11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 On behalf of Third Patty E.W. WILLIAM J. BERGER, ESQUIRE BRADLEY J. EDWARDS, ESQUIRE Rothstein Rosenfeld Adler 401 E. Las Olas Blvd., Suite 1650 Fort Lauderdale, FL 33394 On behalf of Third Party, The Post DEANNA SHULLMAN, ESQUIRE Thomas, LoCiero & Bralow

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 On behalf of Third Patty E.W. WILLIAM J. BERGER, ESQUIRE BRADLEY J. EDWARDS, ESQUIRE Rothstein Rosenfeld Adler 401 E. Las Olas Blvd., Suite 1650 Fort Lauderdale, FL 33394 On behalf of Third Party, The Post DEANNA SHULLMAN, ESQUIRE Thomas, LoCiero & Bralow

es: 1. On November 10, 2009, Rothstein Rosenfeld) Adler, P.A. ("RRA") was put into involuntary bankruptcy. That case is pending as In Re Estate of Rothstein Rosenfeld Adler, P,A., On November 20, 2009, Herbert Stettin was appointed Trustee of RRA. On November 30, 2009, an Order for Relief was entered by this Court. 2.

connection whatsoever to any specific claims of misconduct against the plaintiffs in the Epstein Cases. See letter dated 6 Edwards was a partner at Rothstein Rosenfeld Adler ("RRA") from April 2009 through November 2009, which was during the same period when, according to the Razorback Complaint, the Epstein cases were

were the facts upon which Epstein relied as requisite cause to assert his causes of action against Rothstein and Edwards: Edwards was a partner at Rothstein Rosenfeld Adler ("RRA") from April 2009 through November 2009. During that time, his firm was a front for the largest Ponzi scheme in Florida's history. Also durin

nces to supporting documentation. (R. 808-818). Those facts, along with the references as footnotes, are recounted below. Edwards was a partner at Rothstein Rosenfeld Adler ("RRA") from April 2009 through November 2009.' During that time, his firm was a front for the largest Ponzi scheme in Florida's history,2 and RRA,

individually, and L.M., individually, Defendants. MOTION FOR FROTECTIVE ORDER FOR HERBERT STETTIN, TRUSTEE Herbert Stettin, Chapter 11 Trustee of Rothstein Rosenfeld Adler, P.A., ("RRA") hereby moves for a Protective Order as to a Subpoena issued upon him for records to be produced by March 16, 2011 and states: 1. F

ims of RRA's fraudulent scheme described in the Razorback Complaint received $170,000,000 to settle their claims. [Cite] 6 Edwards was a partner at Rothstein Rosenfeld Adler ("RRA") from April 2009 through November 2009, which was during the same period when, according to the Razorback Complaint, the fraudulent pleading

were the facts upon which Epstein relied as requisite cause to assert his causes of action against Rothstein and Edwards: Edwards was a partner at Rothstein Rosenfeld Adler ("RRA") from April 2009 through November 2009. During that time, his firm was a front for the largest Ponzi scheme in Florida's history. Also durin