Epstein Secrets

ll counsel on the attached list on April Gary M. Farmer, Jr. Farmer, Jaffe, WeissIn°, Edwards, Flstos & Lehrman, PL 425 N. Andrews Ave., Suite 2 Fort Lauderd 33301 Attorn-ys 9klant L.M. cins44_ arr. Gary M. Farmer, Jr. Florida Bar No.: 914444 , 2010. By: 5 EFTA00728322

COTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant. MOTION FOR PROTECTIVE ORDER L.M., pursuant to Florida Rule of Civil Procedure 1.280(c), hereby files this Motion for Protective Order to prevent the depositions of any private investigators who are working on or hav

of the contract, as facts underlying all counts were interrelated). BACKGROUNDS This unique and complex case arose from the 2009 implosion of the Fort Lauderdale law firm Rothstein, Rosenfeldt & Adler, where defendant/counter- plaintiff Bradley Edwards worked and held himself out as a partner. The principal o

Edwards filed his motion to set case for trial, 7 EFTA00793699 the case was not at issue, and thus, the scheduled trial may not proceed based on Florida Rule of Civil Procedure 1440.5 (App. 15). Upon receiving Edwards' Supplement to his Motion for Separate Trials, Epstein's counsel immediately researched the Rule

r, Jr. Wcblaw ; we W. Ches. er. M ewer, 250 S. Australian Avenue Suite 1400 West Palm Beach, FL 3340I 6 Torii* Haddad, M. • 315 SR 7* Street, Fort lauderdek, FL 33301• 954.461 1223 EFTA00617989 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CAS

ntitled to fees and costs. H. ANALYSIS The requirements for a valid proposal for settlement are set forth in section 768.79, Florida Statutes, and Florida Rule of Civil Procedure 1.442. The offer of judgment statute and rule must be strictly construed, as they are in derogation of the common law rule that each party

s of America represented by Fax: Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED United States Attorney's Office 500 East Broward Blvd 7th Floor Ft Lauderdale , FL 33394 xt. 3546 Fax: Email: LEAD ATTORNEY ATTORNEY TO BE NOTICED Date Filed # dear Docket Text 05/01/2009 1 r COMPLAINT and Demand for

the court reasoned that the purpose of discovery is to eliminate the likelihood of surprise and to Insure a fair opportunity to prepare for trial. Florida Rule of Civil Procedure 1.280(b)(1)• see also Surf Drugs. Inc.. v. Vermette 236 So.2d 108, 111 (Fla. 7 EFTA00175217 Case 9:09-cv-80656-KAM Document 5 Entere

~; and Bradley4 • . and William J. , . • . • y llf 'I' i • . . : Berger; Esq., RothstakfRoeenlbldiAdler, 401 East Las Olas Blvd :111.; 3650, Fon Lauderdale, I li • ' I ' , jr, !. Ir: ' .:ridri Pt 43JN (taxi bath's ist day off:Ina, 2009.! 1.11,1! : : • t.:( : : i• ! st. i ' re+ I • : . !

EPSTEIN, JEFFREY E, Defendant. MOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW COMES NOW, Applicant, ■. and requests this Court, pursuant to Florida Rule of Civil Procedure 1.230, for leave to intervene as a party in Mr. Epstein's criminal matter for the following reasons: 1. Applicant's intervention is in