IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN individually, J. individually, Defendant/Counter-Plaintiff. # NOTICE OF E-FILING E)ctla Plaintiff/Counter-Defendant Jeffrey Epstein, by and through his undersigned counsel and pursuant to Rule 2.516 of the Florida Rules of 'Judicial Administration, hereby files his exhibits to Plaintiff/Counter-Defendant Jeffrey Epstein's Motion for Summary Judgment on Defendant/Counter-Plaintiff Fourth Amended Counterclaim and Supporting Memorandum of Law ("Motion"), previously filed and accepted by the Palm Beach County, Florida Civil Division Filing II 5846906. The files accompanying this Notice of Filing Exhibits were previously filed on September 26, 2013 and again on October 2, 2013, but moved to Pending Queue due to procedural issues. This filing is an attempt to correct those procedural issues. The attachment hereto contains the exhibits to the above referenced Motion, which is not being re-filed contemporaneously herewith. However, the exhibits are being divided based upon the filing requirements of the rules of e-filing; each new exhibit begins when so marked on the is so marked on the bottom of the first page of said exhibit. WE HEREBY CERTIFY that a true and correct copy of the foregoing was served, via electronic service (through the e-file portal), to all parties on the attached service list, this October 3, 2013. > /s/ Ton a Haddad Colem Tonja Haddad Coleman,- Florida Bar No.: 1767 Tonja Haddad, P 5315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 (facsimile) Attorneys for Epstein # SERVICE LIST CASE NO. 502009CA040800)OOCXMBAG Jack Scarola, Esq. jsx@searcylaw.com; mep®searcylaw.com Searcy Denney Scarola Palm Beach Lakes Blvd. 404 Scarolaet al. West Palm Beach, FL 33409 Jack Goldberger, Esq. jgoldberger@agwpa.com; smahoney®agwpa.com Atterbury, Goldberger, & Weiss, PA West Palm Beach, FL 33401 250 Australian Ave. South Suite 1400 iS 4/) 9 Marc Nurik, Esq. I East Broward Blvd. Suite 700 Fort Lauderdale, FL 33301 J. Esq. abr athtojustice.com Jaffe Weissing Ed 425 N Andrews Avenue Suite 2 Fort Lauderdale, Flori 01 s Lehrman Fred Haddad,( Dee@FredHaddadLaw.com 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33301 W. Chester Jr., Esq. wcbiawtitaol.cony wcbcg@aol.com W. Chester Jr., P.A. One Clearlake Centre, Suite 1400 250 Australian Avenue South West Palm Beach, FL 33401 (con't) ? S' Tonja Haddad Coleman, Esquire\ Tonja@tonjahaddad.com; efiling@tonjahaddad.com\ Law Offices of Tonja Haddad, P.A.\ 315 SE 7th Street, Suite 301\ Fort Lauderdale, FL 33301\ Attorneys for Jeffrey Epstein NOT A CERTIFIED COPY ![](_page_4_Picture_24.jpeg) # THE FLORIDA BAR Daily News Summary An electronic digest of media coverage of interest to leaders of The Florida Bar compiled each workday by the Public Information and Bar Services Department. Distributed to Board of Governors, section and committee chairs, staff members, Florida Supreme Court justices and selected other persons. For fax/photocopies of full-text articles, contact the Public Information & Bar Services Department at 850/561-5834 or e-mail [pubinfo@flabar.org](mailto:pubinfo@flabar.org). Please visit our Web site () for links to full text of articles. Nov. 1, 2010 --Legal Profession-- **ON HER TOES--** *Florida Trend*, , Nov. 1, 2010. Not only is Pamela C. Marsh the first woman to be appointed U.S. Attorney for Florida's Northern District, she's also the district's first U.S. Attorney who's a former ballerina. Marsh says she's honored that President Barack Obama picked her to lead the U.S. Attorney's Northern District office, but she says being a woman has less impact on her approach to her job than her ballet experience. Dancing professionally for ballet companies in Seattle and Fort Worth in the mid-1980s, she says, helped her become a more dogged prosecutor. Marsh manages the district's 36 assistant U.S. attorneys and helps them focus on the department's priorities, including healthcare fraud, drug trafficking and Internet crimes against children. **STAYING ATOP THE PILE--** *Pensacola News Journal/Pensacola Business Journal*, , Oct. 31, 2010. The mountain of lawsuits piling up as a result of the BP oil spill could become the largest and most expensive collection of tort damage cases in American legal history. Billions of dollars in damages are at stake as thousands of individuals and business owners sue BP, Transocean and Halliburton. Pensacola attorney Brian Barr is one of four lawyers chosen from a national pool by U.S. District Judge Carl Barbier to guide the damage suits — all consolidated in his court — to trial. Barr's job as a member of the Plaintiffs' Steering Committee's four-person executive council will be to coordinate litigation procedures for hundreds of other lawyers representing individual plaintiffs. --Judiciary-- **JUDGE TURNER: PLEASE LET ME BACK ON THE BENCH. NO DECISION EXPECTED FOR WEEKS--** *Orlando Sentinel*, , Oct. 29, 2010. He admitted breaking campaign-finance regulations, financial-disclosure requirements and tax law, but Orange-Osceola Circuit Judge N. James Turner asked the Judicial Qualifications Commission Thursday [Oct. 28] not to throw him out of office. Turner, 64, was on trial, accused of being a bad judge. Among the many allegations was that he touched women at the Osceola County Courthouse, where he worked, as well as hugged and kissed one deputy clerk several times a day. Turner has been off work since April, when Chief Judge Belvin [REDACTED] Jr. suspended him. Testimony concluded Thursday, but there was no immediate verdict. The JQC will produce a written report and forward it to the Florida Supreme Court, which will make the final decision. **--Lawyer Ethics/Legal Discipline--SCOTT ROTHSTEIN SCANDAL: ONE YEAR LATER--** *Sun-Sentinel*, , Oct. 31, 2010.Fallout from the largest fraud in South Florida history continues after the dark secret behind Scott Rothstein's success was revealed a year ago this week. The Ponzi schemer now sits in prison with limited contact from the outside world. While Rothstein's name has been wiped from buildings and billboards, the path of financial destruction left in his wake remains. With the one-year anniversary of the scandal, questions still loom. The Florida Bar has investigated 64 complaints against 49 RRA attorneys and all but four attorneys have been cleared by the Bar of any wrongdoing. Rothstein was disbarred. **--Civil Justice Issues--JUDGE: 357 IDLE FORECLOSURE SUITS GONE IN 2 1/2 HOURS--** *The Bradenton Herald*, , Oct. 30, 2010.The foreclosure case was filed in March 2007. Within a month, all of the parties were served with copies of the suit. Then, nothing. The court case sat idle for the next 3 1/2 years, seemingly forgotten among the thousands of foreclosures clogging the legal system. That was until Thursday, when 12th Circuit Court Judge Paul E. Logan dismissed it for inactivity. In the span of 2 1/2 hours, he threw out 357 foreclosure cases because they had been inactive for at least 10 months. The purge was part of an effort to reduce the backlog of open foreclosure cases, estimated at 12,000 in Manatee County alone. The target: A 62-percent reduction, or nearly 7,500 cases, before July. **JOE FRANCIS NOT THE ISSUE IN THIS CASE--** *Walton Sun/Panama City News Herald*, column, , Oct. 30, 2010.The column by *News Herald* editor Mike Cazalas states: "There is a reason media companies — and newspapers particularly — fight so hard to protect the rights provided by the First Amendment. And whether the proceedings against 'Girls Gone [REDACTED]' founder Joe Francis in federal civil court should remain open to the public, and the media, is a much bigger issue than the case itself. . . . Now we have the current case, the one that had Freedom Communications' First Amendment and public records attorney John Bussian giving oral arguments before the 11th Circuit Court of Appeals in Atlanta last week. In that case, four women sued Francis, saying they were under 18 when they were filmed in various stages of undress. They are now in their early-to-mid-20s. But as this case moves near trial, attorneys for the plaintiffs have become desperate in their attempts to protect the women's identities. . . . Freedom Communications fought that under the basic premise that courtrooms are open forums and it is not the government's job to tell the media what to report." **TOBACCO MISTRIAL: SPLIT JURY CAN'T AGREE ON SMOKER'S ADDICTION--** *Daytona Beach News-Journal*, , Oct. 30, 2010.The case to decide the first of more than 130 local cigarette smokers' lawsuits against the tobacco industry ended in a mistrial Friday [Oct. 29], after a jury deliberated for more than 10 hours but could not break a deadlock. Seventh Circuit Judge Robert K. Rouse Jr. told the three men and three women on the jury of Koballa v. R.J. [REDACTED] Tobacco Co. that it "was the second time in 15 years" a verdict could not be reached in his courtroom. Stella Koballa, 77, of Daytona Beach smoked for more than 48 years, beginning in 1948 when she was a teenager. Koballa's attorneys said she suffered lung cancer and chronic obstructive pulmonary disease as a result of her long addiction to cigarettes. Jurors, who asked not to be identified, said they couldn't agree on the meaning of the word addiction. \*\*--Criminal Justice Issues--\*\**Florida Today*, , Oct. 30, 2010. Three years ago, Taj Mahal [REDACTED] was sent away to prison for 45 years after a jury found him guilty of attempted second-degree murder and shooting into an occupied motor vehicle. In 2004, [REDACTED] waited at a street corner in Melbourne and then shot into a vehicle occupied by his former girlfriend Anntwinnett [REDACTED] and Edmund Cochrane, according to law enforcement authorities. On Friday [Oct. 29], attorneys representing [REDACTED] at a post-conviction relief hearing granted by Judge [REDACTED] Maxwell said the two public defenders representing [REDACTED] at the time failed to interview two potential alibi witnesses and did not provide [REDACTED] proper advice regarding a plea offer. The two public defenders -- [REDACTED] Beres and Terry Locy -- who no longer work for that office, were subpoenaed to appear in court Friday. Beres said the state offered [REDACTED] a plea deal of 25 years but he advised his client to reject it, in part, because he believed Cochrane was not going to show up as a witness. Cochrane turned up at the trial and testified identifying [REDACTED] as the shooter. **SHERIFF [REDACTED] WILL LIMIT HIS HELLOS--** *Pensacola News Journal*, , Oct. 30, 2010. Escambia County Sheriff David [REDACTED] agreed Friday [Oct. 29] to a judge's request to stop greeting jury pools who assemble in the courthouse Monday mornings for jury duty. Meanwhile, at least two defense attorneys said Friday they are filing motions for retrials for their convicted clients, claiming [REDACTED] could have unduly influenced jury members. Public Defender James [REDACTED] and a group of criminal defense attorneys complained in letters to Chief Judge Terry Terrell on Thursday [Oct. 28] that [REDACTED] talks with jurors may unfairly sway them to law enforcement's side in criminal cases. For the past several months, [REDACTED] has appeared before citizens summoned to the M.C. Blanchard Judicial Building on Monday mornings to thank them for their public service. Before that, as prospective jurors board a trolley for the ride from a parking lot near the Pensacola Civic Center to the state or federal courthouse, [REDACTED] greets them, hands them a business card and thanks them for their service. [REDACTED] agreed to discontinue his greetings to jury assemblies, but Terrell declined to stop [REDACTED] from going to the trolley stop because the parking lot is a public place. **BABY SHANNON'S MOTHER RELEASED AFTER FELONY CHARGE DROPPED--** *Northwest Florida Daily News*, , Oct. 30, 2010. The case that made national headlines last year when "Baby Shannon" went missing came to a quiet end Friday for the baby's mother, as she pleaded no contest to a misdemeanor charge and was released from jail. Crystina Mercer, who was jailed for providing false information to law enforcement, was given credit for time served. Shannon Dedrick disappeared from her home Oct. 31, 2009. The ensuing five-day search for Baby Shannon was the largest operation in the history of the Washington County Sheriff's Office. The child was located Nov. 4 in a latched wooden box under the bed of her baby sitter, Susan Baker. Baker was convicted Oct. 1 after a weeklong trial on charges of aggravated child abuse, interference with custody and providing false information to law enforcement. Because the state maintains Baker stole the baby, Mercer's 911 call after Shannon's disappearance was legitimate, authorities said. Since Baker stole the baby, Mercer didn't interfere with custody. --Other-- **MONEY WOES CAN BE EARLY CLUE OF ALZHEIMER'S--** *The Gainesville Sun*, , Oct. 31, 2010. The article is by *The New York Times*. One day, it all came crashing down. The homeowners' association called asking for their fees. To Mrs. Packel's surprise, her husband had simply stopped paying them. Then she learned he had stopped writing checks to his creditors, too. It turned out that Mr. Packel was developing Alzheimer's disease and had forgotten how to handle money. New research shows that one of the first signs of impending dementia is an inability to understand money and credit, contracts and agreements. It is not just families who are affected — financial advisers and lawyers say they are finding themselves in a bind when their clients' minds seem to be slipping. For lawyers, the main question is at what point a client lacks the capacity to execute a will or other document, and who decides when that point has been reached. ______________________________________________________________________ ### © The Florida Bar - 11/1/2007 - Version 1.0.4 NOT A CERTIFIED COPY From the South Florida Business Journal \:http://vninv.blzjoumals.comlsouthflorida/print-edition/2010/10/22/rothstein.html SUBSCRIBER CONTENT: Oct 22, 2010, 6:00am EDT # A year after Rothstein, many questions unanswered Paul Brinkmann It's been a year since South Florida learned that Scott W. Rothstein was a Ponzi schemer and not just an eccentric, flashy attorney. Rothstein's victims are just starting to recover: Charities still have gaping holes in their budgets, and law firms are still pecking over the carcass of his former law firm, Rothstein Rosenfeldt Adler, in bankruptcy