2-004 GAG LOWO JANE DOE, ### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80893CIV —MARK. Plaintiff, vs. JEFFREY EPSTEIN, Defendant. # Re-NOTICE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of Donald Trump on, September 24, 2009, 14c fem., at Esquire Court Reporters One Penn Plaza Suite 4715 New York, NY 10119 t\\ 6611/4) The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day day, weekends and holidays excepted, until completed. I HEREBY CERTIFY that a true and correct copy of the foregoing has been served by U.S. Mall and email transmission this 24- day of August 2009 to all those on the attached Service List. OS' **ROTHSTEIN ROSENFELDT ADLER** Attorneys for Plaintiff 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33301 Tel: (954) 522-3456 Fax: (954) 527-8663 Email: [bedwards@rra-law.com](mailto:bedwards@rra-law.com) By: ![](<>)BRAD EDWARDS, ESQ. Florida Bar No.: 542075 cc: Esquire Court Reports NOTA CERTIFIED ### UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV —MARRAf JANE DOE, Plaintiff, JEFFREY EPSTEIN, Defendant. ## Re- NOTICE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plainat; DOE, will take the deposition of on October 19, 2009mS 0:00 a.m., at: /\` Esquire Court Reporters ) One Penn Plaza Suite 4715 , ) New York, NY 10119 The deposition s be conducted pursuant to the Federal Rules of Civil Procedure and shall continue day to day, weekends and holidays excepted, until completed. CERTIFY that a true and correct copy of the foregoing has been served by U.S. 'I and email transmission this day of September, 2009 to all those on the attached Service List. ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33301 Tel: (954) 522-3456 Fax: (954) 527-8663 Email: bedwards(arra-law.com (jO vS1 By: -51.16 BRAD ESQ. Florida Bar No.: 542075 cc: Esquire Court Reporters ## Service List **09-22785** Robert D. Critton, Jr., Esq.\ BURMAN, CRITTON, ET AL.\ 515 North Flagler Drive, Suite 400\ West Palm Beach, FL 33401 **09-22785** Jay Howell & Assoc.,\ 644 Cesery Boulevard,\ Suite 250,\ Jacksonville, FL 32211 **09-22785** Jack Alan Goldberger, Esq.,\ Atterbury Goldberger et al.,\ 250 Australian Ave. South,\ Suite 1400,\ West Palm Beach, FL 33401. **09-22785** Paul G. Cassell, Esq.\ 382 South 1400 E\ Room 101\ Salt Lake Cirty, UT 84112 **09-22785** Jack Alan Goldberger, Esq.\ Atterbury, Goldberger & Weiss, P.A.\ 250 Australian Avenue South\ Suite 1400\ West Palm Beach, FL33401-5012 9/2 UNITED STATES DISTRICT COURT\ SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV-MARRA/ [REDACTED] JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant **Re- NOTICE OF TAKING VIDEOTAPED DEPOSITION** **PLEASE TAKE NOTICE** that the Plaintiff, JANE DOE, will take the deposition of **Nadia Marcinkova** on **October 20, 2009**, at **10:00 a.m.**, at: **Esquire Court Reporters\ One Penn Plaza\ Suite 4715\ New York, NY 10119** The deposition shall be conducted pursuant to the Federal Rules of Civil Procedure and shall continue day to day, weekends and holidays excepted, until completed. **I HEREBY CERTIFY** that a true and correct copy of the foregoing has been served by U.S. Mail and email transmission this 8 day of September, 2009 to all those on the attached Service List. **ROTHSTEIN ROSENFELDT ADLER** Attorneys for Plaintiff 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33301 Tel: (954) 522-3456 Fax: (954) 527-8663 Email: bedwards@rralaw.com ![](<>)By: BRAD EDWARDS, ESQ. Florida Bar No.: 542075 cc: Equire Court Reporters *Phelps\ 2* UNITED STATES DISTRICT COURT\ SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV -MARRAY [REDACTED] JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. **Re - NOTICE OF TAKING VIDEOTAPED DEPOSITION** **PLEASE TAKE NOTICE** that the Plaintiff, JANE DOE, will take the deposition of Ghislane Noelle Maxwell on October 26, 2009, at 10:00 a.m., at: Esquire Court Reporters\ One Penn Plaza\ Suite 4715\ New York, NY 10119 The deposition shall be conducted pursuant to the Florida Rules of Civil Procedure and shall continue day to day, weekends and holidays excepted, until completed. **I HEREBY CERTIFY** that a true and correct copy of the foregoing has been served by U.S. Mail and email transmission this ~~16th~~ day of October, 2009 to all those on the attached Service List. *received for e-mail\ 18.01.16* **ROTHSTEIN ROSENFELDT ADLER** Attorneys for Plaintiff 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33301 Tel: (954) 522-3456 Fax: (954) 527-8663 Email: [bedwards@rra-law.com](mailto:bedwards@rra-law.com) By: ![](<>)BRAD [REDACTED] ESQ. Florida Bar No.: 542075 cc: Esquire Court Reporters **CERTIFICATE OF SERVICE**\ **SERVICE LIST** **Jane Doe v. Jeffrey Epstein**\ **United States District Court, Southern District of Florida** **Jack Alan Goldberger, Esq.**\ **[jgoldberger@agwpa.com](mailto:jgoldberger@agwpa.com)** **Robert D. Critton, Esq.**\ **[rcritton@bclclaw.com](mailto:rcritton@bclclaw.com)** **Isidro Manual** [REDACTED]\ **[isidrogarcia@bellsouth.net](mailto:isidrogarcia@bellsouth.net)** **Jack** [REDACTED]\ **[jph@searcylaw.com](mailto:jph@searcylaw.com)** **Katherine Warthen Ezell**\ **[KEzell@podhurst.com](mailto:KEzell@podhurst.com)** **Michael James Pike**\ **[MPike@bclclaw.com](mailto:MPike@bclclaw.com)** **Paul G. Cassell**\ **[cassellp@bclclaw.com](mailto:cassellp@bclclaw.com)** **Richard Horace Willits**\ **[lawyerswillits@aol.com](mailto:lawyerswillits@aol.com)** **Robert C. Josefsberg**\ **[rjosefsberg@podhurst.com](mailto:rjosefsberg@podhurst.com)** **Adam D. Horowitz**\ **[ahorowitz@sexabuseattorney.com](mailto:ahorowitz@sexabuseattorney.com)** **Stuart S. Mermelstein**\ **[ssm@sexabuseattorney.com](mailto:ssm@sexabuseattorney.com)** **William J. Berger**\ **[wberger@rra-law.com](mailto:wberger@rra-law.com)** *Pley 2* # UNITED STATES DISTRICT COURT for the\ Southern District of New York Jane Doe\ Plaintiff\ v.\ Jeffrey Epstein\ Defendant Civil Action No. 08-80893 CIV-MARRA\ (If the action is pending in another district, [redacted] where:\ Southern District of Florida ## SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION To: Ghisland Noelie Maxwell, 116 East 65 LLL, New York, NY Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a deposition to be taken in this civil action. If you are an organization that is not a party in this case, you must designate one or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf about the following matters, or those set forth in an attachment: | Place: Eaquire Court Reporters, One Penn Plaza
Suite 4715, New York, NY | Date and Time:
10/26/2009 10:00 am | | ---------------------------------------------------------------------------- | --------------------------------------- | | ---------------------------------------------------------------------------- | --------------------------------------- | The deposition will be recorded by this method: Production: You, or your representatives, must also bring with you to the deposition the following documents, electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the material: See Schedule A attached The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule 45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are attached. Date: 09/21/2009 CLERK OF COURT OR *[Signature]*\ *Attorney's Agent* The name, address, e-mail, and telephone number of the attorney representing (name of party) Jane Doe, who issues or requests this subpoena, are:\ Brad [redacted], Esq., Rothstein Rosenfeldt Adler, 401 E. Las Olas Blvd., Suite 1650, Fort Lauderdale, Florida 33301\ Bedwards@rre-law.com. (954) 522 2346 *D f e v* Civil Action No. 08-60893 CIV-MARRA **PROOF OF SERVICE** (This section should not be filled with the court unless required by Fed. R. Civ. P. 45.) This subpoena for (name of individual and title, if any) \_\_\_\_\_\ was received by me on (date) \_\_\_\_\_. - I personally served the subpoena on the individual at (place) \_\_\_\_\_\ on (date) \_\_\_\_\_; or \_\_\_\_\_ - I left the subpoena at the individual's residence or usual place of abode with (name) \_\_\_\_\_\ , a person of suitable age and discretion who resides there,\ on (date) \_\_\_\_\_, and mailed a copy to the individual's last known address; or \_\_\_\_\_ - I served the subpoena on (name of individual) \_\_\_\_\_, who is\ designated by law to accept service of process on behalf of (name of organization) \_\_\_\_\_\ on (date) \_\_\_\_\_; or \_\_\_\_\_ - I returned the subpoena unexecuted because \_\_\_\_\_; or \_\_\_\_\_ - Other (specify): \_\_\_\_\_ Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also\ tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of\ \$ \_\_\_\_\_ My fees are \$ \_\_\_\_\_ for travel and \$ \_\_\_\_\_ for services, for a total of \$ \_\_\_\_\_ 0.00 I declare under penalty of perjury that this information is true. Date: \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_ Additional information regarding attempted service, etc: Federal Rule of Civil Procedure 45 (c), (d), and (e) (Effective 12/1/07) (c) Protecting a Person Subject to a Subpoena. (1) *Avoiding Undue Burden or Expense; Sanctions.