraphs 52 and 53 falsely allege that Movant violated Florida Bar rules and Department of Justice regulations by representing Epstein's employees in civil litigation after Movant retired from the United States Att