court. The Florida Bar found no cause to investigate 31 former RRA attorneys, and only three cases remain open. Federal authorities moved relatively quickly to indict Rothstein on Dec. 1, after a period during which he helped them bring down reputed mafia members. However, federal prosecutors have only indicted two people related to the scheme: Rothstein and his firm's COO, Debra Villecias. # Rude awakening Like a fairy tale gone bad, Rothstein's rags-to-riches story proved to be an illusion noteworthy even by South Florida standards. For four years, Rothstein grinned and glad-handed his way onto billboards and society pages. He threw money around like candy at a parade. He got a former judge, an ex-mayor and a felonious former sheriff to work for him. But, quicker than his meteoric rise, Rothstein was suddenly gone one day — to Morocco. The money was gone, too, in a \$1.2 billion Ponzi scheme. That was Oct. 27, 2009. He returned to Florida on Nov. 3. For a month, Rothstein was seen in various spots around town, apparently oblivious, promising to pay people back. people to invest in his phony lawsuit settlements. Finally, on Dec. 1, Rothstein was handcuffed and charged. At the time, Daniel Auer, IRS special agent in charge, promised: "We will continue to move forward with this investigation, wherever it leads, and we will bring to justice those who defrauded the American public and members of our community out of their hard-earned money." A year later, the government has taken its time in fulfilling that promise. Rothstein told the South Florida Sun-Sentinelin November that Fort Lauderdale was "a town full of thieves." # Federal investigation Rothstein was sentenced to 50 years in prison on June 9. Authorities charged =on April 27; she pleaded guilt ant vas sentenced Oct. 4 to 10 years. Their sentencin ud es, U.S District Judges James I. Cohn and William Zloch, noted that Rothstein and would have further sentencing reductions if they continue cooperating with authorities. John Gillies, FBI special agent in charge for Miami, summed up MI crime with these words: "She chose greed over her integrity? Cohn ruled Aug. 30 that about 300 victims were entitled to \$363 million in restitution, although only \$50 million to \$60 million is available. A select list of non-investor clients was made completely whole. At the end of October, people close to the Rothstein investigations were predicting more arrests were imminent. "For the first year, the government apparently wanted to move slowly," said William Scherer, an attorney representing investors in a \$150 million lawsuit. "It has seemed like five years' worth of news in one year." # Bankruptcy case Rothstein's law partner, Stuart Rosenfeldt, tried to put the firm into a state court receivership the day after Halloween 2009. But, several Rothstein victims soon petitioned for a bankruptcy court filing. In bankruptcy court, attorneys for trustee Herbert Stettin have sued dozens of people to recover money in civil claims. Rothstein's biggest feeder, Levin, agreed to settle claims against him by turning in assets valued at up to \$200 million. Auto dealership owner Ed Morse, another Rothstein chum, settled for \$30 million. Stettin and attorneys in the RRA bankruptcy, including Miami-based Berger Singerman, often clashed with federal authorities over the firm's assets. Cohn has granted the bankruptcy estate custody of RRA's former bank accounts, but federal authorities marshaled other assets, including boats and houses. # Investor lawsuit The Rothstein investor lawsuit could be the largest such lawsuit in Broward County history at 2,200 pages, with more than two dozen plaintiffs and two dozen defendants. The big targets are TD Bank and Gibraltar Private Bank & Trust, banks that handled Rothstein's money, but have denied knowing it was dirty. The investor lawsuit handled by Scherer is just starting to schedule depositions of key witnesses. TD Bank's attorneys have sought more time to depose witnesses and ask questions of the plaintiffs. So far, Judge Jeffrey \$treitfeld has declined to put limits on depositions. On Oct. 20, the federal Office of Thrift Supervision slapped Gibraltar with a cease and desist order for weak money laundering controls. The bank has declined to comment on whether the order is related to the Rothstein scandal, but is operating under restrictions on how it accepts deposits and compensat offic9rs. # Florida Bar takes little action The Florida Bar has taken relatively Ii tle action in response to one of the biggest crises in its history. Last November, Rothstein agreed to disbarment on consent. Bar President Jesse Diner issued a statement at the time, saying the Rothstein scandal was "a terribly unfortunate and tragic situation, but it is also a rare circumstance in the legal profession." At the time, Diner said the Bar would "continue to investigate any violations of its rules by other attorneys who may have been involved in this case." The Bar originally opened investigations into 34 former RRA attorneys. At the end of June, it announced that 21 of those cases were closed. When asked by the Business Journal for ianll ate on Oct. 19, the Bar said only three of those cases remain open: Rosenfeldt, Adler and Steven Lippman. Rosenfeldt is also fighting a \$10 million claim in the ruptcy case. Few people know where Rothstein is, except that he is supposed to be in federal prison. His name does not come up in a public website search for prisoners' names because he is still cooperating with federal investigators. Rothstein professed remorse in court, but that had little effect on his sentence. In a June 3 letter to Cohn, Rothstein wrote: "I do not really possess the words to adequately explain the magnitude of what I have done, why I did it, and the overwhelming remorse and self-loathing I feel about myself and the intense harm and pain I have inflicted upon innocent people." Whether South Floridians have changed their reaction to Rothstein-type personalities in business remains to be seen. "I think people are being more careful with flamboyant personalities, particularly charities and Investors," Scherer said. "We saw that Rothstein could buy political good will and stature. But there have always been frauds, and there will always be." pbrinkmann@bizjournals.com I (954) 949-7562 Lei is) back2 • ' ; Home ! News I 'froward I Palm Beach ! Sports I EntertainmeigA Travel t Lif Opinion ! Video I Home • Collections • Florida Bar Ads By Google ![](_page_12_Picture_7.jpeg) FIND TFARES NOW. ![](_page_12_Picture_18.jpeg) ![](_page_12_Picture_19.jpeg) # Shocking Language Video If you don't know Spanish (and you to! you should or here to see t video Watch 'deo AdChcces jetBlue Florida lariooking at 35 forme' fro stein's firm 13, 2010 I By Amy Sherman and Jay Weaver, The Miami e Florida Bar is investigating at least 35 former senior Ii headed by Scott Rothstein, who was disbarred before using the firm to run a \$1.2 billion investment racket. The Bar confirmed to The Miami Herald on Wednesday th the former firm -- Rothstein Rosenfeldt Adler — lied about and whether they stole any of it. Ads By Google # Local Breast Cancer Walk Making Strides Breast Cancer Walk, Help Saw MakingStridesWalk.org # Related Articles State Bar Investigates 4 From Rothstein Firm November 26 2009 Scott Rothstein scandal: One year later November 1, 2010 Judge Warns OI 'distressing News" In Scott Rothstein Law... November 2 2009 Were Rothstein's Associates Blinded By His 'Star Power'? November 8 2009 # Find More Stories About Florida Bar +6s Rothstein is scheduled to plead guilty Jan. 27 to federal r charges stemming from his massive Ponzi scheme, which funds. Several of Rothstein's former partners have said they wen law firm to sell bogus legal settlements to wealthy investor without mentioning names, have said that some of the las culpability." The Florida Bar board of governors and its president, Jest Rothstein in early November when word of the scandal bn pursue the probe into the other lawyers. "The Bar takes this issue very seriously,' Diner, a Fort Lat actively investigating and will puns\* remedies against an. investigation didn't stop with Scott Rothstein. "This is a terrible thing that has happened to the legal prof the profession and the public to fully investigate this thing. Diner said that Bar Investigators will first determine wheth, made any false representations to the Bar when they certi annually certify such accounts, which are used to hold CiiE memberships. He also said Bar investigators will determine whether any isappropriated money from client trust accounts -- as Rc dmitted doing when he agreed to be disbarred voluntaril) Diner said the Bar, which plays the role of a regulatory prc punishment ranging from a public reprimand to suspensio According to the federal criminal charges, Rothstein raide' firm held at Toronto Dominion Bank in Broward County. The Bar initially disclosed in November thillso Investic tall: name partners Stuart Rosenfeldt and Adler, a general counsel David Boden. Ads By Google # Anidiar & Levine Law Firm So Florida Lawyers Specializing in Personal Injury Casi southfloridainjurylaw corn/Lawyers # Dell LatitudeT" Laptop Don't Forget to Shop Scalable Dell Latitudee" Laptops' www dell com/Latitude But additional attorneys have received letters from the Bar investigation, said Howard Greitzer, a Fort Lauderdale atti Meanwhile, Rothstein appeared in federal court Wednesd who worked at his firm, has no conflicts of interest in repro his upcoming guilty plea cannot be appealed. ![](_page_14_Picture_20.jpeg) Index by Keyword | Index by Google | Privacy Policy | Terms of Service Please note the [REDACTED]-lined linked article text has been applied commercially without any involvement from our newsroom editors, reporters or any other editorial staff. **Criminal Defense Lawyer** **Aggressive Criminal Defense! Free Consultation** [www.palmbeachcountydefense.com](http://www.palmbeachcountydefense.com) **Featured Articles** ![](_page_14_Picture_27.jpeg) 10 must-see places to visit in Florida ![](_page_14_Picture_29.jpeg) Use your own iPhone Walmart's Straight unlimited plan **MORE:** | Low [REDACTED] blood cell count not always a sign of medical problem | Lift mi | | -------------------------------------------------------------------- | ------- | | Fort Lauderdale accepting Section 8 applications | Te | | How to recognize and treat a spider bite | Ar De | ![](_page_15_Picture_1.jpeg) ![](_page_15_Picture_2.jpeg) # Home Broward County Palm Beach County Weather Sports Business Entertainment Consumer Cla | Lifestyle | Food | Living | Home & Garden | Fashion | Travel | | | ----------- | ------ | -------------------------------------------- | --------------- | --------- | -------- | --- | | ----------- | ------ | -------------------------------------------- | --------------- | --------- | -------- | -- | ![](_page_15_Picture_6.jpeg) Rothstein wants some of her bling back I Main I Scott Rothstein partner Stuart Rosenfekft testifies under oath # 22 former Scott Rothstein attorneys cleared by The Florida Bar By Peter Franceschina Sun Sentinel The Florida Bar has cleared 22 former attorneys who wort Acis e Rothstein Rosenfeldt Adler law firm of any wngdoing ro during the time Ponzi schemer Scott Rothstein nning a massive \$1.4 billion fraud scheme. The Bar recently sent out letters notifying the cleared attorneys that a grievance committee found no probable cause of any wrongdoing. Fourteen other attorneys — including name partners Stuart Rosenfeldt and Adler — remain under investigation, according to Bar spokeswoman Karen Kirksey. The cases involving those 14 attorneys have not yet been heard by the grievance committee. The Bar is investigating whether any of the firm's top lawyers were involved in any trust account irregularities at the firm. Rothstein, 48, ran his fraud scheme using the now-bankrupt firm's trust accounts. Bankruptcy records show hundreds of millions of dollars flowing in and out of those accounts. According to the Bar, the cleared lawyers are: Steven L. Abrams Shawn L Birken Harold S. Bofshever Robert C. Buschel Sara Coen-Giovanelli Mark S. Fistos Scott A. Julio E Herrera Steven R. Jaffe Christina M. Kellerman Seth Michael Lehrman Arthur C. Neiwirth Steven H. Other Posted by Admin al 1.19 PM I John Michael Adam J. Steinberg Richard B. Storfer Osvaldo F. Matthew D. Weissing Johnny Jr Tami R. Wolfe Blandin J. The attorneys who have not yet had their cases heard, according to the Bar, are: Adler William J. Berger David .1. Boden Gary M. Jr. Denis A. Kleinfeld Carl H. Linder Steven N. Lippman Marc S. Nurik Michael A Pancier Carlos J. Stuart A. Rosenfeldt Grant J. Barry J. Les Stracher The Sun Sentinel obtained a copy of a Bar letter sent last of no probable cause and letter of advice to accused." c 0 0" C2he cleared C attorneys. It is titled, "Notice The letter says the attorney held himself out as a "pa ne Rosthstein Rosenfeldt Adler when only Rothstein and Rosenfeldt held equity in the firm (they were 50 percent partners), but the Bar acknowledged that the practice is customary around the country. I Os The Bar apparently heard the cases first involving attorneys who were considered "partners? and those who have not had their cases heard yet were considered "shareholders." It appears the Bar is also looking at whether some of the RRA attorneys were involved in campaign finance violations. Federal prosecutos alleged in their criminal charges against Rothstein that employees of the firm violated state and federal election law by being reimbursed for political contributions. "The Bar also became aware of allegations that lawyers at RRA may have engaged in actions that constituted violations of campaign finance law," the letter says. "It was alleged that lawyers at RRA were instructed to make political campaign contributions that were then reimbursed to the lawyer from funds at RRA." The lawyer. who received the clearance letter "denied having knowledge of any trust account irregularities before the news accounts of Mr. Rothstein fleeing the United States and thereafter being prosecuted criminally. You denied that you were ever reimbursed for making campaign contributions or that you were ever asked to do so," according to the letter. The letter goes on to caution the attorney about proper trust account procedures and to observe standards of professional conduct. POSTED IN: Scott Rothstein (109) > Discuss this entry Pennatink I Share.le es # 'COMMENTS Aw come on. isn't looking the other way a crime? Posted by: ;Th no Wryer I July 1.2010 2:19 PM Is anyone but me tired and disgusted at haveing to look at this crooks smiling face every time the Sun-Sentinel runs a story on him. Posted by: Robert I July 1, 2010 2:30 PM Free -11 Posted by 1. 