* A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The issuing court must enforce this duty and impose an appropriate sanction — which may include lest earnings and reasonable attorney's fees — as a party or attorney who fails to comply. (2) *Command to Produce Materials or Permit Inspection.* (A) *Appearances Not Required.* A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial. (B) *Objections.* A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply: (i) At any time, on notice to the commanded person, the serving party may move the issuing court for an order compelling production or inspection. (ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance. (3) *Quashing or Modifying a Subpoena.* (A) *When Required.* On timely motion, the issuing court must quash or modify a subpoena that: (i) fails to allow a reasonable time to comply; (ii) requires a person who is neither a party nor a party's officer to travel more than 100 miles from where that person resides, is employed, or regularly transacts business in person — except that, subject to Rule 45(c)(3)(B)(iii), the person may be commanded to attend a trial by traveling from any such place within the state where the trial is held; (iii) requires disclosure of privileged or other protected matter, if no exception or waiver applies; or (iv) subjects a person to undue burden. (B) *When Permitted.* To protect a person subject to or affected by a subpoena, the issuing court may, on motion, quash or modify the subpoena if it requires: (i) disclosing a trade source or other confidential research, development, or commercial information; (ii) disclosing an unretained expert's opinion or information that does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party; or (iii) a person who is neither a party nor a party's officer to incur substantial expense to travel more than 100 miles to attend trial. (C) *Specifying Conditions as an Alternative.* In the circumstances described in Rule 45(c)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party: (i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and (ii) ensures that the subpoenad person will be reasonably compensated. (d) Duties in Responding to a Subpoena. (1) *Producing Documents or Electronically Stored Information.* These procedures apply to producing documents or electronically stored information: (A) *Documents.* A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand. (B) *Form for Producing Electronically Stored Information Not Specified.* If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms. (C) *Electronically Stored Information Produced in Only One Form.* The person responding need not produce the same electronically stored information in more than one form. (D) *Inaccessible Electronically Stored Information.* The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery. (2) *Claiming Privilege or Protection.* (A) *Information Withheld.* A person withholding subpoenad information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and (ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim. (B) *Information Produced.* If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the basis for it. After being notified, a party must premptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may premptly present the information to the court under seal for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved. (c) *Contempt.* The issuing court may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena. A nonparty's failure to obey must be excused if the subpoena perports to require the nonparty to attend or produce at a place outside the limits of Rule 45(c)(3)(A)(ii). ### Schedule "A" to the Subpoena Ducea Tatum of Gh!alone Maxwell A list of ell girls that Defendant, Epstein, had at his house at 358 El Brill° Way for any reason at any time, Including guests and masseuses for the entire duration when you worked with or for Jeffrey Epstein. A list of 211 gins that Defendant Epstein, had at his house in Manhattan for any reason at any time, including guests and masseuses for the entire duration when you worked with or for Jeffrey Epstein. Any and all documents that reflect scheduling and/or appointments for Epstein's flights, travels, accommodation, massages or meelino for the entire duration when you worked with or for Jeffrey Epstein. / s'N.,) A complete list of all girls whom you know to have flown in any of Defendant, Epstein'a airplanes or Jets at anytime during the time you worked with or for Jeffrey Epstein. 4/'%e14/' Any and all diaries and/or notes and/or logs that In any way relate to Defendant Epstein, his airplanes, his properties, his assets and/or his finances. *per* # UNITED STATES DISTRICT COURT for the\ Southern District of New York Jane Doe *Plaintiff* v. Jeffrey Epstein *Defendant* Civil Action No. 08-80893 CIV-MARRA (If the action is pending in another district, state where: Southern District of Florida ## SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION To: Ghisland Noelle Maxwell, 116 East 65 LLL, New York, NY **Testimony:** YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a deposition to be taken in this civil action. If you are an organization that is *not* a party in this case, you must designate one or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf about the following matters, or those set forth in an attachment: | Place: Esquire Court Reporters, One Pern Plaza
Suite 4715, New York, NY | Date and Time:
10/26/2009 10:00 am | | ---------------------------------------------------------------------------- | --------------------------------------- | | ---------------------------------------------------------------------------- | --------------------------------------- | The deposition will be recorded by this method: **Production:** You, or your representatives, must also bring with you to the deposition the following documents, electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the material: See Schedule A attached The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule 45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are attached. Date: 09/21/2009 CLERK OF COURT OK *Jane Doe* *Signature of Clerk or Deputy Clerk* *Attorney's Signature* The name, address, e-mail, and telephone number of the attorney representing (name of party) Jane Doe , who issues or requests this subpoena, are: Brad [redacted], Esq., Rothstein Rosenfeldt Adier, 401 E. Las Olas Blvd., Suite 1650, Fort Lauderdale, Florida 33301\ Bedwards@ma-law.com. (854) 522 2346 *16. DL\ no* ## UNITED STATES DISTRICT COURT for the Central District of California Jane Doe ) Mamie' ) v. ) Civil Action No. 06-80893CIV-MARRAJJ0HNSO Jeffrey Epstein ) ) Of tho eclion is pcix1Lng in another district, state wberc: 1 Defendant ) Southern District of Florida ### SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION To Michael Freidman, 53320 Avenida Madero, La Quinta, CA 92253 d Tertnnony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a deposition to be taken in this civil action. If you are an organization that is not a party in this case, you must designate one or more officers, directorS, or managing agents, or designate other persons who consent to testify on your behalf about the following matters, or those set forth in an attachment: Place: Farewell Court Etraorters 50505 SpyolassEl Or, La Ctulota, CA Date and Time: 11/19/2009 10:00 Tbc deposition will be recorded by this method: S courtjimirter O Production: You, or your representatives, must also bring with you to the deposition the following documents, electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the material: The provisions of Fed. ft. