Epstein Secrets

18 19 20 21 22 23 24 25 Page 4 context with just a little background about how we got here. This action is a civil action. It's pending in Circuit Court up in Palm Beach County. Jeffrey Epstein has sued Mr. Rothstein, individually, and Mr. Edwards, individually, regarding -- the genesis of which wa

sert the privilege. And I'm seeing legally some appellate issues with that one. Actually, I think we may end up being in a reversible situation in the State Court on that, if it goes before Appellate Court scrutiny. So I'm concerned at this point legally telling Mr. Edwards and telling Mr. Farmer that they

's proper exercise of its jurisdiction to adjudicate matters pending before it, including subpoenas issued from that court. Moreover, the honorable Circuit Court has already ruled on a motion for protective order on the subject state court issued subpoena duces tecum. Accordingly, for reasons of comity, this

materials which the Circuit Court would not allow. See Epstein's Motion to Compel, DE 807. III. Memorandum of Law A. Discovery Issues Related to the State Court Issued Subpoena Arc Not Properly Before the Bankruptcy Court Despite Epstein's stated position to the contrary, neither 28 U.S.C. §§ 152 or 1334 co

to trigger application of section 26.012, Florida Statutes, the statute that establishes the jurisdictional amount required for filing in Florida's Circuit Court (as opposed to County Court). 2 Lewis. 'Lein n. 3059 G.0.90AviNut, Stun 340, COCONW Gotovt, FLOMDA 33133 20340 EFTA00234069 • 'I''• Case 9:08

Case 9:08-cv-80811-WJZ Document 1 Entered on FLSD Docket 07/21/2008 Page 5 of 40 5. The State Court docket has been filed. All papers filed in the State Court are attached to this Removal Petition. Conclusion Because this is a civil action between citizens of different states, excluding any fraudulently

to us. We will 11 THE COURT: And there is a privilege log 11 file the appropriate privilege log with the 12 and the judge has made a ruling? 12 Circuit Court judge who is presiding over the 13 MR. FARMER: No. The dispute now really is 13 case, who is most familiar with the case, who 14 over who's going

1O41O111: Good morning, your Honor, MR. NESVEZTH: — both of whom are MOTE MOTION TO COMP ILPRODUCTTON OF DOCUMENT'S FROM TRUSIta, 12 familiar with the State Court angle on this than 1 12 PURSUANT TO COMMENT PRCOUCTION PROTOCOL BSTABLISHED 13 am, so they came along to be able to elucidate that BY DB0672 (S07),

to trigger application of section 26.012, Florida Statutes, the statute that establishes the jurisdictional amount required for filing in Florida's Circuit Court (as opposed to County Court). 2 Lewis Min PI. 3059 GRANOAVIP44, Sum 340, Cocann Gaon. teem33133 2 0140 EFTA00175482 • 'Case 9:08-cv-13L_ 11-K

#12 in the case of JANE DOE, a/k/a. JANE DOE NO. 1 v. JEFFREY EPSTEIN et al. Case NO.08-80804-CIV-MARRA/JOHNSON should it be Returned to EPSTEIN by the State Court, and expedite the duplication of this evidence immediately upon its return, in advance of any Rule 26 conference. EFTA00175478 Case 9:08-cv-86, .