2010 3:00 PM What about the suspicious employess that worked there? I heard that Andrew Barnett wasA - :t. vecl in this fiasco along with others. > 3 I July 1.2010 3:27 PM What about the suspicious employess that worked there? I heard that An c)BeCdwas involved in this fiasco along with others. Some damn fine lawyers (and former judges) are still in the4up. \\ i s like. My guess? The ones that didn't just hold themselves out as partners, but were actually partners, are still being investigated for Trust accounting violations. Too bad. But they were supposed to keep track of the accounts. Non-delegable duty, I'm afraid. It anint fair. given the custom of letting the major shartiolders do all the accounting. Practice will change as a result. Posted by: Steven I July 1.2010 3:29 PM # 8 C And how many of these newly FL Ba clean ttomeys laundered RRA money for political contributions to Charlie Crist, John McCain, et al? Need a pt? Doesn't ve a mug-shot you could use? I think the smug "f at" before shot, is best. Posted by: Walt-A-Minute I July 1, 2010 4.27 PM Posted by: And What About I July I, 20106:10 PM Posted by: Cheese I July 1, 2010 6:44 PM What a joke the Bar is you saps. Its a country club for lawyers. Do you really think they're going to revoke somebody's membership in the club for committing a crime? They're slapping each other on the back laughing at the farce they just pulled off... Posted by andrew leaffnonth I July 1, 2010 9:26 PM Not sure what all the fuss is about. 99 per cent of the firm had no clue about any wrongdoing and there was no reason to believe so. Posted by: roe huckster I July 2.2010 12:13 AM Shawn Birken? Judge Birken's son? That Gears up the mystery why an incompetent like Judge Birken's wife, Barbara McCarthy was appointed to the benh by Charlie. Posted by: Sian I July 2. 2010 8:10 AM What about Pedro Dijols?????? Posted by: Grob I July 2.2010 8:35 NA The bar giving press releases involving attorneys under investigation is their attempt to look like the knight riding in on his big horse to save the poor public from thse cretins leave it to a group headed by Jesse Diner to be full of itself. Posted 2010 8:38 AM lsnt not getting back to clients about their case make clients wonder if the attorney are really innocent or guilty? The Florida Bar is a criminal enterprise. And no one can reign them in, until they go away. st thing to do is ignore them Posted by. LILLY I J\*2. 2010 2:17 PM Posted by. Dumbfounded i July 4. 2010 1:23 AM Nice, So I wonder how much the Fla Bar was paid to clear 4Fssi names. You can't tell me that they knew "NOTHING" about a major scheme that was happenin Witicryery office. Unbelieveable.. I ## POST A COMMENT Name: Email Address: URL: ltri Remember 7 Comments: HTML tags for style) To help keep MI off our site, please enter the letter "q" In the field below: Posted by: Not surprised I July Is. 201011:51 AM [Preview](#) [Post](#) NOT A CERTIFIED COPY ![](_page_20_Picture_147.jpeg) Rothstein Rosenfelt Adler\ Attorneys at Law [REDACTED] J. [REDACTED]\ Direct Dial: 954-315-7266\ bedwards@ma-law.com July 22, 2009 **Via Facsimile:** 305-931-0877 Adam D. Horowitz, Esquire\ Stuart S. Mermelstein, Esquire\ 561-832-7137 Isidro Manuel [REDACTED], Esquire\ 305-931-0877 Jeffrey Marc Herman, Esquire\ 305-358-2382 Katherine Earthen Ezell, Esquire\ Robert C. Josefsberg, Esquire\ 561-684-5707 Jack [REDACTED], Esquire Dear Counsel, We have recently received Notice for Depositions from Adam Horowitz for several witnesses and the lever from Jack Hill indicating an intent to take others. We intend to Cross-Notice each deposition. Additionally, we intend to set the following other individuals for video deposition: 1. 1. Donald Trump (West Palm Beach) 1. 2. Glen [REDACTED] (West Palm Beach) 1. 3. Ghislain Maxwell (New York) 1. 4. Sara [REDACTED] (New York) 1. 5. Leslie Wexner (Ohio) 1. 6. Bill Clinton (D.C.) 1. 7. Paula-Heil.-(New York) 1. 8. Jean-Luc Bruhel (New York) | Δ π EXHIBIT 3 | | | -------------------- | -------------------------- | | Deponent | Melanda [Signature] | | Date | 3/23/16 | | Rptr. | Ct | | DEPOSITOR | | #3 July 22, 2009 Page 2 of 3 We will choose dates that have not already been occupied by other depositions already set in this case. If you would like to be included in the scheduling of these depositions, please provide me with your scheduling secretaries' names and e-mail addresses. If any of you do not need to be consulted regarding the scheduling of these depositions, please advise me of that as wells. Very truly yours, ROTHSTEIN ROSENFELDT ADLER J. Esquire Fort the Firm cos 4s) Partner BJE/mgl # UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV —MARRP JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant COS 649 # NOTICE OF TAKING VIDEO DEPOSITION PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of Leslie Wexler on Friday, August 14, 2009, at 11:00 a.m., at: McGinnis & Associates 5701 North High Street Suite 300 Worthington, El 0e085 (614)431344 The depre)tion 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 ei day of July, 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: bedwardserra-law.com BRAD, ESQ. Florida Bar No.: 542075 cc: US Legal Support Court Reporters 6 \*) WE HEREBY CERTIFY that a copy of the foregoing was mailed this,19th day of July, 2009, to: Via regular mail and fax to: Robert D. Critton, Jr., Esquire 515 N. Flagler Drive, Suite 400 West Palm Beach, Florida 33401 561-488-6929 fax rcrit@bc1claw.com Via email to: Jack =. inh@searcvlaw.com Isidro Manuel= isidrogarcia@bellsouth.net Katherine Warthen Ezell Kezell(throdhurst.com Michael James Pike I'vfoike@bc1claw.com Paul G. Caccell cassellp@law.utah.edu Richard Horace Willi lawverwillits@aol.co Robert C. Josefsberg riosefsberagpodhurst, con Stuart S. Meunelstein ssmasmutbuseattomev.com Adam D. Horowitz aborowitz@sexabuseattomev.com ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33394 Telephone (954) 522-3456 Telecopier (954) 527-8663 By: Florida Bar No. 542075 [bedwards@rra-law.com](mailto:bedwards@rra-law.com) William J. Berger Florida Bar No. 197701 [wberger@rra-law.com](mailto:wberger@rra-law.com) NOT A CERTIFIED COPY # UNITED STATES DISTRICT COURT for the Southern District of Florida JANE DOE ) Plaintiff v. JEFFREY EPSTEIN Defendant Civil Action No. 08-80893CIV-MARRA/JOHNSO Of the action is pending in another district, state where: To: Leslie H. Wexler, One Whitebam Road, New Albany, Ohio 43054 Testimony: YOU ARE COMMANDED to appear at the time, date, and ply set)forth below to beatify at a deposition to be taken in this civil action. If you are an organization that is it in this case, you must designate one or more officers, directors, or managing agents, or designate other t consent to testify on your behalf about the following matters, or those set forth in an attachment # SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTIOb Place: McGinnis & Associates 5701 North High Street, Suite 300 H4 85 The deposition will be recorded by this O Production: You, or your representatives, also bring with you to the deposition the following documents, electronically stored information(ofi obje,a,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: 1/2.7 / q I CLERK OF COURT OR te, SYgnanwe of Clerk or Deputy Clerk Attorney's signature The name, address, e-mail, and telephone number of the attorney representing (naMC of party), who issues or requests this subpoena, are: Brad.. Esq., ROTHSTEIN ROSENFELDT ADLER, Attorneys or Plaintiff, 401 East Las Olas Blvd., Suite 1650, Fort Lauderdale, Florida 33301, bedwards@rra-law.com (V.54,-) 52.7\_ scits' Civil Action No. 08-80893CIV-MARRALJOHNSO ### PROOF OF SERVICE (This section should not be filed with the court unless required by Pet R. Civ. P. 45.) This subpoena for (name of individual and title, ifanY) was received by me on (date) O I personally served the subpoena on the individual at (place) OR (date) or O I left the subpoena at the individual's residence or usual place of abode with oulaisic, a person of suitable age and discretion who resides there, 011 (dale), and mailed a copy to the individual's last known address; or O I served the subpoena on frame ofindatdva0 , who is designated by law to accept service of process on behalf of frame O I returned the subpoena tmexecuted because ; or CI Other (spectfri 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 S for travel and S for services, fora tend of S 0.00 Date: I declare under paof perjury that this infoxmation is true. Server's signature Printed name and title Saver's address Additional information regarding attempted service. etc: JANE DOE, Plaintiff, vs. # UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV -MARRA/JOHNSON JEFFREY EPSTEIN, Defendant. # NOTICE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of Ghislane Noelle Maxwell on MgndaL August 17, 2009, at 11:00 a.m., at: Esquire Court Repot One Penn Plaza State 4715 New York, NY 10119 The depoaltichall be conducted pursuant to the Florida Rules of Civil Procedure and shall day to day, weekends and holidays excepted, until completed. 1 BY CERTIFY that a true and correct copy of the foregoing has been served by U.S. Mail and email transmission this 2: day of July, 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: bedwardsnrra-law.com By: cc: US Legal Support Court Reporters ESQ. rida Bar : 2075 # UNITED STATES DISTRICT COURT for the Southern District of Florida JANE DOE Plaintiff Y. JEFFREY EPSTEIN Defendant ### SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTI To: GHISLANE NOELLE MAXWELL, 116 E. 65 LLC, NEW YORK Civil Action No. 08-60893CIV-MARRAJJOHNSO (if the action is pending in another diatectItate where: / C fir Testimony: YOU ARE COMMANDED to appear at the time, date, and place set)f.orth below to testify at a deposition to be taken in this civil action. If you are an organization that is t a in this case, you must designate • one or more officers, directors, or managing agents, or designate other PS wr nsent to testify on your behalf about the following matters, or those set forth in an attachment: Place: Esquire Court Reporters One Pem Plaza, Suite 4715,New York, NY 10119 I Date and Time: 08/17/2009 11:00 am The deposition will be recorded by this method: 0 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: 5/2 7/6? CLERK OF COURT Signature of Clerk or Deputy Clerk OR Attorney's signature The name, address, e-mail, and telephone number of the attorney representing (name of party), who issues or requests this subpoena, are: BraaWsq., ROTHSTEIN ROSENFELDT ADLER, Attorneys or Plaintiff, 401 East Las Olas Blvd., Suite 1650, Fort Lauderdale, Florida 33301, bedwards©rra-law.com /9.55.9 S 2.7- 3 StC Civil Action No. 08-80893CIV-MARRAMOHNSO ### PROOF OF SERVICE (This section should not be filed with the court unless required by Fed. K Clv. P. 45.) This subpoena for (name of indiridual and title, V any) was received by me on (date) O I personally served the subpoena on the individual at (place) On (date) Or Otte the subpoena at the individual's residence or usual place of abode with orrissc on (dale), a person of suitable age and discretion who resides there, , and mailed a copy to the individual's last known address; or O I served the subpoena on (name of individual), who is designated by law to accept service of process on behalf of (awn or 0 I returned the subpoena unexecuted because or O Other (speeifit): 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 S for services, for a total of S 0.00 Date: I declare under ptm of perjury that this information is true. Saner 's signature Printed name and tide Server's address Additional information regarding attempted service, etc: # UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV --MARRA/ JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. # NOTICE OF TAKING VIDE T 'SeEPOSITION PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of Glenn on Tuesday, August 18, 2009, at 11:00 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 2-8 day of July, 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@rra-law.com](mailto:bedwards@rra-law.com) By: ![](<>)![](<>)Florida Bar No.: 542075 cc: US Legal Support\ Court Reporters NOTA CERTIFIED # UNITED STATES DISTRICT COURT for the Southern District of Florida JANE DOE Plainfiff Civil Action No. 08.80893CIV-MARRA/JOHNSO JEFFREY EPSTEIN Defendant To: Glenn M, 1010 5th Avenue, Unit WA, New York, NY 10028 # SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION I Testimony: YOU ARE COMMANDED to appear et the time, date, and pl Cedforth below to testify at a deposition to be taken in this civil action. If you are an organization that is I a y in this case, you must designate one or more officers, directors, or managing agents, or designate other pe whconsent to testify on your behalf about the following matters, or those set forth in an attachment (If the action is pending in another district. Amc where: Place: Esquire Court Reporters te'and Time: One Penn Plaza, Suite 4715,New York, NY 10119,#' 08/18/200911:00 am The deposition will be recorded by this method: CI 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 toe subpoena, and Rule 45 (d) and (e), relating to your duty to iwvund to this subpoena and the potential consequences of not doing so, are attached. Date: 7 / 2 7 /07 CLERIC OF COURT Signature of Clerk or Deputy Oak OR Attorney's signature The name, address, e-mail, and telephone number of the attorney representing (name ofparty), who issues or requests this subpoena, arc: Brad Esq., ROTHSTEIN ROSENFELDT ADLER . Attorneys or Plaintiff, 401 East Las Otos Blvd., Suite 1650, Fort Lauderdale, Florida 33301, bedwerds@rra-law.com (9sti) .52- a Z44-5-6 Civil Action No. 08-80893CIV-MARFtA/JOHNSO ### PROOF OF SERVICE (This section should not bellied with the court unless required by Fed. R. Civ. P. 45.) This subpoena for (name ofindividual and title. Vary) was received by me on (dare) O I personally served the subpoena on the individual at (place) on (date) or O i left the subpoena at the individual's residence or usual place of abode with (swee\_\<, , a person of suitable age and discretion who resides thcrc, on (date), and mailed a copy to