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule 95 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are attached. Date: 10/22/2009 CLERK OF COURT OR Signature o/Clerh or Deputy Clark Ateorney:r elpnottere The name, address, e-mail, and telephone number of the attorney representing (name °Murry) 't -- , who issues or requests this subpoena, are: Brad othsleln Rosenfeldt Adler, Suite 1650, 4O1 E. Las Olas Blvd. Fort Lauderdale, FL 33301 954 b 3456 dwards@RRA-law.corn. Jane Doe # UNITED STATES DISTRICT COURT for the Central District of California Jane Doe Plitimuf V. Jeffrey Epstein WOWS/a I Civil Action No. 08-80893CIV-MARRA/JOHNSO of the action is pending in another district, state where: Southern District of Florida ### SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION To: Rosalie Freidman, 53320 Avenida Madero, La Quints, CA 92253 Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a deposition to be taken in this civil action. If you are an organization that is nor a party in this case, you must designate one or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf about the following matters, or those set forth in ea attachment: /Place: Farewell Court Ragprtens L 50605Spyglass MDr. La Quints, GA The deposition will be recorded by this method: Sta ri Reporter Dote and Time: 11/19/2009 10:00 Cl Produalon: You, or your representatives, must also bring with you to the deposition the following documents, electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the material: The provisions of Fed. R. Civ. P. 45(c), relating to your protection B.1. a person subject to a subpoena, and Rule 45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are attached. Date: 10/22/2009 CgRK OF COURT Signature of Clerk or Deputy Clerk Aunty's alproture The name, address, e-mail, and telephone number of the attorney representing (mate of parry) Jane Doe , who issues or requests this subpoena, are: Brad pip. Rothstein Rosenfeldt Allier, Suite 1650, 401 E. Las Olas Blvd. Fort Lauderdale, FL 33301. 954 5 . litedwards©RRA-law.com. 10/20 **UNITED STATES DISTRICT COURT**\ for the\ Central District of California | Jane Doe | ) | | --------------- | ----------------------------------------------------------------------------------------------- | | Plaintiff | ) | | v. | ) | | Jeffrey Epstein | Civil Action No. 08-80893CIV-MARRA/JOHNSO | | | ) | | Defendant | (If the action is pending in another district, state [redacted]
Southern District of Florida | **SUBPOENA TO TESTIFY AT A DEPOSITION\ OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION** To: Michael Sanka, 449 South Beverly Drive, Suite #101, Beverly Hills, Ca 92253 Testimony: YOU ARE COMMANDED to appear at the time, date, and place set forth below to testify at a deposition to be taken in this civil action. If you are an organization that is not a party in this case, you must designate one or more officers, directors, or managing agents, or designate other persons who consent to testify on your behalf about the following matters, or those set forth in an attachment: | Piace: 433 North Camden Drive, 4th floor, Beverly Hills, Fl 90210 | Date and Time: 11/19/2009 10:00 | | ------------------------------------------------------------------- | --------------------------------- | | ------------------------------------------------------------------- | --------------------------------- | The deposition will be recorded by this method: Court Reporter Production: You, or your representatives, must also bring with you to the deposition the following documents, electronically stored information, or objects, and permit their inspection, copying, testing, or sampling of the material: The provisions of Fed. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule 45 (d) and (e), relating to your duty to respond to this subpoena and the potential consequences of not doing so, are attached. Date: 10/22/2009 **CLERK OF COURT** **OR** ![](<>)*Signature of Clerk or Deputy Clerk* *Attorney's signature* The name, address, e-mail, and telephone number of the attorney representing (name of party) Jane Doe, who issues or requests this subpoena, are: Brad [redacted], Rothetein Rosenfeldt Adler, Suite 1650, 401 E. Las Olas Blvd. Fort Lauderdale, FL 33301, 954 522 3458. Bedwards@RRA-law.com. **Federal Rule of Civil Procedure 45 (c), (d), and (e) (Effective 12/1/07)** **(c) Protesting a Person Subject to a Subpoena.** **(1) Avoiding Undue Burden or Expense; Sanctions.** A party or attorney responsible for issuing and serving a subpoena must take reasonable steps to avoid imposing undue burden or expense on a person subject to the subpoena. The issuing court must enforce this duty and impose an appropriate sanction — which may include jost earnings and reasonable attorney's fees — on a party or attorney who fails to comply. **(2) Command to Produce Materials or Permit Inspection.** **(A) Appearance Not Required.** A person commanded to produce documents, electronically stored information, or tangible things, or to permit the inspection of premises, need not appear in person at the place of production or inspection unless also commanded to appear for a deposition, hearing, or trial. **(B) Objections.** A person commanded to produce documents or tangible things or to permit inspection may serve on the party or attorney designated in the subpoena a written objection to inspecting, copying, testing or sampling any or all of the materials or to inspecting the premises — or to producing electronically stored information in the form or forms requested. The objection must be served before the earlier of the time specified for compliance or 14 days after the subpoena is served. If an objection is made, the following rules apply: (i) At any time, on notice to the commanded person, the serving party may move the issuing court for an order compelling production or inspection. (ii) These acts may be required only as directed in the order, and the order must protect a person who is neither a party nor a party's officer from significant expense resulting from compliance. **(3) Quashing or Modifying a Subpoena.** **(A) When Required.** On timely motion, the issuing court must quash or modify a subpoena that: - (i) fails to allow a reasonable time to comply; - (ii) requires a person who is neither a party nor a party's officer to travel more than 100 miles from where that person resides, is employed, or regularly transacts business in person — except that, subject to Rule 45(c)(3)(B)(iii), the person may be commanded to attend a trial by traveling from any such place within the state where the trial is held; - (iii) requires disclosure of privileged or other protected matter, if no exception or willer applies; or - (iv) subjects a person to undue burden. **(B) When Permitted.** To protect a person subject to or affected by a subpoena, the issuing court may, on motion, quash or modify the subpoena if it requires: (i) disclosing a trade secret or other confidential research, development, or commercial information; (ii) disclosing an unretained expert's opinion or information (as it does not describe specific occurrences in dispute and results from the expert's study that was not requested by a party; or (iii) a person who is neither a party nor a party's officer to mean substantial expense to travel more than 100 miles to attend trial. **(C) Specifying Conditions or an Alternative.** In the circumstances described in Rule 45(o)(3)(B), the court may, instead of quashing or modifying a subpoena, order appearance or production under specified conditions if the serving party: (i) shows a substantial need for the testimony or material that cannot be otherwise met without undue hardship; and (ii) ensures that the subpoenad person will be reasonably compensated. **(d) Duties in Responding to a Subpoena.** **(1) Producing Documents or Electronically Stored Information.