, 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 responds to the Defe

t seeks information concerning persons, not parties to this litigation, whose privacy rights are implicated. Whatever public documents exist are in the State Court file and equally accessible to Plaintiff. Request No.4. All documents obtained in discovery or investigation relating to either the Florida Crimi

#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, .

2011 Page 3 of 6 inadmissible under the Federal Rules of Evidence and the Florida Rules of Evidence. Counsel for Plaintiffs, for their part, argued the State Court is in the best position to determine whether the evidence is admissible in the state proceeding and that insofar as the internal Justice Department

2011 Page 3 of 6 inadmissible under the Federal Rules of Evidence and the Florida Rules of Evidence. Counsel for Plaintiffs, for their part, argued the State Court is in the best position to determine whether the evidence is admissible in the state proceeding and that insofar as the internal Justice Department

ent speaks for itself about the expectations of the USAO regarding the length and conditions of punishment. Ultimately, the sentence was imposed by the State Court Judge who presided over the matter. At this time, we cannot comment further on your questions regarding any possible cooperation by Mr. Epstein, o

t seeks information concerning persons, not parties to this litigation, whose privacy rights are implicated. Whatever public documents exist are in the State Court file and equally accessible to Plaintiff. Request No.4. All documents obtained in discovery or investigation relating to either the Florida Crimi

2011 Page 3 of 6 inadmissible under the Federal Rules of Evidence and the Florida Rules of Evidence. Counsel for Plaintiffs, for their part, argued the State Court is in the best position to determine whether the evidence is admissible in the state proceeding and that insofar as the internal Justice Department

t seeks information concerning persons, not parties to this litigation, whose privacy rights are implicated. Whatever public documents exist are in the State Court file and equally accessible to Plaintiff. Request No.4. All documents obtained in discovery or investigation relating to either the Florida Crimi

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

seized Evidence identified in Ex. A, to Exhibit 1 of this Motion (Palm Beach Police Department Property Receipt) should it be Returned to EPSTEIN by the State Court, and EFTA00234456 Case 9:08-cv-80804-KAM Document 12 Entered on FLSD Docket 08/21/2008 Page 2 of 5 expedite the duplication of this evidence i

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),

t seeks information concerning persons, not parties to this litigation, whose privacy rights are implicated. Whatever public documents exist are in the State Court file and equally accessible to Plaintiff. Request No.4. All documents obtained in discovery or investigation relating to either the Florida Crimi

, 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 appointed' receiver ("Receiver") and Chief Restructuring Officer ("CRO") of Rothstein Rosenfeldt Adler, P.A.'s ("RRA"), hereby responds to the Defe

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

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

ns is of no moment in these proceedings. The alleged privileged e-mails and all issues related to privilege and waiver are currently pending before the State Court. CONCLUSION As the sole basis for seeking to hold Epstein liable for a violation of the November 2010 Agreed Order, Movants contend that Epstein's

so produced containing 3,804 pages of documents in the first box and 3,880 pages of documents in the second box, totaling 7,684 pages. In May 2012, the State Court Judge Crow ordered 163 pages of documents from the February 23, 2011 privilege log be produced and Edwards and Fanner Jaffe complied. The remaining

o answer those questions is of no moment. The alleged privileged e-mails and all issues related to privilege and waiver are currently pending before the State Court. 5 EFTA00794242 CONCLUSION As the sole basis for seeking to hold Epstein liable for a violation of the November 2010 Agreed Order, Edwards cont

ns is of no moment in these proceedings. The alleged privileged e-mails and all issues related to privilege and waiver are currently pending before the State Court. CONCLUSION As the sole basis for seeking to hold Epstein liable for a violation of the November 2010 Agreed Order, Edwards contends that Epstein'