the individual's last known address; or Cl I served the subpoena on (name of individual) designated by law to accept service of process on behalf of f ; 01 , who is O I returned the subpoena unexecuted because ; or O 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 S My fees are S travel and S for services, for a total of \$ 0.00 Date: Servers signature I declare under of perjury that this information is true. Additional information regarding attempted service, etc: Printed name and ads Server's address # UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-80893CIV —MARRA/. JANE DOE, • Plaintiff, vs. JEFFREY EPSTEIN, Defendant. # Re-NOTICE OF TAKING VIDEOT PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of Donald Trump on, August 18, 2009, at 11:00 a.m., at iS amj\* Cos Esquire Court Reporters One Penn Plaza Suits 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. Mali and email transmission this Ziaday of August, 2009 to all those on the attached Service List. ROTHSTEIN [REDACTED] FELDT 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 ## 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 Nov 1 '09\ AUG 09\ Nov 09\ Aug 09 Nov 09\ Aug 09\ Nov 09\ Aug 09 Nov 09\ Aug 09\ Nov 09\ Aug 09 Nov 09\ Aug 09\ Nov 09\ Aug 09 Nov 09\ Aug 09\ Nov 09\ Aug 09 NOT A CERTIFIED COPY # UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV -MARRA JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. # NOTICE OF TAKING VII3E01APASTIEPOSITION • :71( • PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of on Thursday, September 3, 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 Pnctcedure and shall continue day to day, weekends and holidays excepted, until completed. • 1 I HERESY CERTIFY that a true and correct copy of the foregoing has been served by U.S. Mail and email transmission this Ri\)BRAD [REDACTED], ESQ. Florida Bar No.: 542075 cc: Esquire Court Reporters NOTA CERTIFIED # UNITED STATES DISTRICT COURT for the Southern District of Florida JANE DOE Ploini(ff v. JEFFREY EPSTEIN Defendant Civil Action No. 08-90893CIV-MARRAMOHNSO (lithe action is pending in another district, stater what: ### SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION To: Mark Epstein, 301 E. 66th Street, New York, NY iir Testimony: YOU ARE COMMANDED to appear at the time, date, and place rth below to testify at a deposition to be taken in this civil action. If you are an organization that is non 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: Asc.) Place: Esquire Court Reporters, One Penn Plaza Suite 4715, New York, NY The deposition will be recorded by this Alc4and Time: 09/21/2009 11:00 am 0 Production: You, or your representatives, must also bring with you to the deposition the following documents, electronically stored information, ¶Fobjecltsarnd 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, arc attached. Datc: CLERK OF COURT OR Simonise of Clerk a Deputy Clerk Attorney's signature The name, address, e-mail, and telephone number of the attorney representing (non ofpony) , who issues or requests this subpoena, are: Brad, Esq., Rothstein Rosenteldt Adler, 401 E. Las Olas Blvd., Suite 1650, Fort Lauderdale, Florida 33301 s rra-law.com. (954) 522 2346 Civil Action No. 08-90893CIV-MARRNJOHNSO ### PROOF OF SERVICE (This section should not be filed with the court unless required by Fed. R. Lb. P. 45.) This subpoena for (name of Individual and lisle, jam') was received by me on (date) O I personally served the subpoena on the individual at (place) on (date) Cl I left the subpoena at the individual's residence or usual place of abode with (name, a person of suitable age and, non ho resides there, on (date), and mailed a copy to the individual's last known address; or O I served the subpoena on (name of individual) designated by law to accept service of process on behalf of (name, who is ; or O I returned the subpoena unexecuted because ; or O Other (spec(&): ( S 4 Unless the subpoena was issued on behar0f )tiled States, or one of its officers or agents, I have also tendered to the witness fees for one day% 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 Date: Server's signature I declare under penalty of perjury that this information is true. Additional information regarding attempted service, etc: Printed name and tide Server's address ## 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 lost 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 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 secret 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 subpoenaed 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 subpoenaed 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 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). # UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV —MARRA/.. JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. # NOTICE OF TAKING VIDE9e8D "ClDEPOSITION 0 PLEASE TAKE NOTICE that the Plain, JANE DOE, will take the deposition of Jean Luc Bruhel on Tuesday, September 22, 2009, at 10:00 a.m., at: Esquire Court Reporters One Penn Plaza 14.) / Suite 4715 New York, NY 10.119, 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 ICE t CERTIFY that a true and correct copy of the foregoing has been served by U.S. Mail and email transmission this /(k -day of August, 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 33361- Tel: (954) 522-3456 Fax (954) 527-8663 Email: bedward -.41:t AD, ESQ. \\Merida Bar No.: 542075 cc: Esquire Court %ponies # UNITED STATES DISTRICT COURT for the Southern District of Florida JANE DOE Plaintiff v. JEFFREY EPSTEIN Defendant Civil Action No. 08-90893CIV-MARRA/JOHNSO (IT the action is pending in another district, state where: ### SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACTION 0 I C ) 1 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 arc an organization that is t a party in this case, you must designate one or more officers, directors, or managing agents, or designate other p ho consent to testify on your behalf about the following matters, or those set forth in an attachment: rPlace: Esquire Court Reporters. One Penn Plaza and Time: To: Jean Luc Bruhel, 301 E. 66th Street, New York, NY Suite 4715, New York, NY The deposition will be recorded by this ma: 09/22/2009 10:00 am n 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: CLERK OF COURT OR Sismondi of Clerk or Deputy Gent Attorney's signature The name, address, e-mail, and telephone number of the attorney representing (name of party) , who issues or requests this subpoena, are: Brad Esq.. Rothstein Rosenfeld( Adler, 401 E. Las Olas Blvd., Suite 1650, Fort Lauderdale, Florida 33301 Bed rra-law.tsxn. (954) 522 2346 Civil Action No. 08-90893CIV-MARRNJOHNSO ### PROOF OF SERVICE (This section should not be filed with the court unless required by Fed. R. ay. P. 45.) This subpoena for (name of individual and role, af an)) was received by me on (dare) O I personally served the subpoena on the individual at (place) on (date) CP I left the subpoena at the individual's residence or usual place of abode with (name) on (date) a person of suitable age and discretion who resides there, , and mailed a copy to the individual's last dNISII)or O I served the subpoena on (name of individual) designated by law to accept service of process on behalf of (name of organisation) on (date) O I returned the subpoena =executed because O Other (rpecifr): ;or, who is ;Of 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 S for travel and S for services. for a total of \$ 0.00 Date: I declare under penalty of perjury that this information is true. Server's signature Printed name and tide Server's address 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 lost 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 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 secret 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 subpoenaed 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 subpoenaed 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 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). # UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV —MARRa JANE DOE, Plaintiff. vs. JEFFREY EPSTEIN, Defendant # / a\\ Re - NOTICE OF TAKING VIDEOTAPED DEPOSITION Cos PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the depositioh of .Ghislane Noelle Maxwell on Wednesday, September 23, 2009, at 10:00 a.m., at Esquire Court Reporters One Penn Plaza Suite 4715 New York, NY 101111 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 ///%ay of August, 2009 to all those on the attached Service List. aw Sequin Cart Reporters 6)\* ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff 401 East Las Olas Blvd., Suite 1850 Fort Lauderdale, Florida 33301 Tel: (954) 522-3456 Fax (954) 527-8863 Email: bedward By: BRAD EDWARDS, ESQ. Florida Bar No.: 542075 ## Service List **09-22785** Robert D. Critton, Jr., Esq.\ BURMAN, CRITTON, BT 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 Nov 1 2008\ Part 1\ Part 2\ Part 3\ Part 4 12/26/08\ Apr 1 2008\ H Cons.\ Atte 250\ Jacksonville 12/27/08\ Jacksonville\ Atterbury\ Atterbury\ Atte 250\ Cons. Part 2 12/28/08\ Apr 1 2008\ H Cons.\ Atterbury\ Atte 250 12/28/08\ Apr 1 2008\ H Cons.\ Atterbury\ Atte 250 NON-CERTIFIED COPY # UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.08-80693CIV-MARR.A JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, ,O4hic / C Defendant. O # Re-NOTICE OF TAKING VIDEOTAPED DEPOSIT/OR PLEASE TAKE NOTICE that the Plaintiff, JANE DOE, will take the deposition of Donald Trump on, September 24, 2009, at 11:00 a.m., at: One Penn Plaza Esquire Court Reporters (S\\ New York, NY 10119 4S 4.1e1 Suite 4715 The deposition shall be con ucted 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. Mall and email transmission this at day of August, 2009 to all those on the attached Service List. ROTHSTEIN ROSENFELDT ADLER Attorneys for Plaintiff 401 East Las Olas Blvd., Sulte 1650 Fort Lauderdale, Florida 33301 Tel: (954) 522-3456 Fax (954) 527-8663 Email: bedwards@rra-law.com B BRAD, ESQ. Florida Bar 2075 co: Esquire Court Reports 'S )'49 # UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 08-CIV —MARRa JANE DOE, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. # Re- NOTICE OF TAKING VIDEOTAPED DEPOSITION PLEASE TAKE NOTICE that the Plaint E DOE, will take the deposition of on October 19, 2009, kiti00d.m., at: Q 14/ ) 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 HEFb3E3Y CERTIFY that a true and correct copy of the foregoing has been served by U.S. lAvIrnd 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: bedwardsftfra-law By: 6)\*. B Florida BM.No.: 542075 ESQ. cc Egg\*\* 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 # :UNITED.STATES•DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASENO:.08-Ch/LMARFta JANE DOE, Plaintiff, JEFFREY EPSTEIN, Defendant. # Re- NOTICE AKING i S ON PLEASE TAKE NOTICE that the E DOE; will take tie deposition of on October 20, . at .00 aan., at .EsquIre Court Reports • • .One Penn Plaza Suite 4715 • . • New York; NY 1,0119 The depos and shall co conducted pursuant to the Federal Rules of Civil Procedure to day, weekends and holidays excepted, until completed. sh CERTIFYthat a true and correct copy of the foregoing has been served by U.S. I and emallttansmissionthls & 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 .‹-tc .1/". By: J BRAD EDWARDS, ESQ. .Flo • a Bar No.: 542075 UNITED STATES DISTRICT COURT\ SOUTHERN DISTRICT OF FLORIDA\ CASE NO. 08-CIV -MARRA/JOHNSON *Plaintiff*\ 2 JANE DOE, vs. Plaintiff, 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. *served to e-mail\ e-DT, 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 ![](<>)ESQ. Florida Bar No.: 542075 cc: Esquire Court Reporters NOTA CERTIFIED **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**\ **[isidrogarcia@bellsouth.net](mailto:isidrogarcia@bellsouth.net)** **Jack**\ **[iph@searcylaw.com](mailto:iph@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)** please\ 2 # UNITED STATES DISTRICT COURT for the\ Southern District of New York Jane Doe Plaintiff v. Jeffrey Epstein Defendant Civil Action No. 08-80693 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 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 Ped. 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 *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 Brad [REDACTED], Esq., Rothstein Rosenfeldt Adier, 401 E. Las Olas Blvd., Suite 1650, Fort Lauderdale, Florida 33301\ Bedwards@ma-law.com. (954) 522 2346 do f e vr 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: \_\_\_\_\_\ \_\_\_\_\_\ Server's signature \_\_\_\_\_\ Printed name and title \_\_\_\_\_\ Server's address 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 lost 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 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 secret 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 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 scal 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). # Schedule "A" to the Subpoena Ducos recu m of Ghlslane Maxwell A list of a girls that Defendant, Epstein, had at his house at 358 El BriIto 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 Al girls 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. Anv and all documents that reflect scheduling and/or appointments for Epsteln's flights, travels, accommodation, massages or meetings for the entire duration when you worked with or for Jeffrey Epstein. A complete list of all girls whom you know to have flown in any of Defendant, Epstein's airplanes or jets at anytime during the time you worked with or for Jeffrey Epstein. 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. C4\* O # UNITED STATES DISTRICT COURT for the\ Southern District of New York Jane Doe Plaintiff y. 