hought were very, very high-caliber -- extremely high-caliber. I got to know more people there, of course. One of the clients of the firm was the Conrad Scherer firm. The Conrad Scherer firm was 20 ran by Bill Scherer. Bill Scherer la one of most 21 prominent lawyers in South Florida, certainly in 32 Se

Yeah. I heard of Bill Scharer. Bill Scherer 1 defendants? 4 is a prominent Fort Lauderdale attorney who wa➢ a 0 A Sure. 3 client. His firm Conrad Scherer -- yeah, I've 1 Q And before you would file that complaint, 10 practiced here since 1975. And I had a number of cases 10 you would make sure

Did the Special Magistrate Carney a Scherer tiro was involved in chat litigation, and 3 or Judge Ray over hold a hearing to deternine Che a the Conrad Scherer firm wag alto interested in 4 nature of the privilege? Was that over called up 0 getting to take a look at whatever relevant e -nails 5 for a he

of what Was going on in bankruptcy • I was a personal participant with the lawyers for a court, connunicaced co Judge Carney, • This subpoena 1 Conrad Scherer, and an agreement was reached with 10 was issued in my case. While I respect you and the 10 the 'aware for Conrad Scherer because, as we have It

of what Was going on in bankruptcy • I was a personal participant with the lawyers for a court, connunicaced co Judge Carney, • This subpoena 1 Conrad Scherer, and an agreement was reached with 10 was issued in my case. While I respect you and the 10 the 'aware for Conrad Scherer because, as we have It

Did the Special Magistrate Carney a Scherer tiro was involved in chat litigation, and 3 or Judge Ray over hold a hearing to deternine Che a the Conrad Scherer firm wag alto interested in 4 nature of the privilege? Was that over called up 0 getting to take a look at whatever relevant e -nails 5 for a he

re setting hearing on our Objection to Duces Tecum; cull through bankruptcy filings to pull out pertinent documents to use at hearing re waiver / Conrad Scherer; review bankruptcy hearing transcripts; cull out and review docket for all Orders Setting Trial and prepare detailed timeline to use as demonstrat

e re setting hearing on our Objection to Duces Tecum; cull through bankruptcy filings to pull out pertinent documents to use at hearing re waiver/ Conrad Scherer; review bankruptcy hearing transcripts; cull out and review docket for all Orders Setting Trial and prepare detailed timeline to use as demonstrat

]; Information Charging Scott W. Rothstein in United States of America v. Scott W. Rothstein, 09-60331-CR-COHN On November 20, 2009, the lawfirm of Conrad Scherer filed a complaint, Razorback cause in this case, is well established by his affidavit filed in support of his original summary judgment motion. [ci

rsary in the Razorback Litigation. Edwards waived attorney-client privilege and work-product protection claimed in the e- mails by producing them to Conrad Scherer in the Razorback litigation. Section 90.507, Florida Statutes governs this type of waiver by voluntary disclosure and provides: Waiver of privilege

tigations into over one-half of the attorneys employed by RRA. At or about the same time in November 2009, I also became aware that the law firm of Conrad Scherer filed a Complaint against Scott Rothstein and others, Razorback Funding, LLC, et al. v. Scott W. Rothstein, et al., Case No. 09-062943(19) (hereina

gations into approximately 40 of the 70 attorneys employed by RRA. At or about the same time in November 2009, the press reported that the law firm Conrad Scherer filed a Complaint against Rothstein and others, Razorback Funding, LLC, et aL v. Scott W. Rothstein, et at, Case No. 09-062943(19) (hereinafter the

tigations into over one-half of the attorneys employed by RRA. At or about the same time in November 2009, I also became aware that the law firm of Conrad Scherer filed a Complaint against Scott Rothstein and others, Razorback Funding, LLC, et al. v. Scott W. Rothstein, et al., Case No. 09-062943(19) (hereina

d before he was criminally charged last month with using the firm to run a $1.2 billion investment racket."). On November 20, 2009, the law firm of Conrad Scherer filed a complaint, Razorback Funding, LLC, et aL v. Scott W. Rothstein, et aL, Case No. 09-062943(19) (hereinafter referenced as the "Razorback Com

ions into over one- half of the attorneys employed by RRA. 8. At or about the same time in November 2009, I also became aware that the law firm of Conrad Scherer filed a Complaint against Scott Rothstein and others, Razorback Funding, LLC, et al. v. Scott W. Rothstein, et al., Case No. 09-062943(19) (hereina

gations into approximately 40 of the 70 attorneys employed by RRA. At or about the same time in November 2009, the press reported that the law firm Conrad Scherer filed a Complaint against Rothstein and others, Razorback Funding. LLC, a at v. Scott W. Rothstein, a at, Case No. 09-062943(19) (hereinafter the "

ions into over one- half of the attorneys employed by RRA. 8. At or about the same time in November 2009, I also became aware that the law firm of Conrad Scherer filed a Complaint against Scott Rothstein and others, Razorback Funding, LLC, et al. v. Scott W. Rothstein, et al., Case No. 09-062943(19) (hereina

2 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 this Ponzi scheme. On November 20, 2009, the law firm of Conrad Scherer initiated a lawsuit against Rothstein and others entitled Razorback Funding, again, a copy of which is provided to the Court and is relied upon as

ions into over one- half of the attorneys employed by RRA. 8. At or about the same time in November 2009, I also became aware that the law firm of Conrad Scherer filed a Complaint against Scott Rothstein and others, Razorback Funding, LLC, et al. v. Scott W. Rothstein, et al, Case No. 09-062943(19) (hereinaf

years ago (for whatever expedient or economic reason) to voluntarily give away the allegedly attorney-client privileged and work product e-mails to Conrad Scherer in the Razorback litigation triggered section 90.507. After taking steps inconsistent with the maintenance of privileges in confidential information