** These procedures apply to producing documents or electronically stored information: **(A) Documents.** A person responding to a subpoena to produce documents must produce them as they are kept in the ordinary course of business or must organize and label them to correspond to the categories in the demand. **(B) Form for Producing Electronically Stored Information Not Specified.** If a subpoena does not specify a form for producing electronically stored information, the person responding must produce it in a form or forms in which it is ordinarily maintained or in a reasonably usable form or forms. **(C) Electronically Stored Information Produced in Only One Form.** The person responding need not produce the same electronically stored information in more than one form. **(D) Inaccessible Electronically Stored Information.** The person responding need not provide discovery of electronically stored information from sources that the person identifies as not reasonably accessible because of undue burden or cost. On motion to compel discovery or for a protective order, the person responding must show that the information is not reasonably accessible because of undue burden or cost. If that showing is made, the court may nonetheless order discovery from such sources if the requesting party shows good cause, considering the limitations of Rule 26(b)(2)(C). The court may specify conditions for the discovery. **(2) Claiming Privilege or Protection.** **(A) Information Withheld.** A person withholding subpoenad information under a claim that it is privileged or subject to protection as trial-preparation material must: (i) expressly make the claim; and (ii) describe the nature of the withheld documents, communications, or tangible things in a manner that, without revealing information itself privileged or protected, will enable the parties to assess the claim. **(B) Information Produced.** If information produced in response to a subpoena is subject to a claim of privilege or of protection as trial-preparation material, the person making the claim may notify any party that received the information of the claim and the bases for it. After being notified, a party must promptly return, sequester, or destroy the specified information and any copies it has; must not use or disclose the information until the claim is resolved; must take reasonable steps to retrieve the information if the party disclosed it before being notified; and may promptly present the information to the court under seal for a determination of the claim. The person who produced the information must preserve the information until the claim is resolved. **(e) Contempt.** The issuing court may hold in contempt a person who, having been served, fails without adequate excuse to obey the subpoena. A nonparty's failure to obey must be excused if the subpoena purports to require the nonparty to attend or produce at a place outside the limits of Rule 45(c)(3)(A)(ii). Civil Action No. 08-80693CIV-MARRA/JOHNSO **PROOF OF SERVICE** *(This action should not be filed with the court unless required by Fed. R. Civ. P. 45.)* This subpoena for (name of individual and like, if any) \_\_\_\_\_\ was received by me on (date) \_\_\_\_\_ I personally served the subpoena on the individual at (place) \_\_\_\_\_\ on (date) \_\_\_\_\_; or I left the subpoena at the individual's residence or usual place of abode with (name) \_\_\_\_\_\ , a person of suitable age and discretion who resides there,\ on (date) \_\_\_\_\_, and mailed a copy to the individual's fast known address; or I served the subpoena on (name of individual) \_\_\_\_\_, who is\ designated by law to accept service of process on behalf of (name of organization) \_\_\_\_\_\ on (date) \_\_\_\_\_; or I returned the subpoena unexecuted because \_\_\_\_\_; or\ Other (expect): Unless the subpoena was issued on behalf of the United States, or one of its officers or agents, I have also\ tendered to the witness fees for one day's attendance, and the mileage allowed by law, in the amount of\ \$ \_\_\_\_\_ My fees are \$ \_\_\_\_\_ for travel and \$ \_\_\_\_\_ for services, for a total of \$ \_\_\_\_\_ 0.00 I declare under penalty of perjury that this information is true. Date: \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_\ \_\_\_\_\_ Additional information regarding attempted service, etc: IN THE CIRCUIT COURT OF THE\ FIFTEENTH JUDICIAL CIRCUIT IN AND FOR\ PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201\ CASE NO. Plaintiff, 50 2009 CA O 0 B 0 0 XXXXMB v. SCOTT ROTHSTEIN, Individually,\ BRADLEY J. [REDACTED] Individually, and\ L.M., Individually, Defendants. COPY\ RECEIVED FOR FILING\ DEC 07 2009 COMPLAINT SHOULDER FILED\ CLERK'S COMMENTS\ ABOUT BY LAWSIDEN Plaintiff, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN, Individually, [REDACTED] J. EDWARDS, Individually, and L.M., Individually. Accordingly, EPSTEIN states: SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A. for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and professional obligations to the administration of justice, deliberately engaged in a pattern of racketeering that involved a staggering series of gravely serious obstructions of justice, actionable frauds, and the orchestration and conducting of egregious civil litigation abuses that resulted in profoundly serious injury to Jeffrey Epstein one of several targets of their misconduct and others. Rothstein and RRA's fraud had no boundary; Rothstein and his coconspirators forged Federal court orders and opinions. Amongst the violations of law that are the subject of this lawsuit are the marketing Of non-exlstent Epstein settlements end the sanctioning of a series of depositions that were unrelated to any principled Iltigatlen purpose but Instead designed to discover extraneous private Information about Epstein or her personal and business associates (including well-known public figures) In order to defraud investors and support extortionate s for payment from Epstein. The misconduct featured the filing of legal motions pursuit of a civil litigation strategy that was unrelated to the matey or value etheit dents' cases and, instead, had as Its Improper purpose the furthering of Rothstein's misrepresentations and desalt to third party Investors. As a result, Epstein was subject to abusive Investigatory tactics, unprincipled media attacks, and unsupportable legal filings. This lawsuit Is flied and win be vigorously pursued 06 all those defendants. The Rothstein racketeering enterprise endeavored to compromise the tore values of both state end federal ju site systems In South Florida and to vindicate the hardworking and honest lawyers end their clients who were adversely effected by the misconduct that Is the subject of this ComploinL I. Plaintiff reserves the right to add additional defendants — co-consplrators as the and evidence is developed. ### GENERAL ALLEGATONS - 1. Tbla Is an action for damages In excess of \$15,000.00, exclusive costs, Interest, and attorneys' fees. - 2. Plaintiff, EPSTEIN, Is an adult and currently is residing and works In Palm Beath County, Florida. 3. Defendant, SCOTT ROTHSTEIN CROTHSTEIN'), Is en individual residing in Browand County, Florida. end was licensed to practice law In the MeC . elebrida. In Novomber2009, ROTHSTEIN voluntarily relinquished his law licensed thermIdsi of the implosion Of Rofhstetn, Roserdeildt and Adler, PA CERA". He was disbarred by the Florida Supreme Court on November 20, 2009.. Destern '..) 