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 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 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 Adler, 401 E. Las Olas Blvd., Suite 1650, Fort Lauderdale, Florida 33301\ Bedwards@rra-law.com. (954) 522 2346 10.DL\ no # UNITED STATES DISTRICT COURT for the Central District of California Jane Doe Plaintiff v. Jeffrey Epstein I Defendant ) ### SUBPOENA TO TESTIFY AT A DEPOSITION Oft TO PRODUCE DOCUMENTS IN A CIVIL ACM,() Civil Action No. 08-90893CIV-MARRA/J0HNSO (If the action is pending in another district, state where: Southern District of Flom Michael Freidman, 53320 Avenida Madero. La Quinta, CA 92253 d Testimony: YOU ARE COMMANDED to appear at the time, date, and pl c se2forth 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: IPlace: Farewell Court Fcmprtera 50505 Spyglass El Dr, La Quinta, CA AS Sled Time: 11/19/2009 10:00 The deposition will be recorded by this method: Reporter 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. R. Civ. P. 45(c), relating to your protection as a person subject to a subpoena, and Rule (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 err Signature of Clerk or Deputy Clerk OR Attorney signature The name, address, e-mail, and telephone number of the attorney representing (name ofpony) Jane Doe LErrad 954 5 r, Suite 1650, 401 E. Las Olas Blvd. Fort Lauderdale, FL 33301. , who issues or requests this subpoena, are: To: Rosalie Freidman, 53320 Avenida Madero, La Quinta, CA 92253 ref Testimony: YOU ARE COMMANDED to appear at the time, date, and p deposition to be taken in this civil action. If you am an organization that is qor one or more officers, directors, or managing agents, or designate other p about the following matters, or those set forth iu an attachment: sistlorth below to testify at a in this case, you must designate consent to testify on your behalf \[Place: Farewell Court -H rters 50505 Spyglass IN Dr, La Quinta, CA The deposition will be recorded by this method: Ct3br1 Reporter nd Time: 11/19/20O9 10:00 # UNITED STATES DISTRICT COURT for the Central District of California \_ Jane Doe Plaintiff v . Jeffrey Epstein Defendaa Civil Action No. 08-80893CIV-MARRNJOHNSO (If the action is pending iu another disbiet, Ste where: Southern District of Florisitta.,,II ### SUBPOENA TO TESTIFY AT A DEPOSITION OR TO PRODUCE DOCUMENTS IN A CIVIL ACI1OO CI Production; You, or your representatives, must also bring with you to the deposition the following documents, electronically stored information, of 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 asa 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: 10/2 Met CLERK OF COURT OR Signotstre of Clerk or Deputy Clerk Attorney's signature The name, address, e-mail, and telephone number of the attorney representing (name of pony) Jane Doe , who issues or requests this subpoena, arc: Bil:111F R—.othsteln Rosenfeldt Adler, Suite 1650, 401 E. Las Olas Blvd. Fort leaden:ate, FL 33301. 954 5 . Bedwards C RRA-law.com. **UNITED STATES DISTRICT COURT**\ for the\ Central District of California Jane Doe *Plaintiff* v. Jeffrey Epstein *Defendant* Civil Action No. 08-80893CIV-MARRA/JOHNSO (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: 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] Rothstein Rosenfeldt Adler, Suite 1650, 401 E. Las Olas Blvd. Fort Lauderdale, FL 33301, 954 522 3456, Bedwards@RRA-law.com. **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 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, capting, 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) Queshing or Modifying a Subpoena.** **(A) When Required.** On timely motion, the issuing court must quest 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, quest or modify the subpoena if it requires: (i) disclosing a trade secret or other confidential research, development, or commercial information; (ii) disclosing an unrelated 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 queshing 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 subpoenaed 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 subpoenaed 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 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. 06-80893CIV-MARRA/JOHNSO **PROOF OF SERVICE** *(This section should not be filed 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 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 (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: \_\_\_\_\_\ \_\_\_\_\_\ Server's signature \_\_\_\_\_\ Printed name and title \_\_\_\_\_\ Server's address Additional information regarding attempted service, etc: ### IN THE CIRCUIT COURT or THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFIthitEPfftell4, Complex Litigation, Ha. R. Civ. Pro. 1.201 CASE NO. v. Plaintiff, 0 ROTHSTEI J. Individually, and n t dua y, Defendants. 50 2009 CA 0 h 0390MM I # COMPLAINT Plaintiff. JEFFREY EPSTEIN, (hereinafter \*EPSTEIN\*), by and through his undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN, Individually, J. EDWARDS, Individually, and L.M., Individually. Accordingly, EPSTEIN states: COPY RECEIVED FOR FILING DC G # SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeld', 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\\ brchestmtion 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; Rothstoin 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-existent Epstein sottiements and the sanctioning of a series of depositions that were unrelated to any principled litigation purpose but instead designed to discover extraneous private information about Epstein or hie personal and business associates (including well-known public figures) In order to defraud investors and support extortionate de payment from Epstein. The misconduct featured the filing of legal motions and the pursuit of a civil litigation strategy that was unrelated to the merits or value oitheir clients' cases and, instead, had as its improper purpose the furthering of Rothstein's misrepresentations and deceit to third party Investors. As a result, Epstein was subject to abusive investigatory tactics, unprincipled media attacks, and unsupportable legal filings. This lawsuit is filed and will be vigorously pursued against ail these defendants. The Rothstein racketeering enterprise endeavored ti.kienairomlso the corn values of both state and federal Justice systems in South Florida and to vindicate the hardworking and honest lawyers and their clients who were adversely affected by the misconduct that is the subject of this Complaint. Plaintiff reserves the right to add additional defendants — co-conspirators as the ta4and evidence is developed. # GENERAL ALLEGATONS - 1. This 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 Beach County, Florida. 1. Defendant, SCOTT ROTHSTEIN (\*ROTHSTEIN"), is an individual residing In Broward County, Florida, and was licensed to practice law in the State of Florida. In November 2009, ROTHSTEIN voluntarily relinquished his taw license in the midst of the implosion of Rothstein, Rosenfeld( and Adler, P.A. ("RRA"). s disbarred by the Florida Supreme Court on November 20, 2009. On Det 1. 2009, ROTHSTEIN was arrested and arraigned In Federal Court h Browazi Cou, Florida. 1. At all times relevant hereto, ROTHSTEIN was the managing partner and CEO of RR& 4-: SC 1. Defendant, ROTHSTEIN end 'Stuart Rosenteldt. are and were the principal owners of equity in RRA and each RRA. 1. Defendant, NEM. ED ARDS el is an individual residing in Broward County, Florida and Is licensed to practice law in the State of Florida. At all times relevant hereto, was an employee, agent, associate, partner, shareholder- Or other representative of RRA. 1. Dife410 L.M. ("L.M."), is an individual residing in Palm Beach County, Florida. At all times relevant hereto, L.M. was represented by RRA, ROTHSTEIN and EDWARDS in a civil lawsuit against Epstein and was an essential participant in the scheme referenced inks by, among ether things, substantially changing prior sworn testimony, so as to assist the Defendants in promoting their fraudulent scheme for the promise of a multi-million dollar recovery relative to the Civil Actions (defined below) Irwolving Epstein, which was completely out of proportion to her alleged damages. 1. Non-party, RRA is a Florida Professional Service Corporation, with rincipal address of 401 East Las Olas Blvd., Suite 1650, Fort Lauderdale, FL Mon to Its principal office, RRA also maintained seven offices In Florida, New York, and Venozuefa, and employed over 70 attorneys and 200 support staff. RRA also maintains en office at 1109 NE 2d Street, Hallandale Beach, Florida 33009-8515. RRA, through Its attorneys, Including those named as Defendants herein, conducted business throughout Florida, and relevant to this actionoeducted business and tiled lawsuits on behalf of clients In Palm Beach County, Florida. (RRA is currently a debtor In bankruptcy. RRA is not named as a Defendant). ### FACt ALLEGATIONs 9. The United States in Uniteditates of America v. Scott W. Rothstein Case No. 09-60331CR-Cohn, United States District Court. Southern District of Florida, has brought an action for Racketeering Conspiracy, 18 U.S.C. § 1962(d) against Scott W. Rothstein tetras the chief executive officer and chairman of Within the Informatternwhich was filed, the United States of America has identified the enterprise as being the law firm, RRA, through which Rothstein in conjunction with "his co-00f1 tors" (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 Ponzi scheme. The USA further alleges that 'Rothstein and co-conspirators initiated the criminal conduct alleged In the Instant Information in order to personally enrich themselves and to supplement the Income and sustain the daily operation of RRA.' in essence, in the absence of Rothstein and his coconspirators conducting the Pond scheme, the daily operation of RRA, which Included payroll (compensation to lawyers, staff, investigators, et accounts payable Including unlimited Improper, harassing and potential illegal investigation on cases, including Epstein-related matters, would in all likelihood would not have been sustainable. A copy of the Information is attached as Exhibit 1 to this action. 10. As more fully set forth herein, RRA held itself out as legitimately and properly engaging In the practice of law in relay, ROTHSTEIN and others in RRA were using RRA to market Investments, as d bed 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 assignments of a structured pay-out settlements, supposediy reached on behalf of RRA for clients, in exchange for immediate payments to these clients of a discounted lump sum amount Investors wore being promised in excess of a 30% return on their Investment which was to be paid out to the investors over time. 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) prat) conferences and releases and the Information the massive Portz! scheme and pa t of criminal activity meant to lure Investors began sometime In 2005 and continueitth h the fall of 2009, when the scheme was uncovered by some of the investors and the FBI. As of November of 2009, civil lawsuits were and continue to be filed against various Defendants as result of their massive fraudulent and criminal scheme. 01. This fraudulent and Illegal Investment scheme la also evidenced by the filing of Amended Complaint For Dissolution And For Emenjertekpansfer of Corporate Powers to Stuart A. Rosenfeld!, Or, In The Attemetiv the Appointment of A Custodian or Receiver by ROSENFELDT, and RRA, against ROTHSTEIN, Individually. (Case No. 09 059301, In the Circuit Court of the Seventeenth Judicial Circuit, Bruward County, Florida, Complex Business Div.), (hereinafter 'RRA dissolution action, and attached hereto as Exhibit 2). i i r 01. Plaintiff references the RRA dissolution action for the sole purpose that tt acknowledges that and ROTHSTEIN were in fact conducting an illegal and I improper inv ent 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 part that - 'ROTHSTEIN, 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 \[ i 1 1 I i interests in structured settlements.- See Prelinunaty Statement of RRA dissolution action, Exhibit 2 hereto. 14. In furtherance of the scheme, RRA's letterhead was used in conwrications regarding Investment opportunities in purported structured settlements. RBA's trust account was used to deposit hundreds of millions of dollars or wire transfer of monies from duped Investors and othervictims, RRA personally guaranteed payments. 01. Rothstein's scheme went so far as to manufacture false and fraudulent Court opinions/orders Inducting forging the signatures of U.S. District Judge, Kenneth A. Marra and U.S. Circuit Court Judge, Susan yet known if he forged similar documents In Exhibit 3 hereto, 1 t hCircuit in other cases. It is not related matters. See Composite 01. Thu details of this fraudulent scheme are being revealed on a daily basis through various media reports and court documents. The most recent estimate of the financial scope of the scheme is thrikez4eeds \$1.2 billion dollars. 01. Relevant to this at-lion, EPSTEIN is currently named as a defendant In three civil actions alleging, Inter ails, sexual assault and battery that were handled by RRA and Its attorneys Including EDWARDS prior to its Implosion - one of which is fled in federal court (Jane Doe v. Epstein, Case No. 08•CIV-60893, U.S.D.C. S.D. Fla.)\O\\*appeansara1,18 out of the-40.-boxes -retard by the FBI as part of its Investigation at RRA conskstadotIllaseelePeg bathe CM Actions Involving EPSTEIN, as reported by counsel for the Bankruptcy Trustee. .tintlitheSe boxes can be reviewed, as well as other discovery, Epstein WA opt knoie the depth of fraud and those involved. i• regarding sortie, ROTHSTEIN and others were able to lure investors into ROTHSTEIN'S lair and bilked them of millions of dollars which, in turn, was used to fund the litigation against EPSTEIN for the sole purpose of continuing the massive Ponzi 30. By using the Civil Actions against EPSTEIN as -bar and fabricating settlements scheme. ( NIIS, 31. As part of this scheme, ROTHSTEIN and the Litigation Team, Incliv!dimity and in a concerted effort. May have unethically and illegally: - a. Sold. allowed to be sold and/or assisted with the sale of an Interest In nonsettled personal Injury lawsuits (which ere non-assignable and nontransferable) or sold non-existent structured settlements (including those cases involving Epst - b. Reached agreements hare attorneys fees with non-lawyers; - c. Used Investor, money to pay plaintiffs (I.e., L.M., E.W. and Jane Doe) 'up front' money such that plaintiffs would Klima to settle the Civil Actions; d, Conducted searches, wiretaps or intercepted conversations In violation of (Ste or federal laws and Bar rules; and Utilized the judicial process including, but not limited to, unreasonable and unnecessary discovery, for the sole purpose of furthering the Ponzi scheme. 32. Any such actions by ROTHSTEIN, and other attorneys, including the Litigation Team, directly or indirectly, would potentially be a violation of vadous Florida Bar Rules, I I including prohibiting the improper sharing of fees or costs and various conflicts of Issues rules. 