FELDT ADLER, P.A.'S RESPONSE TO DEFENDANT'S EMERGENCY MOTION FOR ORDER FOR THE PRESERVATION OF EVIDENCE [D.E. 405] The Honorable Herbert Stettin ("Stettin"), the State Court appointed1 receiver ("Receiver") and Chief Restructuring Officer ("CRO") of Rothstein Rosenfeldt Adler, P.A.'s ("RRA"), hereby r

Receivership Action: (a) removed Rothstein as the Chief Executive Officer, and (b) appointed Stettin as the Receiver for RRA. Promptly thereafter, Stettin assumed stewardship of RRA and since then, has handled a very broad set of problems, virtually of which have been on an emergency basis, including

rt Rosenfeldt as partner/shareholder and receiver of RRA” (Def’s Emer. Mtn., p.1). However, on November 11, 2009, a resolution was entered appointing Stettin as the CRO of RRA and delegating to him all operational and managerial control over RRA. This Resolution effectively removed Rosenfeldt from all man

Entered on FLSD Docket 11/18/2009 Page 1 of 3 effectively removed him as well, resulting in Stettin, as CRO, being the only executive at RRA. 2 Stettin has represented that he intends to continue to fully comply with his fiduciary duties both as receiver and now as CRO of an alleged bankruptcy debtor

Epstein Case No. 08-CIV-801189 Epstein's Emergency Motion for Order for the Preservation of Evidence & Incorporated Memorandum of Law Page 7 of 9 Stettin, Esq. as Court Appointed Receiver, Berger Singerman, 2000 South Biscayne Blvd., Suite 1000, Miami, FL 33131. At the time this motion is being filed

ant's Emergency Motion for Order for the Preservation of Evidence [DE 405], and states: 1. It now appears that the Honorable Herbert Stettin ("Mr. Stettin") is the sole individual, as the Chief Restructuring Officer, in charge of RRA assets, including electronic and paper records. There also appears t

ng on November 17, 2009. [DE #408]. In a November 16, 2009 Response to Defendant's Emergency Motion for Order for the Preservation of Evidence, Mr. Stettin, in his capacity as RRA's Receiver and Chief Restructuring Officer, 1 represented that he "understands fully the gravity of document and evidence p