Epstein Secrets

Connissko II DO 76647D. BoxleillniSflakrsiNcOryAsen: COMMISSION NUMBERIPAPMATIONSEAL Pauc 7 of I 3 EFTA00729497 United States Court of Appeals, Eleventh Circuit. Under Sca]-Civ-Marra. EDWARD MORSE and CAROL MORSE, Plaintiffs-Appellants, v. JAN JONES INTERNATIONAL, INC. a/k/a ICON BY JAN JONES, Defendant-A

that RBA's trust accounts were maintained with a well established international banking institution, in accordance with the rules and regulations of the Florida Bar, and that at:7.gs to balances in the trust accounts was allegedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and o

mitted, COFFEY BURLINGTON Counsel for Plaindffs 2699 South Bayshore Drive, Penthouse Miami, Florida 33133 (305) 858-2900 B OS I LLADNECIV FEIN Florida Bar . 259861 Annexed hereto as Exhibit A is an affidavit from Plaintiff Rosenfeldt attesting to the truthfulness of the allegations contained herein.

ore the United States Supreme Court, First Circuit, Second Circuit, Third Circuit; Fourth Circuit, Fifth Circuit, Sixth Circuit, Ninth Circuit, and Eleventh Circuit. 3. Movant designates RONALD G. NE1W1RT14, ESQ., of FOWLER WHITE BURNETT, P.A., who is qualified to practice in this Court and who consents to des

MIECF) Roth & Schol Attn: Jeffrey C. Roth, Esq .(VIA CMIEC Ft Rogers, Morris & Ziegler, LIP «IA CMIECF) Arthur C. Nelvát, Esq. -(VIA CMIECF) The Florida Bar Mia E. Charnels, Esq. Alan Anthony Pascal, Esq. -(VIA CMIECF) Micheal W. Moskowitz, Esq. -(1/1A CWECF) Francis L Carter, Esq. -(VIA CMIECF) Brad

ed by the local rules of this court, the rules of professional conduct and all other requirements governing the professional behavior of members of the Florida Bar, WHEREFORE, Movant respectfully requests entry of the attached proposed Order Admitting Attorney Pro Hac Vice, authorizing his special admission to

ore the United States Supreme Court, First Circuit, Second Circuit, Third Circuit; Fourth Circuit, Fifth Circuit, Sixth Circuit, Ninth Circuit, and Eleventh Circuit. 3. Movant designates RONALD G. NE1W1RT14, ESQ., of FOWLER WHITE BURNETT, P.A., who is qualified to practice in this Court and who consents to des

MIECF) Roth & Schol Attn: Jeffrey C. Roth, Esq .(VIA CMIEC Ft Rogers, Morris & Ziegler, LIP «IA CMIECF) Arthur C. Nelvát, Esq. -(VIA CMIECF) The Florida Bar Mia E. Charnels, Esq. Alan Anthony Pascal, Esq. -(VIA CMIECF) Micheal W. Moskowitz, Esq. -(1/1A CWECF) Francis L Carter, Esq. -(VIA CMIECF) Brad

ed by the local rules of this court, the rules of professional conduct and all other requirements governing the professional behavior of members of the Florida Bar, WHEREFORE, Movant respectfully requests entry of the attached proposed Order Admitting Attorney Pro Hac Vice, authorizing his special admission to

.,;;7,,..,t,•'‘ Band Traits Plea Nary Ann- < + COIMISSION NUMBERJEXPIILATIONSEAL Pout 7 of 15 EFTA00795681 1 United States Court of Appeals, Eleventh Circuit. Under Seal-Civ-Marra. EDWARD MORSE and CAROL MORSE, Plaintiffs-Appellants, V. 4 c e JAN JONES INTERNATIONAL, INC. a/k/a ICON BY JAN JONES, Defe

THSTEIN investors that RRA's trust accounts in ned with a well established international banking institution, in accordance with d regulations of the Florida Bar, and that access to balances in the trust accoun I egedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and other co

false claims. 2. Rothstein and his co-conspirators abused the legal process in other cases. They forged the signature of judges, and even forged an Eleventh Circuit opinion. 3. Rothstein lawyers demanded phony protective orders. 4. In our case, they sought discovery. of Epstein's plane logs to fish for celebr

that RRA's trust accounts were maintained with a well established international banking institution, in accordance with the rules and regulations of the Florida Bar, and that access to balances in the trust accounts was allegedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and ot

tion were violated when its name was listed among 246 unindicted coconspirators 'This opinion of the Fifth Circuit was made binding precedent in the Eleventh Circuit pursuant to Bonner'. City of Prichard, 661 F.2d 1206, 1209 (11th Cir. 1981) (en bane). 8 EFTA00184851 CAsse€0338cov8EBB5614AW Obnaarrea0M-1EnEnt

06 530 0440 fay P. Issgowitz, ESQ. DaCeectiteitt% 2007 Non 2 0P4 MECUMS Olutica glotta any past or Altura delay. Mr. Epstein currently has four Florida Bar members on his defense team, so attorney scheduling is not an adequate basis for delay. Three weeks ago/ sts° asked you to provide our Office wItht

false claims. 2. Rothstein and his co-conspirators abused the legal process in other cases. They forged the signature of judges, and even forged an Eleventh Circuit opinion. 3. Rothstein lawyers demanded phony protective orders. 4. In our case, they sought discovery of Epstein's plane logs to fish for celebri

that RRA's trust accounts were maintained with a well established international banking institution, in accordance with the rules and regulations of the Florida Bar, and that access to balances in the trust accounts was allegedly monitored by one of the two independent verifiers. 17. Defendant ROTHSTEIN and ot

elieved that this state plea could affect the federal investigation or the rights of my clients in that federal investigation.” In Wild, the Eleventh Circuit panel stated that the government “seemingly” deferred to Epstein’s attorneys’ requests not to notify the victims about the NPA, and that in sending

statements by omission of material facts in his representations [to counsel].” Florida Bar v. Joy, 679 So. 2d 1165, 1166-68 (Fla. 1996). See also Florida Bar re Webster, 647 So. 2d 816 (Fla. 1994) (petition for reinstatement denied due to “misrepresentation by omission”). 442 In Feinberg, 760 So. 2d