33. Evidencing that the Litigation Team knew or should have known of the improper purpose that ROTHSTEIN was pursuing In the continuation of the scheme, ROTHSTEIN used RRA's Litigation Team in the EPSTEIN cases to pursue Issues and evidence unrelated to and unnecessary to the claims pled le the Civil Actions, but significantly beneficial to lure investors Into the Ponzl ROTHSTEIN and other co-conspirators. JA\\ orchestrated by 01. Upon information and belief, ROTHSTEIN.and others claimed their investigators discovered that there were high-profile Individuals onboard Epstein's private jet where sexual assaults took place and showed D3 (and possibly others) copies of a tight log purportedly containing names of celebrities, dignitaries, and International figures. 01. For instance, the Litigatior,Carn relentlessly and knowingly pursued flight data and poosonger manifcato rogers14 flighto EPSTEIN took with these famous Individuals knowing full well that no underage women were onboard and no Illicit activflies took place. ROTHST EtN and the Litigation Team also inappropriately attempted to take the depositions of these celebrities In a calculated effort to bolster the marketing scam that to faking place. 3ADrie of Plaintiffs' counsel, , deposed three of EPSTEIN'S pilots, and sought the deposition of a fourth pilot (currently serving In Iraq), The pilots were 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 transportation on flights of RRA clients on any of EPSTEIN'S planes. But asked many Inflammatory and leading Irrelevant questions about the pilots' thoughts and beliefs (which will never be admissible at trial) which could only have been asked for the purposes of 'pumping' the cases and thus by using the depositions to sell the cases (or a pad of them) to third parties. 37. Because of these facts, ROTHSTEIN claimed Mitt Epstein wanted to make Certain none of these individuals would be deposedA therefore he had offered \$200.000,000.00 to settle the claims of RRA female ctier'erious potential plaintiffs in actions against EPSTEIN. The offer of a\$200 million dollar settlement by EPSTEIN was completely fabricated; no such offer ever been made. 01. office also notified Defendant that he Intended to take the depositions of and was subpoenaing: - (i) Donald Trump (real-estate magnate and business mogul); - (e) Alan Dershov4tz (noted Harvard Law professor, constitutional attorney . and one of EPSTEIN'S criminal defense attorneys); ,')alit Clinton (Former President of the United States); )Tommy Mottola (former President of Sony Record); end - (v) David Copperfield (illusionist). 39>The above-named individuals were friends and acquaintances of EPSTEIN with whom he knew through business or philanthropic work over the years. None of the above-named Individuals had any connection whatsoever with any of the Litigation Team's clients, E.W., L.M. Of Jane Doe. 40. filed amended answers to Interrogatories In the state court matters, E.W. and L.M., and listed additional high profile witnesses that would allegedly be called at trial, including, but not limited to: - (i) Bill (Governor of New Mexico, formerty U.S. Representative and Ambassador to the United Nations); and - (ii) Any and all persons having knowledge of EPSTEIN'S charitable, political or other done tions;2 41. The sole purpose of the scheduling of thOSAL friondakoguafitances as potential witnesses was, attain, to "pump" the cases to investors. There Is no evidence to date at these Individuals had or have any knowledge regarding RRA's Civil Actions. ns or listing high profile 01. In furtherance of their Illegal and fraudulent scheme against EPSTEIN, ROTHSTEIN, (who either know or should have known) and, at times, L.M. in her Civil Action against LPSTEIN: - a) Included elairns for damages in Jane Doe's federal action in excess of 550,000,000.00 rather than simply 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 2 Thesa high-profile celebrity 'purported' wilresses have no personal knowledge regarding the facts on these 'Three Cases', but were being contacted, subpoenaed or fisted to harass and intimidate them end Epstein, and to add 'etas- appeal to the markolIng effort of the Renzi scheme. investors or to prejudice Epsteln's right to a fair trial in Palm Beach County. - c) Berger arxt Adler (another rternedrf4fr RRA) all attended EPSTEiN's deposition. At that time, outrageous questions were 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 discovery unrelated to the claims In or subject matter of the Civil Actions for the purpose of harassing and embarrassing witnesses and EPSTEIN and causing EPSTEIN to spend tens of thousands of dollars in unnecessary attorneys' fees and costs defending what appeared to be discovery related to the Civil Actions but was entirety rotated tv the furtherance of the Ponzischerno. - 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 dramatically in addressing the court on various motions from being substantive ■ **the facts pled to ridiculously inflammatory and sound-bite rich such as the July 31, 2009, transcript when** 1--LEDWARI:1,11) a ted to the Court in E.VVIL.M.: "What the evidence Is really going to show Is that Mr. Epstein — at least dating back as far as our Investigation and resources have permitted, back to 1997or '98 — has every single day of his life, made an attempt to - sexually abuse children. We're not talking about five, iitelre talking about 20, we're t5ot talking about 100, we're not talking about 400, which, I beileve Is the ntriennown to taw enforcement, we are talking about th0eeands of children. .. and It Is through avery intricate and complicated system that he devised where he has as many as 20 people working underneath him that he is paying well to schedule these appointments, to locate those girls.' - f) As an example, EDWARDS filed an unsupportable and legally deficient Motion for Injunction Restraining Fraudulent iransfor of Assets, Appointment of a Receiver to Take Charge of Property of Epstein, and to Post a \$15 million Bond to Secure Potential Judgment, In Jane Doe v Epstein, Case No. LIB-CV-80893- Marra. The motion was reported in the press as was the 1 ultimate goal (i.e., to "pump" the cases for Investor following). However, the Court found \*Naintiffs motion entirely devoid of evidence ... ", and denied the motion in into. - g) ROTHSTEIN told investors he had another 52 fernates that he represented, and that Epstein had offered \$200 million to resolve, h) ROTHSTEIN and the Litigation Team knew or should have kn that their three (3) filed cases were weak and had minimal value for the following reasons: te. — testified she never d any type of sex with Epstein; worked" s strip clubs; is an admitted prostitute as11 call giri; has a history of Illegal drug use (pot, painkillers, Xenex, Ecstasy); and continually asserted me 5°i Amendment during her depositions lrrordertt avoidanswering relevant but problem questions for her, (II) E.W. — testified she worked at eleven (11) separate strip clubs, including Cheetah which RRA represented and In which R0THSTEIN may have owned an Interest and E.W. also worked at Platinum Showgirls In Boynton Beach, which was the subject of a recent police raid where dancers were allegedly selling prescription painkillers and drugs to customers and prostituting themselves. Jane Doe (federal case) seeks \$50 million from Epstein. She and her attorneys claim severe I but that he could settle, confidently, these cases for \$600 million, I, separate and apart from his legal fees. ...it I > \:- I emotional distress as a result of her having voluntarily gone to Epstein's home. She testified that there was never oral, andaat sexual Intercourse; nor did she ever touch his genitalia. Yet, Jane Doe suffered wdreprie emotional distress well prior to meeting Epstein us a result of having witnessed her father ardor his girlfriend's son. She was required Wive sworn testimony In that matter and has admitted that she has fled in sworn testimony. Jane Doe worked at two different strip clubs, including Platinum Showgirls In Boynton Beach. - l) Conducted ridiculous and irrelevant discovery such as subpoenaing records from an alleged sox therapist, Dr. Leonard Bard In Massachusetts, when the alleged police report reflected that EPSTEIN had only seen a chiropractor In Palm Beach named Or. Bard. No records rotating to EPSTEIN existed for this alleged sex therapist, Dr. Bard, and 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 - I - k) Told investors, as reported In an Associated Press article, that celebrities and other famous people had flown On EPSTEIN'S plane when assaults took place. Thereto even though none \_\_\_(zero) of RRA's clients claim they fievirA 'S planes, the Litigation Team sought pilot and plane logs. Why? Again, to prime the Investment "pump" with new money without any relevance to the existing claims made by the RRA clients. intercourse with EPSTEIN and she had never touched his genitalia. 0 After joined RRA, and former Circuit Judge William Berger filed and argued motion to make the Non-Prosecution Agreement (NPA) between Epstein and USAO public. But, RRA, and Berger, 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 Civil Actions. The concept behind certain civil provisions in the NPA was to allow an alleged victim to resolve a chili claim with Epstein, maintain her complete privacy and anonymity and move on with her life. As an assistant United States Attorney stated al a hearing in federal court, the NPA was not designed "to hand them a jackpot or a key to a bank." 43. ROTHSTEIN, with the Intent and improper motive to magnify his financial gain so continue 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 were meant to further the fraudulent scheme and criminal activity of ROTHS I tiN so that he and others could fraudulently overvalue the settlement value of the existing and non-existent claims against EPSTEIN to potential investors. \<';') 01. As a result of the fraudulent Investment or (Ponzi) scheme, RRA and Its attorneys In the Civil Actions against EPSTt may have compromised their clients' interests. ROTHSTEIN and the Litigation Team would have been unable to give unbiased legal counsel bocaute e investor(s) had been promised a financial interest In the outcome of the hItfoni: Additionally, if a plaintiff received payments from investment monies while her a6tIon is pending, this dearly could impact the plaintiffs decision of whether or not to settle the current litigation or shade their testimony (i.e. commit perjury) to gain the greatest return on the investment and to further promote the Ponzi St e. ' ht.) The truthfulness of L.M.'s allegations and testimony in L.M.'s state civil have been severety compromised by the need to seek a multi-million 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 Ponzi 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. a. Though she held herself out as a °victim\* of Epstein, she admitted to having returned over and over again to him despite her currert1 claim of abuse. She .\_.... ....\_ . ......\_\_... ... \_..— .. has now admitted, under oath, to being a call girt/escort since the age of 15. (in her deposition September 24, 2009 Transcripi-D T' 280:16,19). She testified "Well, I lived life as a prostf tsee DT 156:7) and 1 am a prostitute when I make money" (see IT 1 .12-13). L.M. admitted her activity with men other than Epstein to making \$1,000 a day from prostitution on maybe more than 20 occasions in ono year alone (DT 157:11-158:21). L.M. admitted under .o keeping a list of amounts she collected from "Johns- in "two or three" lined books Including a book of 'Psalms" that she obtained from a religious store (DT 152:1-14). Under the circumstances, her claim for damages against EPSTEIN, one of LM.'s many "Johns" during that e period, would be so incredible and certainly not likely to produce the Cr inary settlements promised to "RBA's Investors." \\ In April 2007, before she was represented by, 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 aegations on which i I L.M.'s civil action against Epstein Is now based. However, once in the hands of i I I. and RRA, L.M.'s story changed dramatically. All of a sudden she wanted to sue EPSTEIN and like other RRA clients, sought tens of millions of dollars. - a. 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 an awesome man and it reaty would be a theme. It's a shame that he has to go through this because he's an awe he didn't do nothing wrong, nothing.' (pp. 67.58 - FBI). In feet, C.M. spoke so highly of EPSTEIN and her interactions with him that the US Attorney's office Wormed a federal court in Jr 08 that the US Attorney could not consider L.M. a victim. IN. -v Yet, by September 24, 2009, the date on which L.M. began her deposition he civil action and now represented by RRA and L.M.'s new and very different tale about purported sexual sconduct under the supposed Influence of EPSTEIN had been ughty rehearsed and her role into the ROTHSTEIN scam was complete. In her deposition in her civil action, L.M. declared that: 0 al, I don't really care about money? (DT 208:8) \*Ho needs time In Jail. 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 life I have lived that shitty life because of Jeffrey Epstein?' (DT 222:7-8) • - b. In her sworn FRI testimony (pre- and RRA), L.M. was ; emphatic that her interactions with Epstein Involved no Inappropriate sexual touching In any way. In fact, it was exactly the opposite: Q; Did he at any point kiss you, touch yap. show any kind of affection towards you? A: Never, never. (p. 21 — FBI) ... .) Q: So he never pulled you closer to him in a sexual way? A: I wish. No, no, f, MAK no, never. Jeffrey is an awesome man. no. (p.21 -FBI) after Yet. L.M. led her second amended complaint in April 2009, Joined RRA, the allegations against EPSTEIN In complaint became even more salacious. In paragraph 12 of A; Second Amended Complaint, L.M. a%eges among other things, that: "Jeffrey Epstein coerced, induced, or enticed . .the then minor Plaintiff to comma various acts of sexual misconduct. These acts 1. Included, but were not limited to, fondling and inappropriate and illegal sexual touching of lho then minor Plaintiff. forcing or inducing the then minor plaintiff into oral sex or other sexual misconduct..." 1 1 c. In her sworn FBI statement (pre and RRA), L.M. testified mat the Individual who first brought LM. to EPSTEIN's home, told LM. 