t Court, Southern District of Florida, Miami Division, under Your name, Florida Bar number and e-mail address while you were employed by Rothstein, Rosenfeldt & Adler ("RRA"). 19. Admit that the Complaint (DE #1) in Case No. 09-CV-81092 is two hundred thirty-four (234) pages, contains six hundred forty-four (644

t Court, Southern District of Florida, Miami Division, under your name, Florida Bar number and e-mail address while you were employed by Rothstein, Rosenfeldt & Adler ("RRA"). 3. Admit that the Complaint (DE #1) in Case No. 09-CV-81092 is two hundred thirty-four (234) pages, contains six hundred forty-four (644

ly, as set forth in Exhibits E and F of the Defendant's Sentencing Memorandum, the Defendant has provided assistance to the creditors of Rothstein, Rosenfeldt & Adler and to its trustee in bankruptcy. Combined, these factors militate in favor of a sentence below the advisory Guidelines sentence. However, in advoc

in which he granted a protective order regarding the depositions of Michael Fisten and Rick Fandrey, investigators previously employed by Rothstein, Rosenfeldt & Adler ("RRA"). As the Court may recall, RRA represented Jane Doe prior to its implosion. 5 EFTA00728108 16. While Epstein sought to depose Mr. Fisten

of 97 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 in the bankruptcy for the law firm Rothstein, Rosenfeldt & Adler had been subpoenaed to produce emails contained on the server of that law firm? A I don't recall. Q Did it ever come to your attention that ema

g 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 of the firm, defendant Scott Rothstein,

unsel to the bankruptcy trustee. A I don't recall. Q Did you ever come to learn that the trustee in the bankruptcy for the law firm Rothstein, Rosenfeldt & Adler, had been subpoenaed to produce emails contained on the server of that law firm? A I don't recall. DRAFT !!!! NOT PROOFREAD EFTA00804174 14

ON Edwards seeks to prevent Epstein from introducing any testimony and evidence regarding the criminal misconduct that occurred with the Rothstein, Rosenfeldt & Adler law firm ("RRA") during the six months that he was employed there, but that was not known to Epstein until after December 9, 2009. Epstein agrees t

r recipient ("to," "cc," or "bcc"), for the period of March 1, 2009, through November 30, 2009, obtained from the e-mail servers of the Rothstein, Rosenfeldt & Adler firm during the United States' investigation of Scott Rothstein, including in the matter of United States of America v. Scott W. Rothstein, U.S. Di

In November, 2009, Rothstein voluntarily relinquished his law license in midst of the collapse of a firm in which he was a member, called Rothstein, Rosenfeldt & Adler, P.A. ("RRA"). 4. Rothstein was disbarred by the Florida Supreme Court on November 20, 2009. Subsequently, Rothstein was arrested, arraigned in f

Herbert Stettin was initially appointed as a state court appointed receiver, and subsequently as the chief re-structuring officer of the Rothstein, Rosenfeldt & Adler, P. A. ("RRA") law firm. 2. Subsequently, RRA was placed in an involuntary bankruptcy, which was not contested, and Herbert Stettin was appointed

Herbert Stettin was initially appointed as a state court appointed receiver, and subsequently as the chief re-structuring officer of the Rothstein, Rosenfeldt & Adler, P. A. ("RRA") law firm. 2. Subsequently, RRA was placed in an involuntary bankruptcy, which was not contested, and Herbert Stettin was appointed

Herbert Stettin was initially appointed as a state court appointed receiver, and subsequently as the chief re-structuring officer of the Rothstein, Rosenfeldt & Adler, P. A. ("RRA") law firm. 2. Subsequently, RRA was placed in an involuntary bankruptcy, which was not contested, and Herbert Stettin was appointed

reimbursement of costs and expenses or in payment for legal services rendered. 9. A copy of all documents reflecting payments by you, Rothstein, Rosenfeldt & Adler, Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman PL and/or any other law firm through which you have provided legal services and/or an other law

nk, 20 out of jail, and there are civil suits taking place. 21 Many of these are coming out of a disgraced law firm, 22 Rothstein Adler -- Rothstein, Rosenfeldt & Adler. 23 At that law firm is a lawyer who started 24 there in April, May, 2009, called Brad Edwards. In 25 2009, allegedly the FBI gets a call

of 165 16 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 in the bankruptcy for the law firm Rothstein, Rosenfeldt & Adler had been subpoenaed to produce emails contained on the server of that law firm? A I don't recall. Q Did it ever come to your attention that ema

co-counsel who were helping him with this case, one of the former judges of this court who resigned in order to accept a position with Rothstein, Rosenfeldt & Adler, and was co-prosecuting this case with Brad Edwards. Mr. Epstein cannot say, Tell me about the conversation that you had with one another about t

summary of the action in the complaint that was filed. "Attorney Scott Rothstein, aided by other lawyers and employees of the firm for Rothstein, Rosenfeldt & Adler, PA for personal greed and enrichment in betrayal of the ethical, legal and fiduciary duties to their own clients, the professional obligations t

nk, 20 out of jail, and there are civil suits taking place. 21 Many of these are coming out of a disgraced law firm, 22 Rothstein Adler -- Rothstein, Rosenfeldt & Adler. 23 At that law firm is a lawyer who started 24 there in April, May, 2009, called Brad Edwards. In 25 2009, allegedly the FBI gets a call