ered by the Court's Order on other 5th Amendment Privilege issues (DE 242). 3. The undersigned counsel has spoken with Brad Edwards' law partner, William Berger, and each party has agreed to the extension of time until September 11, 2009. 4. While the undersigned lawyers are attempting to resolve certain i

lf of C.M .. A., Adam Langino on behalf of B.B., William Berger on behalf of three Plaintiffs were present for th

A028058XXXXMB AB), (hereinafter "civil actions"). 3. In each of these civil actions, each of the Plaintiffs is represented by Bradley J. Edwards, William Berger and the RRA law firm, 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. Attorneys Russell Alder and Peter Feaman have also appeared for the

with new money without any relevance to the existing claims made by the RRA clients. I) After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non- Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, EDWARDS and Berger, and their three

with new money without any relevance to the existing claims made by the RRA clients. I) After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non- Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, EDWARDS and Berger, and their three

"number one girl," described his genitalia as being deformed, "egg-shaped", according to a police record. Attorneys, including former Cirucit Judge William Berger, sought the release of the sealed deal also as part of their legal strategy in those civil suits. Epstein has repeatedly invoked his right to remai

ber one girl" - described his genitalia as being deformed and "egg-shaped", according to a police record. Attorneys, including former Cirucit Judge William Berger, sought the release of the sealed deal as part of their legal strategy in those civil suits. Epstein has repeatedly invoked his right to remain sil

33401-5913 Phone: Jeffrey H. Sloman, Esq. U.S. Attorney's Office-Southern District 500 S. Australian Ave., Suite 400 West Palm Beach, FL 33401 William Berger, Esq. Attorney For: E.W. Rothstein Rosenfeldt Adler 401 E. Las Olas Blvd., Suite 1650 Ft. Lauderdale, FL 33394 Diana L. Maftin Florida Bar No.

rting to be affiliated with RRA, including without limitation, Mike Fisten, Ken Jenne, Wayne Black, Patrick Patrick Diaz, Rick Fandry, Cara Holmes, William Berger, Russell Adler and Mark Nurik, or any other representatives of or persons purporting to be affiliated with RRA or representing themselves to have k

o or on behalf of any Plaintiff. 2. All e-mails, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell Adler and/or any attorney or representative of RRA and any Investor or third party (person or entity) regarding Jeffrey Epstein or whic

in"), by and through his undersigned counsel moves this court for clarification of the record regarding representations made by Plaintiffs counsel, William Berger, Esq., at the September 23, 2009 hearing on Plaintiffs Motion for Protective Order, and as grounds therefore, would state: 1. Plaintiffs counsel wa

y Plaintiff and the law firm RRA. 3. All emails, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell Adler and/or any attorney or representative of RRA and any investor or third party (person or entity) regarding Jeffrey Epstein or whic

y Plaintiff and the law firm RRA. 3. All emails, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell Adler and/or any attorney or representative of RRA and any investor or third party (person or entity) regarding Jeffrey Epstein or whic

o or on behalf of any Plaintiff. 2. All e-mails, data, correspondence, memos, or similar documents between Bradley J. Edwards, Scott W. Rothstein, William Berger and Russell Adler and/or any attorney or representative of RRA and any Investor or third party (person or entity) regarding Jeffrey Epstein or whic

e plaintiffs or their attorneys; Subsection 3, all e-mails, data, correspondence, memo or similar documents between Brad Edwards, Scott Rothstein, William Berger and Russell Adler and/or any attorney or representative of RRA and any investor or third party, and so on. I think you get the point there. We ca

Fowler White? MR. LINK: If you remember, you can answer that question. THE WITNESS: Sometime in February. BY MR. SCAROLA: Q Are you aware that William Berger was deposed in the state court civil proceeding? A I don't recall. Q Do you know who William Berger is? Palm Beach Reporting Service, Inc. 561-

Fowler White? MR. LINK: If you remember, you can answer that question. THE WITNESS: Sometime in February. BY MR. SCAROLA: Q Are you aware that William Berger was deposed in the state court civil proceeding? A I don't recall. Q Do you know who William Berger is? A No, sir. Q Do you recall a former

with new money without any relevance to the existing claims made by the RRA clients. I) After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non- Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, EDWARDS and Berger, and their three

be affiliated with RRA, including without limitation, Mike Fisten, Ken Jenne, Wayne Black, Patrick Roberts, Patrick Diaz, Rick Fandry, Cara Holmes, William Berger, Russell Adler and Mark Nurik, or any other representatives of or persons purporting to be affiliated with RRA or representing themselves to have k

with new money without any relevance to the existing claims made by the RRA clients. I) After EDWARDS joined RRA, EDWARDS and former Circuit Judge William Berger filed and argued motion to make the Non- Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, EDWARDS and Berger, and their three