'make sure you're 18 because Jeffrey doesn't went any underage girls.' (p. 8 - FBI). > Yet at her September, 2009 deposition now represented\* and RRA, L.M. told a very different story: > Qt My question was what did Carolyn tell you to tell Mr. Epstein about your age? A: She saki It didn't litter.,, Cr. That's your recollection about what she said? A: Yes, she .remember her saying it doesn't matter. Don't worry (DT 199 25) d. ProIMM and RRA, LM. testified to the FBI : 1 always made sure — I had a fake ID, anyways saying that I was 18.\* (p. 8 - FBI). Yet, when questioned about her fake ID at her September 2009 dope, she Q: And did you have a fake ID? A: No. Q: I lave you ever had a fake ID? A: No. (DT 300:5-8) e. In her FBI statement (pre and RRA), L•trilpstlfied about others LM. brought to the Epstein home. L.M. testified that women she brought to EPSTEIN's home were eager for the opportUntty 94eidirtent with their experiences: > ANone of my girls ever had aproblem and they'd call me. They'd beg me, you know, for us to go to Jeffrey's house because they love Jaffrey. Jeffrey is arespoC•ful man. Ho really Is. I mean, and he all thought we were of age always. This Is what's so sad about ft. (p 30 - FBI). • • • Q: Did any of the girls complain about what happened after they left there? 14/ 6....) A: No..-"You asked me that question. No, everybody loved Jeffrey. (p. 44 - FBI) • AEvery girl That I brought to Jeffrey, they said they worn fine with it. and Ilke for example \[E.VV. — another of RRA's clients in the Civil Actions), a lot of girls begged me to bring them back for the money. And as far as I know, we all had tun there. (p. 45 - FBI) I. 1 I Yet, with and RRA as her attorneys, L.M. did a —MD' at her ". September, 2009 deposition in saying: > A: . . . Once they were there, they were scared out of their mind. They did It anyways and some of them walked out and said L.M. don't ever do this to me again. That was the worst thing that ever happened to me. (DT 170:8-11) .. . A: And then, a lot of girls weren't comfortable. (DT 171:13) f. The above represent only a few of the dramatic changes L.M. made In her testimony prior to her representatlbn by 'RRA and after she hired ROTHSTEIN, and RRA. 48, As a result of the fraudulent investment or (Portz') scheme, L.M. may knowingly have compromised her alleged interests In her Civil Action, or committed a fraud on the 'e) ) court. 49. RRA and the Litigation Team took an emotionally driven of of facto involving alleged Innocent, unsuspecting, underage females and a Palm Beach Billionaire and sought to turn It Into a gold mine. Rather than evaluating and resolving the cases based on the merits (i.e. fads) whch Included knowledgeable, voluntary and consensual actions\\ ili breach of the claimants and substantial pre-Epsteln psychological and emotional conditions of each of the claimants and substantial sexual experiences pre-Epstein, RRA and the Litigation Team sought through protective orders and objections to block relevant discovery regarding their claimants. They Instead forged ahead with discovery the main purpose of which was to pressure Epstein into settling the cases. Fortunately, their tactics have not been successful. As Magistrate Judge Linnea wrote in a discovery order dated September 15, 2009 (DE 299 In Federal Case #08-80119) in denying Plaintiffs' Motion for Protective Order 'This is his [Epstein's] right. The Record in this case is clear that the childhood of many of the Plaintiffs was marred by Instances of abuse and neglect, which in turn may have resulted, In whole or in part, in the damages claimed by the Plaintiffs.' In addition, in an Omnibus Order dated October 28, 2009 (DE 377 in Federal Case #08.80119) Magistrate Judge Linnea Johnson wrote: 'Here the request at issue goes to the very heart of the Plaintlfs damage claims. requesting not only general info on relating to Plaintiffs sexual history, but InqUiring as to specific instarMes wherein Plaintiff received compensation or consideration for sex acts, claim other males sexually assaulted, battered, or abuses her, and/or claim other moles committed lewd or lascivious acts on her. As a global matter, Plaintiffs clearly and unequivocally place theft sexual history In Issue by theft allegations that Epstein's actions in this case has negatively affected their relationships by, among other things, "distrust in men: 'sexual Macy problems,' "diminished trust," "social problems,' " problems In personal fationships," " feeling of stress around men," "premature teenage pregnancy,' 'antisocial behaviors," and 'hyper-sexuality and promiscuity." Considering these allegation, there simply can be no question that Epstein Is entitled to know whether Plaintiffs were molested or the subject of other "sexual activity or "lewd and lascivious conduce In order to determine whether there is an alternative basis for the psychological disorders Plaintiffs claim to have sustained, whether Plaintiffs engaged in prostitution or other similar type acts and how certain acts alleged in the Complaint materially affected Plaintiffs' relationships with others or how those acts did not have such an affect on those relationships and/or whether Plaintiffs suffered from the alleged emotional and psychological disorders as a result of other sexual acts prior to the acts alley the Complaint To deny Epstein thus discovery, would be tantamount to barring him from mounting a defense? 50. ROTHSTEIN, and L.M.'S atilonS'constitute a fraud upon EPSTEIN as RRA, ROTHSTEIN and the Litigation Team represented themselves to be acting In good faith and with the bests Interests of their clients In mind at all times when in reality, they were acting In furtheratice el Investment or Ponzi scheme described herein. EPSTEIN Justifiably relied to hIs detriment on the representations of RRA, and Defendants, ROTHSTEIN, and L.M. as to how he conducted and. defended the CM Actiont sI rought against hint. 01. Perect a ' and proximate result of the fraudulent and Illegal investment or Ponzi scher aChestrateci by ROTHSTEIN and as yet other unknown co-conspirators and as a re ilt of the litigation tactics undertaken by the Litigation Team and L,M. as set forth herein, Plaintiff EPSTEIN has incurred and continues to incur the monetary damages Including, but not limited to, having to pay an amount in excess of the Civil Actions' true value as a result of them refusing to settle In that a percentage of any payment by Epstein v. RRA, et al. Page 30 EPSTEIN may have been promised to third party investors; incurring significant additional legal fees and costs as result of Defendants refusal to conduct settlement negotiations In a forthright and good faith manner because any monies paid by EPSTEIN is in reality a promised return on an investment and incurred significant attorneys' fees and costs In defending the discovery that was not relevant, material and/or calculated to lead to the admissibility of evidence, but which was done for the sole purpose of 'pumping' the cases to Investors. 52. EPSTEIN has also been Injured In that the scope of the fraudulent and criminal or racketeering activity so permeated the RRA law firm that EPSTEIN has been prevented from fully and fairly dafendiree civil actions brought against him. In essence, the very existence of RRA was based on the continuation of the massive Ponzi scheme orchestrated bAR2TI4STEIN and other co-conspirators. In order to ) continuo to bring In monies from Investors, ROTHSTEIN and other coconspirators used the Civil Actions against EPSTEIN, along with other manufactured lawsuits, as a means of obtaining massive amounts of money. 01. ROTHSTEIN, and L.M. are liable for damages caused to EPSTEIN Individually d jointly and severally. N Count,' - VolaUcr n of Se5772.1131, °tsar', Flu. Stat.. Flaws. CIA Nomcialas ter Criminal' Prgetleds Act-Against Alt DefendarrtS 54. Plaintiff realleges and incorporates paragraphs 'I through 53 as if fully set forth herein. 01. RRA, ROTHSTEIN, and L.M. each and collectively constitute an enterprise pursuant to §772.102(3), Ha. Stat. (2009). 01. ROTHSTEIN, and LM. engaged In a pattern of criminal activity if defined in §772.102(3) and (4), Fla. Stat. (2009). 01. As alleged herein, ROTHSTEIN and commkted mutilate predicate acts In violation of §772.103(1), (2), (3) and (4), Fla. Stat, Including violations of Florida Statutes - Chapter 517, relating to securities transactions; Chapter 317, relating to fraudulent practices, false pretenses, and fraud generally (which Includes LM); Chapter 831, relating to forgery; §838.05, relating to extortion (which includes L.M.); and Chapter 837, relating to perjury (which Includes .). Substantially more than two predicate acts (i.e., the selling of or participatlen 0 a sale of fabricated settlements outlined Includes.). iv herein, including the CM Actions involving Epstein as well as the improper litigation tactics outlined above) occurred'fdii a five-year time period. 01. As a direct and proximate result of ROTHSTEIN, and L.M.'s violations of §772.10 p Stat., EPSTEIN has been Injured. 01. Pursuant to § 2,104(1), Ha. Stat" Plaintiff EPSTEIN is entitled to threefold of his actual damages sustained, reasonable attorney's fees and court costs, and such othe tarnages es allowed by law. WHEREFORE, Plaintiff EPSTEIN respectfully demands the entry of a judgment for damages against all the named Defendants. > Countli- Floilda RICO "RacketeerSfleinS" Inffi Pursuant to lA89\$.lAntsennnti.. Stat14/.{2a Miflet. All Defendants 60. Plaintiff realleges and incorporates paragraphs 1 through 53 as If fully set forth herein. I 01. RRA, along with ROTHSTEIN, and L.M., each and euileclive constitute an enterprise pursuant to §895.02(3), Fla. Stat. (2009). 01. During all times relovant hereto, ROTHSTEIN, are associated with the enterprise, RRA, and each other. A‹ and L.M. were and 01. Defendants, ROTHSTEIN, and LM persons associated with the enterprise, RRA and each other (as an enterprise), n conducted or participated, directly or indirectly, in such an enterprise \*h pattern of racketeering, § 895.03(3). Ha. Stat., as alleged above herein. \\S" 01. The breadth and scope of ROTa. and, potentially, L.M.'s racketeering activity continu 6e Investigated by the FBi, as numerous civil lawsuits against some of the Date ants and others continue to be filed by persons who have been damaged. As of the filing of this Complaint, criminal charges have only been brought against ROTHSTEIN. 01. Substantially mom than two predicate acts (I.e., the selling of fabricated settlements outlined herein, including the Civil Actions involving Epstein as well as the improper litigation tactics outlined above) occurred within a five year time period. 01. Pursuant to §695.02, Fla. Stat., ROTHSTEIN and engaged in a pattern of \*racketeering activity" through the commission of crimes as defined In § 595.02(1)(a)-(b), Fla. Stat., including Chapter 517, relating to securities: Chapter 817, relating to fraudulent practices, false pretenses, and fraud (including L.M.) generally; Chapter 813, relating to forgery; §838.05, relating to extortbn (Including L.M.); Chapter 837, relating to perjury (including LM.). 67. Pursuant to §695.05, Ha. Stet, Plaintiff seeks the following relief against Defendants, ROTHSTEIN, and L.M.: - a) Ordering ROTHSTEIN} and to divest themselves of any Interest In the enterprise, RRA; - b) Enjoin ail Defendants from engaging in the same typo of conduct and activities as described herein; and - c) Temporarily enjoining ROTHSTEIN, and LM., from the continuation of the Civil Actions brought against EPSTEIN until criminal charges have been formally brought against RRA and/or any of the Defendants, such that EPSTEIN may be allowed to evaluate whether a stay or dismissal of all Civil Actions against him is merited. 68. EPSTEIN fel seeks an award of his reasonable attorney's fees and costs, and such ot r relief that this Court deems appropriate. WHE14.ARE, Plaintiff EPSTEIN respectfully demands the entry of a judgment for the relief sought and damages against the named Defendants. ### Count Ill — Abuse of Process — Against All Defendants 69. Plaintiff reallcges and Incorporates paragraphs 1 through 53 as if fully set forth herein. 01. After InsUtutIng the CM Actions against EPSTEIN, the actions of Defendants, ROTHSTEIN, and L.M. as alleged In paragraphs 9 through 53 herein, constitute an illegal, Improper or perverted use of process. 01. ROTHSTEIN, and L.M. possessed ulterior motives or purposes In exercising such illegal, Improper, or perverted use of process. 72, As a result of ROTHSTEIN, damages. and L.M.'s actions, EPSTEIN suffered WHEREFORE, Plaintiff EPSTEIN respectfully deep Pantry of a judgment for liafilages against all the named Defendants. ### Count Against All bafondants 73. Plaintiff reafleges and incorporates paragraphs 1 through 53 as if fully set forth herein. 01. ROTHSTEIN, by and through Defendant and L.M. made false statements of fact to EPSTEIN end his attorneys and agents, known to be false at the time made, and/or intentionally concealed material information kern EPSTEIN and his attorneys al4f agents, for the purpose of Inducing EPSTEIN to act in reliance thereon. 01. Ea IN did so act on the misrepresentation and/or concealment by Incurring additional attorney's fees, costs, and expenses in aggressively defending the civil actions whereas in reality, because the Civil Actions against Plaintiff were being exploited and over-valued so es to lure additional investors and to attempt to extort as much money as possible from EPSTEIN so as to continue the massive fraud. WHEREFORE Plaintiff EPSTEIN demands judgment against Defendants for damages incurred and for any other relief to which he is entitled under the law. Conspiracy to Commit Fraud\ Against All Defendants 76. Plaintiff realleges and incorporates paragraphs 1 through 53, and 74 and 75 as if fully set forth herein. 01. ROTHSTEIN, [REDACTED] and L.M. conspired to commit a fraud upon EPSTEIN. 01. ROTHSTEIN, [REDACTED] and L.M. combined by and through concerted action as detailed herein to accomplish an unlawful purpose or accomplish some purpose by unlawful means. The unlawful purpose was, among other things, the orchestrating and continuation of the massive fraudulent Ponzi scheme and receipt of monies for the continuation of the scheme. The unlawful means includes, but is not limited to, the use of the Civil Actions against EPSTEIN in an unlawful, improper, and fraudulent manner. 