1, 2069, ROTHSTEIN was arrested and arraigned In Federal Court In Brewed Counts', Florida. - 4. At ati times relevant hereto, ROTHSTEIN was the managing partner end CEO of RRA. 5. Defendant, ROTHSTEIN and Stuart Rosenfelt:it, are and were the principal owners of equity In RRA and each co-lotmciec/ RRA. 1. Defendant, J. (11 '). fs an Individual residing in Brower() County, Florida and is licensed to practice law In the State of Ronda. At all times relevant hereto, was en employee, agent, associate, partner, shareholder, andtor other representative of RRA. 1. Defendant, L.M. CL.M.1, is an individual residing In Palm Beach County, Florida. At all times relevant hereto, L.M. was represented by RRA, ROTHSTEIN and in a civil lawsuit against Epstein and was an essential participant in the scheme referenced leo by, among other things, substantially changing prior sworn testimony, so as to assist the Defendants In promoting their fraudulent scheme for the promise of a muttknIlllon dollar recovery relative to the Civil Actions (defined below) involving Epstein, which was completely out of proportion totter alleged darn 1. Non-party, RRA is a Florida Professional Service Corporation, vitthAlfIkliti address of 401 East Las Olas Blvd., Suite 1650, Fort Lauderdale, FL 33401. Intldd910n to Its principal office, RRA also maintained seven offices In Florida, New York, and Venezuela, and employed over 70 attorneys and 200 suppott Med/. RRA also maintains an office' et 1'109 NE-2d Street, Nallendate Beach, Florida 33009.8815, RRA, through its attorneys, Including those named as Defendants hereIR, conducted business tbroc9hoUt Florida, and relevant to this action, conducted business and filed lawsuits on behalf of clients In Palm Beach County, Florida. (RRA is currently a debtor !n bankruptcy. RRA Is not named as a Defendant). ### FACTUAL AttEOATIONs 9. The United States in United States of America v. Scott W. Rothstein Case No. 00-88331CFr.-Cohn, tinged Stelae District Court, Southern DIErtrict of Florida, has brought en action for Racketeering Conspiracy, 18 U.S.C. § 1962(d) against Seen W. Rathsteln,;ho was the chief executive officer and chairmen of RRA. Within the fatortnade% which was filed, the United States of America has Identified the enterprise 044.1041 the law firm, RRA, through which Rothstein In conjunction with 'his cotnapliators" (not yet Identified by the USA) engaged In the pattern of racketeering through its base of operation at the offices of RRA from sometime In 2005 up through and continuing Into November of 2009. Through various criminal activities, Including mall fraud, wire fraud and money laundering, the United States of America asserts that \_ Rothstein and his co-conspirators unlawfully obtained approximately \$1.2 billion from Investors by 'fraud In connection with a POIVil schema. The USA further alleges that -Rothstein end co-Goner:dram initiated the criminal conduct alleged In thOlnahal Information in order to personally enrich themselves and to supplement the incotttentld sustain the daily operation of RRA.' In essence, In the absents of Rothstein and Ms tocenspin3tors conducting the Renzi scheme, the daily op afft which Included payroll (compensation to lawyers, staff, investigators, nts payable Including unlimited Improper, harassing and potential illegal ligation on cases, Including Epstein-related matters, would in all not have been sustainable. A copy of the Information is attached as Exhibit 1 to lliaectfon. 10. As more fully set forth herein, RRA hold itself out as legtlimatety and property engaging In the practice of reality, ROTHSTEIN and others In RRA wore using RRA to market Investmentstes described below, so as to bilk investors out of hundreds of millions of dollars. ROTHSTEIN and others In RRA• devised an elaborate plan through which were sold purported confidential aSsignmants of a structured pay-aut settlements, supposedly reached on behalf of RRA for clients, In exchange for immediate payments to these clients of a discounted lump sum amount Investorswere being promised Ln excess of a 30% return on their Investment which was to be paid out to the Investors over lime. While some of the cases relied upon to induce Investor funding were existing flied cases, It Is believed that the confidential, structured pay-out settlements were all fabricated. 01. Based on media reports, Federal Bureau of Investigation (FBI) press conferences and releases and the Information the massive Ponzl scheme and pattern of criminal activity meant to lure Investors began sometime In 2005 and continuadthretZt the fall of 20439, when the scheme was uncovered by some of the Imestors mite FBI. As of November of 2009, civil lawsuits were and continue to Is toed against watts Defendants ea result of their masetve fraudulent and criminal scheme. 01. This fraudulent end illegal investment scheme is ate° evidenced by the filing of Amended Complaint For Dissolution And For Emergency Transfer of Corporate Powers to Stuart A. Rosonfelot Or, in The Attemathee, For the Appointment of A Custodian or Receiver by ROSENFELDT, and R4101(,, agaInst ROTHSTEIN, Individually. (Case No. 09 059301, In the Circuit Court Seventeenth Judicial Circuit, Steward County, Florida, Complex Business DN.); (herelnaffer 'RRA dissoltfflon action, and attached hereto as Exhibit 2). 01. Plaintiff references the dissolution action for the sole purpose that tl acknowledges that RRA and ROTHSTEIN were in fact conducting an Illegal and Improper Investment or Ponzi scheme based on promises of financial returns from settlements or outcomes of supposed legal actions, Including the actions brought against Plaintiff EPSTEIN. The RRA dissolution action alleges In pad that — ASIOTHSTEIN, the managing partner and CEO of the firm (RRA), has, according to assertions of certain investors, allegedly orchestrated a substantial misappropriation of funds from Investor trust accounts that made use of the law firm's name (RRA). The Investment business created and operated by ROTHSTEIN centered around the sale of Interests In structured settlements? See Preliminary Statement of RRA dissolution action, Exhibit 2 hereto. 14. In furtherance of the scheme, RRA's letterhead was used In communications regarding Investment opportunities in purported structured settlements. RRA's bust account was used to deposit hundreds of millions of dollars or wire transfer of monies 1mm duped investors and other victims. RRA personally guaranteed payments. IS. Rothstein's scheme went so far as to manufacture false. and fraudulent Court opfnbnedorders Including forging the signature\* S liskyisblet it Judge, Kenneth A. 'Matta aed US,. Circuit Cain Judge, Susan it Blacit, Circuit In other cases. it b not yet lostiwitif:he forged similar documents h Eeptein related matters. Sea Composite Britoil 3 hereto. 16. The details of this fraudulent scheme are being revealed one daily basis through various media reports anditA6xtuments. j The most recent estimate of the financial scope of the scheme frS that ft exceeds \$1.2 billion dollars. 01. Ftelevard to this action, EPSTEIN is currently named as a defendant In three civil actions alleging, Inter elle, sexual assault and battery that were handled by RRA and its attorneys Including prior to Its Implosion — one of which is flied In federal court (Jane Doe v. Epstein, Case No. 08-CIV-60B93, U.S.D.C. S.D. Fla.)(Jane Doe Is a Steed Defendant herein), and two of which have been filed in state court In the 19 Judicial Circuit Court, Palm Beach County, State of Florida, (I_Aft. v. Epstein. Case No. 502008CA02/305VOMMB AB; E.W. v. Epstein, Case No. 602006CA026058)0000,48 4 I. At3,1, (hereloafter collecfivety referred to as the "Give Actions,' and LA Is a named Defendant herein). The Clvil Actions were all filed In August and September of 2008. 18. What Is dear Is that a fraudulent and improper Investment or Forth scheme was In fact conducted and operated by RRA and certain of the named Defendants, which scheme d4ectly Impacted EPSTEIN as e named defendant in the CIA &tens. 01. Miami attorney bhd.developer, Man Sakowitz, was quoted in lefiliwarriber 2009 nteu1aaslsacetng that he had met with ROTHSTEIN as-a potential investor In August of 2009, but became suspicious. He stated 9 was convinced it wee an a Pont scheme and I notified the FBi in detail how Scotty ROTHSTEiN was hiding behind a legitimate taw film to peddle fake Investments.' Attorney SakOWit2 was also quoted as saying RO111STEIN had sephiStleated eavesdropping equipment and former law enforcement officers who would alit throut:t potential defendants' garbage looking for damaging evidence to use with Investors 'to show how potential defendants could be in essence blackmailed Into paying settlement that far exceeded the value of any legitimate damage claim 01. Ft. Lauderdale attorney VVUllem Scherer represents multiple Rothstein related Investors. I-fe Indicated In an article that RRA/Rothstein had used the 'Epstein Ploy ... as eahowptece an ball That's the way he raised all the money. fie would use. . cases as bait for luring Investors into fictional cases. All the cases he allegedly structured were fictional. I don't believe there was a real one In there.' In fact, on November 20, 20O9, William Scharer, on behalf of certain clients, filed a 147 page Complaint against ROTHSTEIN, David Boden, Debra Andrew Bamett, TO Bank, NA, Epstein v. IRRA, et al. Pape 9 Spinosa, Jennifer Kerstetter, Rosanne Caretsky and Prey() aSserling various allegations that further prove the massive Ponzl scheme behind the RRA facade; and ns of November 25, 2009, a 249 page Amended Complaint minting additional Defendants-was filed:. r%)' 21, In addition, end upon lnformuffon and belief, ROTHSTEIN, David Soden, Debbie \\Minas, Andrew Barnett, Michael listen and Kenneth Johne (all employees of RRA) through brokers or middlemen would stage regutar meetings dining which false statements were made about the number of cases/clients that existed or RRA had against EPSTEIN and the value thereof. They would show end share actual case files horn the EPSTEIN adons with hedge fund managers. Thus, the attorneys and clients have waived any attorney-ellent or work- product privileges that otherwise may have existed, 22. Because potential Investors were given access to some of the actual Civil Action foes Investor-third parties may have became aware of a name of an existing Plaintiff who had flied anonymously against Epstein and had opposed disclosure of her legal tank In other Instances, by RRA, ROTHSTEIN and EDWARDS claiming the need for tmonyrolty with regard to existing or fabricated clients, they were able to effectively use initials, Jane Doe or other anonymous designations which was a key element in the fraudulont scheme. Fictitious names could be created to make the investors believe many other cases existed against Epstein. 24. in each of RRA's OM\] Actions, the Plaintiffs are or were represented by RRA and its attorneys, Including ROTHSTEIN and 01. in addition, Investors ware told that In addition to the Cavil Actions oliother (50) plus anonymous females were represented by RRA, with the potential f)hundreds of millions of dollars In settlements, end that RRA end its attorneys woulcfsue Epstein unless he paid exorbitant-setUement amounts to protect his high-prof le friends. 01. Upon Informat3on and belief, EDWARDS knew or should have known that ROTHSTEIN was ubliting RRA as a front for the massive Ponzi scheme and/or were Selling an alleged Interest or investment In the etvitActions (and other claims) Involving 01. Further evidencing lhat EDWARbS (and possiiity other attorneys of RRA) knew or should have known and participated In the continuation of the massive Ponzi scheme, a front-page palm Roach Post article, dated November 24, 2008, reported on the recent filing of an amended forfelttne complaint by prosecutors against 'dozens of ROMISTE1N's real estate properties, foreign ears, restaurants and other assets — Including \$12 million In the lawyer's bank account in Morocco, along with millions more donated to political campaigns and charitable funds.' The article further reported that - Attorney Scott ROTHSItIN tapped into millions of dollars from his massive Investment scam to cover payroll costs at his expanding Fort Lauderdale law firm, federal authorities said In court records released Monday. ROTHSTEIN's law rum (RRA) generated revenue of \$8 million in one recent year, yet his 70-lawyer law firm had a payroll of \$18 million, prosecutors said. ROTHSTEIN, who owned half of RRA used investors' money from his Ponzi scheme to make up the shortfall, they said. Subsequent articles and court filings have reflected ROTHSTEIN received compensation in excess of \$35.7 million in 2008 and \$10.5 million in 2009, while his partner Rosenfeldt received greater than \$6 million in 2008. 28. ROTHSTEIN attempted to lure the entity known as D3 Capital Club, LLC, ("D3"), by offering D3 "the opportunity" to invest in a pre-suit \$30,000,000.00 court settlement against EPSTEIN; yet this supposed settlement never existed and was entirely fabricated. To augment his concected story, ROTHSTEIN, upon information and belief, invited D3 to his office to view thirteen (13) banker's boxes of case files in Jane Doe (one of the Civil Actions)1 in an attempt to substantiate that the claims against EPSTEIN were legitimate and that the evidence obtained against him by RRA, ROTHSTEIN, and EDWARDS (the "Litigation Team") was real. 01. Upon information and belief, ROTHSTEIN and others offered other investors like the entity D3 fabricated investment opportunities in the Civil Actions involving EPSTEIN. Fisten (a former Dade County police officer with a questionable police record and RRA investigator) and Jenne (a former attorney, Broward County Sheriff and felon) assisted ROTHSTEIN in making these offers by providing confidential, privileged and work-product information to prospective third-party investors. 1 It appears that 13 out of the 40 boxes selected by the FBI as part of its investigation at RRA consisted of files relating to the Civil Actions involving EPSTEIN, as reported by counsel for the Bankruptcy Trustees. Until those boxes can be reviewed, as well as other discovery, Epstein will not know the depth of the fraud and those involved. 30. By using the Mit Actions against EPSTEIN as 'bar and fabricating settlements regarding sena; RaTHSTER4 and others were able to lure investors Into ROTHSTEOPS lair andffstlitedithem of millions of dollars which, in turn, was used to fund itheritligatbkagalitetf.PSTEIN- for the sots purpose of continuing the massive Pond schittet 01. As pan °flits scheme, ROTHSTEIN and the Uffgation Team, indMdtrally end to ansnsettedMIM have unethloally end fllegally; - a. Sold, allowed to be sold and/or assisted with the sale of an Interest In nonsettled personal Injury lawsuits (which are non-assignable and nontran..sfettble) or sold non-existent structured settlements (Including those cases Involving Epstein); - b. Reached agreements to share attorneys fees with non-lawyers; - c. Used investor.money to pay plaintiffs (I.e., L.M.. E.W. end Jane Doe) ^up front' Money such that plaintiffs would refuse to settle the CM Actions; a, .Ogrjduatezi searches, wiretaps or Intercepted conversations in .violation of etatcor federal laws and Bar rules; and is. Utilized the judicial process Including, but not limited to, unreasonable and A\\ unnecessary discovery, for the sole purpose of furthering the Portz! scheme. 32. Any such actions by ROTHSTEIN, and other attorneys, Including the Litigation Team, directly or Indirectly, would potentially be a violation of various Florida Bar Rules, Including prohibiting the improper sharing of foes or costs end various =inflicts of Isaues rules. 33: Evidencing that the Litigation Team knew or should have knew\* of the Improper potpete that ROTHSTEIN was pursuing In the continuation . '1 the scheme, ROTHSTEIN used RRA's Litigation Team In the EPSTEIN cases to puree Issues end eftlen-se unrelated to and unnecessary to the claims pled In the CNA Actions, but significantly beneficial to lure investors Into the Portz( 4me orchestrated by ROTHSTEIN and other co-conspirators. AN'? 3d. Upon information and belief, ROTHSTEIN.and others claimed their lzwestigatora discovered that them were high-profile individuals onboard Epstelnia private Jet where sexual assaults took place and showed D3 (and possibly others) copies of a flight log purportedhl containing names of selebrIlles, dignitaries, and international figures. 36. For instance, the Litigati'TI:m rakintlessly and knowingly ptcrsued light data rand patsonger manifests regarding flights EPSTEIN took with these famous tricilyiduals knowing full well that no underage women were onboard and no Melt actlytties took plate. ROTJ-tSTE(N and the Litigation Team also inappropriately attempted to take the depositions of these celebrities In a calculated effort to bolster the marketing scam that waa taking place. 01. One of Plaintiffs' counsel, S, deposed three of EPSTEIN'S pilots, and sought the deposition of a fourth pilot (currently serving In Iraq). The pilots wore deposed by for over twelve (12) hours, and never asked one question relating to or about E.W., LM., and Jane Doe (RRA clients) as It related to I• 1 transportation on flights of RRA clients on any of EPSTEIN'S planes, taut =II asked many Inflammatory and leading Irrelevant questions about the ;Vote thoughts and beliefs (which vAti never be admissible al trial) which could only have been asked for the purposes of 'pumping' the cases end thus by using the deposifions to sell the cases (or a part of thorn) to thfrd parties. 37. Because of these facts, RUTHISTEIN clahned that Epstein wanted. to make certain none of these IndMduals would be depesepa0 therefore he had offered \$200,400000,00 to settle the claims of RRA female cfient\*iferious potential plaintiffs In actions against EPSTEIN. The offer of a \$200 Kilon dollar settlement by EPSTEIN A was completely fabricated; no such ever beam made. 01. office also notified endant that he intended to take the depositions =was subpoenaing: - () Donald Trump (real-estate magnate and business mogul): - (a) Alan Dershov4tz (noted Harvard Law professor, constitutional attorney and one of EPSTEIN'S criminal defense attorneys); (iii)BIIJ Clinton (Former President of the United States); (iv)Tommy Mottola (former President of Sony Record); end - (v) David Copperfield 39. The above-named individuals were friends and acquaintances of EPSTEIN with whom he !mew through business or philanthropic work over the years. None of the above-named individuals had any connection whatsoever with any of the Lttgation Team's clients, E.W., L.M. or Jane Doe. 1 1 I i. I t 40. EDWAROS filed amended gnawers to interrogatories in the state court matters, E,W. and LM., and listed additional high profile witnesses that would allegedly be tailed at trial, including, but not limited to: - (i) sot Richardson (Governor of New Mexico, formerly U.S. Representative and Ambassador to the United Nations); and OA) Any and all persons having knee/ledge of EPSTEIN'S charitable, political or other donations:2 41. The sots purpose of the scheduling of these depositions or listing high profile friendsieoquatntendas as potential witnesses was, again, to 'pump' the eaaea to Investors. There is no evidence to data that any of these Individuals had or have any knowledge regarding RRA's CM Actions. 01. In furtherance of their /liegel end fraudulent scheme against EPSTEIN, ROTHSTELN, (who either know or should have (nown) and, at times. L.M. in her Civil Action against EPSTEIN: - a) Included claims for damages in Jane Doe's federal action in excess of \$50,000,000.00 rather than simpty alleging the Jurisdictional limits. - b) Organized a Jane Doe TV media interview without any legitimate legal purpose other than to 'pump\* the federal case for potential I 2 These high-preen csaFebtity 'pot witnesses have no personal knowledge regarding the facts on these 'rue Cases', but were Wog contacted, subpoenaed or listed to heroes end inerntdala them and Epstein, ad to add 'stars appeal to the marketing effort of the Ponzi schema. investors or to prejudice Epsteln's tight to a fair trial in Palm Beach County. - c) Barger and Adler (another named partner In RRA) all attended EPSTEIWa deposition. At that time, outrageous questions wore asked of EPSTEIN which had no bearing on the case, but so that the video and questions could be shown to Investors. - d) Conducted and attempted, to conduct completely Irrelevant fr . discovery unrelated to 11: In or subject matter of the Civil Actions for the purpose of Ing and embarrassing witnesses le and EPSTEIN and causing EPSTEIN to spend tens of thousands A of dollarwin unnecessary attorneys' fees and costs defending 7 what appehledTobe discovery related to the Civil Actions but was entirely related to the furtherance of the Punzl scheme. - e) After was recruited and joined RRA In the spring of 2009, the tone and tenor of rhetoric directed to cases against EPSTEIN used by Attorney and Berger changed drameticaay in addressing the court on various motions from being substantive. rho facts pled to ridiculously Inflammatory and sound-bite rich such as the July 31. 2009, transcript when '----\_\_\_P_WARLOS 8 aced to the Court in E.W./L.M.: 'What the evidence la really going to show Is that Mr. Epstein — at least dating back as I • far as our Investigation and resources have permitted, back to 1997 or '96 — has every single day of his life, made an attempt to sarally abuse cttildren. We're not talking about five, wain, not talking about•20, we're-it talking about 100, we're not talking about 400, which, I believe Is the 111416alk known to law a -f; t, we am talking about thousands of children. .. and It is through a very Intricate and complicated system that ha devised where he has es many as 2.D people worldng underneath him that he Is paying well to schedule these appointments, to locate these girls.' IC - f) As an example, flied an unsupportable and legally deficient Motion for Injunction Restraining Fraudulent Transfer of Assets, Appointment of a Receiver to Take Charge of Property of Epstein, and to Post a \$15 million Bond to Secure Potential t ill(' gment, In Arne Doe v. Epstein, Case No. 08-CV-80893- Marra/M The motion was reported In the press as was the Ultimate goal (i.e., to "pump' the cases for Investor following). However, the Court found 'Plaintiffs motion entirely devoid of evidence ... ', and denied the motion /ft toto. - g) ROTHSTEIN told Investors he had another 52 females that he represented, and that Epstein had offered \$200 million to resolve, o's but that he could settle, confidently, these cases for \$600 million, separate and apart from his legal fees. - h) ROa/ and am Litigation Team knew or should have known that their three (3) filed cases were weak and had minimal value for the following reasons: - (I) L.M. testified she. Orly typo of sex with Epstein; wodted/ et strip dubs; is en admitted prostate le call girt; has a history of Illegal dreg use (pot, patMditers, Xanax, Ecstasy): and continually asserted the Oh Amendment tiering her depositions In order fA iiVetitiericiverIng relevant but problem questions for her, EW. — testified she worked at eleven (11) separate strip clubs, including Cheetah which RRA represented and In which ROTHSTEIN may CY have owned an Interest; and E.W. also worked at Platinum Showgirls fn Boynton Beach, which was the subject of a recant police raid where dancers were allegedly selling prescription painkillers end drugs to customers and prostituting themselves. - (Ill) Jane Doe (federal case) sooke_SS0 mllion from Epstein. She and her attorneys claim severe emotional distress as a result at her having voluntarily gone to Epstein's home. She testified that there was never oral, and(or sexual - - Intercourse; nor did she ever toutAke genitalia. Yet, Jane Doe suffered extreme emotional distress wall prior to meriting Epstein as a result of having witnessed W . She was or his girlfriend's son. sworn te5Um0rty In that matter mated that she has lied In sworn testimony. Jane Doe worked at two different strip dubs, Including Platinum Showgirls In Boynton IC - 0 CondualidAtikalous and Irrelevant discovery such as subpoenaing records from on alleged sox therapist, Dr. Leonard t eard In Massachusetts, when the alleged police report reflected that EPSTEIN had only seen a chiropractor In Palm Beach named Dr. Bard. No records relating to EPSTEIN existed for this alleged sex therapist, Dr. Bard, end the alleged subpoena for records was just another mechanism to 'pump. the cases for Investor appeal; - J) Allowed a Second Amended Complaint to be filed on behalf of L.M. alleging that EPSTEIN forced the minor Into 'oral sex,' yet L.M. testified that she never engaged In oral, anal, or vaginal Intercourse With EPSTEIN and she had never touched his genitalia. - k) Told Investors, as reported in an Associated Press article, that ( celebrities and other famous people had flown wOn"' ... ii plane when assaults took place. Therefore, overtiough none I 1,.\_\_\_\_\_(.zero) of RRA's clients claim they flew EPSTEIN'S planes, the Litigation Team sought pilot Why? Again, to prime the investment spat new phoney without any " 'it\\ relevance to the existing claims marks by the RRA clients. - I) After Joined RRA, and former Circuit Judge William ger fled end argued motion to make the Non-Prosecution mart (NPA) between Epstein and USA° ptiblta. end Barger, and their three clients, / already had a copy of the NPA. They knew what it said and they knew the civil provisions in the agreement had no Impact whatsoever on the three pending CND Actions. The concept behind certain ctvQ provisions in the NPA was to allow an alleged victim to resolve a chell claim with Epstein, maintain her complete privacy and anonymity and move on with her life. As en assistant United States Attorney stated at a hearing In federal court, the NPA was not designed 'to hand them a jackpot or a key toe bank." 43. ROTHSTEIN, with the Intent and improper motive to magnify his financial gain so continua to fund the fraudulent and illegal Investment and/or Ponzi scheme, had EDWARDS demand excessive money from EPSTEIN In the Civil Actions. 01. The actions described In paragraph 42 above herein had no legitimate purpose in pursuing the Civil Actions against EPSTEIN, but rather went meant to further the fraudulent scheme and criminal activity of ROTHSTEIN shat he and others could fraudulently overvaTue the settlement value of the existing and non-existent claims against EPSTEIN to potential Investors. ..---% \\ \*" 45. As a result of the fraudulent Investment or (Pont)) sebum% RRA and Its attorneys to the CMI Actions against EPSTEIN may have compromised their clients' interests. ROTHSTEIN and the Litigation Team would have been unable to give unbiased legai counsel because outside Investor(s) had been promised a financial ,t 7 interest la the outcome of the Weft-. Additionally, if a plaintiff received payments from investment monies while her action Is pending, this dearly could Impact the plaintiff's decision of whether or not to settle the current litigation or shade their testimony (1.0. commit perjury) to gain the greatest return on the investment and to further promote the Ponzi Scheme. 46. The truthfulness of L.M.'s allegations and testimony in L.M.'s state civil have been severely compromised by the need to seek a multi-milflon dollar payout to help maintain RRA's massive fraud. Because fictitious settlements of tens of millions of dollars in cases relating to EPSTEIN were represented to 'Investors' In this Ponzl scheme, RRA and the attorneys In the Civil Actions needed to create a fiction that Included extraordinary damages. However. the actual facts behind her action would never support such extraordinary damages. Therefore, extraordinary measures were undertaken to create an entirely inflated value of her claims against EPSTEIN. 11 - a. Though she held herself out as a "victim' of Epstein, she admitted to having returned over and over again to him despite her curtest claim of abuse. She has now admitted, under oath, to being scall.ght1010:01 shr-ec the an of IS. ------\_\_\_\_\_\_ . - - -: ----- (In her deposition September 24, 2O09 Ttetniorlpt r 2.80:111421. Sbe testified 'Welt I lived life as 0 preSttes, (see DT 156:7) and I am a prostitute when I make moiler 0 7158:12-13). L.M. admitted her activity with men other than Ep.ste b. king \$1,000 a day from prostitution -4' t e ,"," on maybe more than 20 occasions In One year alone (DT 167:11-158:21). .. _ LM, admitted undetveltt to keeping a list of amounts she collected from \*Johns" In "two or ti ol, lined books Including a book of 'Psalms' that she obtained from a religious store (DT 152:1-14). Under tho circomotancoa, hor claim for damages against EPSTEIN, one of LM.'s many 'Johns' during that fine period, would be so incredible and certainly not likely to produce the (ordinaryordinary settlements promised to 'RRA's Investors? -47. In April 2007, before she was represented by EDWARDS, and RRA, L.M. gave sworn taped recorded testimony to the agents of the FBI. She was represented by a lawyer other than at that statement She spoke of EPSTEIN In a very positive and friendly terms and directly contradicted the central allegations on whfch L.M.'s civil action against Epstein is now based. However, once In the hands of C 1 and RRA, L.M.'s story changed dramaticalty. At of a sudden the wanted to sue EPSTEIN and Ike other RRA clients, sought tens of milions of dollars. - e. For example, In her sworn statement to the FBI, L.M. was insistent that 'Jeffrey Is an awesome man? (p. 21 — FBI); At the conclusion of she - \_ stated: I hope Jeffrey, nothing happens to Jeffrey because he's en awesome man and itreally would be a shame. Its a shame that he has to go through this because he's an awesome guy and he didn't do nothing wrong, nothing? (pp. 67-58 - FBI). In fact, LM. spoke so highty of EPSTEIN and tier Interactions with him that the US Attorney's office Informed a federal court in July 2O08 that the US Attorney could not consider L.M. a victim. kt i f Yet, by September 24, 2009, the date on which L.M. began her deposition In her OA action and now represented by RRA and EDWARDS. L.M.'s new and very different tale about purported sexual misconduct under the supposed Influence of EPSTEIN had been thoroughly rehearsed and her role Into the ROTHSTEIN scam was complete. In her deposition In her civil action, L.M. declared that: al, I don't really care about money? (DT 208:8) 'He needs time In pa He doesn't want to be — this Is not right for him to be on the streets living daily ...\* (DT 219:21-23) °You don't think my whole fife I have hued that shifty life because of Jeffrey Epstein? (DT Z227-8) - b. In her sworn FBI testimony (pm- and RRA), L.M. was emphatic that hor interactions with Epstein lnvolvedQio inappropriate sexual touching In anyway. In fact, it was exactly the opposite: en Did he et any point kiss you, \$104, show any kind of affection towards you? A: Never, never. (p. 21— FBI) I a So he never pulled you doserto him in a sexual Way? A: I wish. No, no, never, Over, ever, no, never. Jeffrey Is an awesome man, rto. (p.. 1 - FBI) Y . Med her second amended complaint In April 2009, after }Dined RRA, eta allegations opine EPSTEIN In LM.'a complaint became even more salacious. In paragraph 12 of LM.'s Second Amended Complaint, LM, alleges among other things, that 'Jeffrey Epstein coerced, induced, or enticed . . Abe then minor. Plaintiff to commit various ads of sexual misconduct These acts Included, but were not limited to, fondling and Inappropriate and illegal sexual touching of the then minor Plaintiff, forcing or Inducing the then minor plaintiff Into oral sex or other sexual misconduct...' c. In her sworn FBI statement (pre and RRA), L.M. testified that the individual who first brought LM. to EPSTEIN's home, told LM. 'make sure you're 18 because Jeffrey doesn't want any underage girls.' (p. 8 - FBI). Yet at her September, 2009 deposition now represented by EDWARDS and RRA. L.M. told a very different story: Q: My question was what did Cmo4yn tell you to tOR Mr. Epstein ' 46 about your age? d. Pro and RRA, LM. testified to the FBI :1 always made sure — I had a fake ID, anyways saying that I was 18.° (p. 8 - Fel). %I? A: She said it didn't matter. CY. That's your recollection about whet she said? A: Yes, she said — I remember her saying it doesn't matter. Don't worry about it. (DT 199:20-25) 0 Yet, when questioned about her fake ID at her September 2009 depo, she Q And did you have a fake ID? A: No, CY: Have you ever had a fake ID? A: No. (DT 3005-8) e. In her FBI statement (pre alli end RRA), L.M. testified about others L,M. brought to the Epstein home. L.M. testified that women she brought ea EPaN's home were eager for the opportunity and content with their experiences: > kNone of my girls ever had a problem end they'd call me. Thoyd beg me, you know, for ue Xs love Jaffrey. Jeffrey tea he all thought we It ip 30 - F81). to, Jeffrey's house because they He many ts. I mean, and . This is what's so sad about girls complain about what happened after they left You asked 'meted question. No, everybody loved Jeffrey. ...4( FEll) A: Every gitt that I brought to Jeffrey, they said they were fine with lt. end like for example (EN. — another of RRA's clients in the Civil Actions), alot of olds begged me to bring them back for the money. And as far as I know, we all had tun there. (p. 45 - FBI) kt