01. As a direct and proximate result of ROTHSTEIN, [REDACTED] and L.M.'s conspiracy to defraud EPSTEIN, EPSTEIN suffered damages. WHEREFORE Plaintiff EPSTEIN demands judgment against Defendants for damages incurred and for any other relief to which he is entitled under the law. Jury Trial Plaintiff demands Jury Trial on all issues so triable. ![](<>)rcritfatscicievtoan1 MICHAPL J. PIKE, ESQ. Florida Bar #617296 meikeralbsIclaw.aml BURMAN, CRI I ION, LUTTIER & CO 303 Banyan Blvd., Suite 400 West Palm Beech, FL 33401 561-842-2820 Fat 581-253-0154 (Attorneys for Pletntift) • 389 # UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO. 051-60331-CR-COHN UNITED STATES OF AMERICA, Plaintiff, v. SCOTT W. ROTHSTEIN, Defendant. # PLEA AGREEMENT The United States of America and SCOTT W. RO STBIChereinafter referred to as "the defendant") enter into the following agreement: I. The defendant agrees to plead g drive count Information, which charges the defendant in Count 1 with a Racketeering Conspi y, in violation of Title 18, United States Code, Section 1962(d); in Count 2 with Conspiracy to Commit Money Laundering, in violation of Title 18, United States Code, Section 1956(h); in Count 3 with Conspiracy to Commit Mail Fraud and Wire Fraud, in violation of Title 18, United States Code, Section 1349; and in Counts 4 and 5 with Wire Fraud, in violation of Title 1S8, United States Code, Section 1343. 2. Th..... e i defendant is aware that the sentence will be imposed by the Court after considering the Federal Sentencing Guidelines and Policy Statements (hereinafter "the Sentencing Guidelines") in an advisory capacity. The defendant acknowledges and understands that the Court will compute an advisory sentence under the Sentencing Guidelines and that the applicable advisory guidelines will be determined by the Court relying in part on the results of a Pre-Sentence Investigation by the Court's probation office, which investigation will commence after the guilty plea has been entered. The defendant is also aware that, under certain circumstances, the Court may depart from the applicable advisory guideline range and impose a sentence that is either more severe or less severe than the advisory guidelines range. The Court is permitted to tailor the ultimate sentence in light of other statutory concerns. Knowing these facts, the defendant understands and acknowledges that the Court has the authority to impose any sentence within and up to the statutory maximum authorized by law for the offenses identified in paragraph 1 and that the defendant may no1 withdraw the plea solely as a result of the sentence imposed. 3. The defendant also understands and acknowledges that dart may impose a statutory maximum term of imprisonment of up to twentyyears for eacc of the offenses set forth in Counts 1 through 5, for a total of up to one hundred years, followed ,by a term of up to three years of supervised release for each offense. In addition to a tentof imprisonment and supervised release, the Court may impose a fine of up to \$250,000.00 with respect to the offenses set forth in Counts 1, 3, 4, and 5, and may impose a fine with respt4 to the offense set forth in Count 2 of the greater of \$500,000.00 or twice the value of the property involved in the money laundering transactions. 1. The defendant further understands and acknowledges that, in addition to any sentence imposed under paragraph 34Lthis agreement, a special assessment in the amount of \$100.00 with respect to each of the offenses set forth in counts I through 5, for a total of \$500.00, will be imposed on the defendant. which will be paid by the defendant at the time of entry of this plea. 1. The defendant further understands and acknowledges that, in addition to any sentence imposed under paragraphs 3 and 4 of this agreement, that restitution may be imposed as part of that sentence. The defendant agrees that for purposes of triggering the mandatory restitution provisions of Title 18, United States Code, Section 3663A, the offenses to which the defendant is pleading guilty under this agreement in this case are "offenses against property" and were "committed by fraud and deceit," as those terms are understood within Title 18, United States Code, Section 3663A(c)(1)(A)(ii). The defendant accordingly understands and acknowledges that as a result of his plea of guilty pursuant to the terms of the plea agreement in this case the Court may order that he pay restitution pursuant to the provisions of Title 18, United States Code, Sections 3663A and 3664. Promptly following the entry of his guilty plea, the defendant agrees to take all nece steps to make the following property available, as partial satisfaction of any restitution or4entered in this case: (a) all property subject to the post-Information Protective property identified in the Bill of Particulars for Forfeiture. its and (b) all A R IL 6. The defendant further understands and acknowledges that, in addition to any sentence A imposed under paragraphs 3, 4 and 5 of this agreement,trfeiture may be imposed as part of that ,)' sentence. The defendant agrees to the forfeiture ofa clabs right, title and interest to all assets listed in the Information and listed in the Bill of Particulars, and/or their substitutes thereinafter "the assets"), whether controlled individually or through defendant's wholly owned or partially owned corporations or third-parties, hare subject to forfeiture pursuant to Title 18, United States Code, Sections 1963, 982(a)(1) and/or 981(a){1XC). The defendant agrees to assist the United States in achieving forfeiture of the assets and agrees to assist the United States with forfeiture of same, such assistance to melt truthful testimony, especially to the extent that the assets arc in the names of corpora other entities or individuals. The defendant knowingly and voluntarily waives any right to a jury trial or any other adversarial proceeding regarding the assets and waives any notification about forfeiture proceedings, whether administrative or judicial. The defendant further waives any statute of limitations with respect to the commencement of such forfeiture proceedings, e or judicial. The defendant also waives any defenses to the forfeiture, excessive fine or penalty under the Eighth Amendment. The defendant also peal of the forfeiture. The defendant further acknowledges that the property in whole or in part, be used to satisfy any obligation the defendant may have r local taxes, interest and/or other penalties which may now exist or which CC. lice of the United States Attorney for the Southern District of Florida e") reserves the right to inform the Court arid the probation office of all facts icing process, including all relevant information concerning the offenses harged or not, as well as concerning the defendant and the defendant' As )nly to the express terms of any agreed-upon sentencing recommendatiN, ment, this Office further reserves the right to make any recommendation as itity of punishment. ) " A\)PAUL F. SCHWARTZ\ ASSISTANT UNITED STATES ATTORNEY Date: 4/25/10 ![](<>)JEFFREY N. KAPLAN\ ASSISTANT UNITED STATES ATTORNEY Date: 25 Jan 10 ![](<>)LAWRENCE D. LAVECCHIO\ ASSISTANT UNITED STATES ATTORNEY Date: 1/25/10 ![](<>)MARC NURIK\ ATTORNEY FOR DEFENDANT Date: 1/25/10 ![](<>)SCOTT W. ROTHSTEIN\ DEFENDANT The United States of America and SCOTT W. ROTHSTEIN enter into the following stipulated statement of facts in support of the defendant's plea of guilty: Had this case proceeded to trial, the government would have presented evidence which would have established beyond a reasonable doubt that from in or about 2005, through in or about November 2009, Defendant ROTHSTEIN conspired with persons known and unknown to the United States Attorney, to use the law firm, Rothstein, Rosenfeldt and Adler Y.A. (hereinafter referred to as "RRA") as a criminal Enterprise in order to conduct a pattern of racketeering activity. Such pattern of racketeering activity included criminal acts which violated mail fraltwire fraud, money laundering and conspiracy statutes. The government would have presented evidence at trial which would have involved witness 14/ 8/ testimony and documentary and electronic evidence seized pursuant to a search warrant. The government's trial evidence would have established the following: Defendant ROTHSTEIN was an attorney admitted to practice law in Florida. He was the Chief Executive Officer and Chai f RRA. In or about 2005, Defendant ROTHSTEIN and other co-conspirators initiated a heme to generate criminal proceeds through fraudulent acts. Defendant ROTHSTEIN induced investors through the use of false statements to loan money to himself and fictiti wers in return for promissory notes. He solicited bridge loans on behalf of purported clients of RRA, that is, he would falsely inform individuals that clients of RRA desired to borrow ftreds for undisclosed business deals and in return would agree to pay high rates of interest. Defendant ROTHSTEIN was aware that no such clients or requests for business financing actually existed. Defendant ROTHSTEIN and co-conspirators also solicited investors to purchase purported confidential settlement agreements. Such settlement agreements were falsely presented as having been reached between putative defendants based upon claims of sexual harassment and/or whistleblower actions. The investors were falsely informed that such settlement agreements were prelitigation and therefore there was no pending litigation or court oversight. Defendant ROTHSTEIN and other co-conspirators relied upon the purported success of RRA, the existence of actual RRA civil matters and his standing in the community to lure potential investors in order to convince them to make such investments. The investors were falsely informed that the confidential settlement agreements were available for purchase. The purported settlements were allegedly available in amounts ranging from hundreds of thousands of dollars to millions of dollars and could be purchased at a discount and repaid to the investors at face value over time. F instanter, in or about late 2009, a potential investor was solicited by Defendant ROTHSTEIN onspirators to purchase a purported settlement in the amount of \$450,000. The sNernent was alleged to be paid to the purported plaintiff in three installments of \$150,000 each, over the course of three months. The payment schedule was alleged to insure the confidentiality of the settlement. The purported plaintiff allegedly had agreed to accept an immediate payment of \$375,000 in satisfaction of the settlement agreement. In order to facilitate the scheme, the investor received a fraudulent settlement agreement which set forth the terms of the civil settlement, but the names of the purported plaintiff and defendant were ex due to the alleged confidentiality of the settlement. The government would further establish that in order to facilitate and perpetrate the scheme, Defendant ROTHSTEIN and co-conspirators created false and fraudulent settlement agreements, bank statements, assignments of settlement agreements, sale and transfer agreements and personal guarantees, among other documents. Defendant ROTHSTEIN and other co-conspirators falsely informed investors that the purported confidential settlements were either negotiated on behalf of clients of RRA or had been referred by other law firms. The investors were falsely informed that the purported settlements were based upon sexual harassment and/or whistle-blower (qui-tam) actions against corporate defendants. Defendant ROTHSTEIN and other co-conspirators established and maintained trust accounts at several financial institutions in order to receive the investor funds and to give the appearance of legitimacy and security. False and fictitious trust account bank balance statements were created along with purported "lock letters." Such letters allegedly reflected that the funds in the trust accounts would be disbursed only to specific investors. Instead funds were disbursed among and between the various trust accounts and elsewhere by interstate wire transfers and other means in order to facilitate, promote and conceal the fraud, to laun derived therefrom, and to enrich ROTHSTEIN and his co-conspirators. ROTHSTEIN and his co-conspirators created fraudulent on-line banking documents to further mislead investors and to facilitate the fraud. Defendant ROTHSTEIN and co-conspirators also initiated and conducted a separate scheme t to defraud clients of RRA in order to phittetilate the "Pc:qui" scheme. Such clients had retained RRA to institute and file a civil lawsuit. Unknown to the clients, RRA settled the lawsuit and had obligated the clients to pay \$500,000 to the defendant. In order to perpetrate the fraud and deceive the clients, defendan THSTEIN created a false and fraudulent court order purportedly signed by a Federal District Court Judge which falsely alleged that the clients of RRA had prevailed in the lawsuitar owed a judgement of approximately \$23 million. The fraudulent court order also falsely stated that the defendant had transferred funds to the Cayman Islands for the purpose of secreting the assets. Defendant ROTHSTEIN and other co-conspirators falsely advised the clients on several occasions that in order to recover the defendant's ffinds, they had to post bonds to be held in the RRA trust account. Defendant ROTHSTEIN and other co-conspirators fraudulently caused the clients to wire transfer a total of approximately \$57 million over several years to a trust account controlled by defendant ROTHSTEIN, purportedly to satisfy the bonds. Defendant ROTHSTEIN and other co-conspirators were questioned by the clients as to the progress of the alleged lawsuit. In order to delay the return of funds to the clients, defendant ROTHSTEIN fraudulently created a false Federal court order purportedly issued by a United States Magistrate Judge ordering RRA to return the transmitted funds by a later date. Defendant ROTHSTEIN and other co-conspirators utilized funds obtained through the "Ponzi" scheme to supplement and support the operation and activities of RRA, to expand RRA by the hiring of additional attorneys and support staff, to fund salaries and bonuses, and to acquire larger and more elaborate office space and equipment romote the ongoing scheme and to enrich the personal wealth of persons employ fated with RRA. Defendant ROTHSTEIN and other co-conspirators engaged in the below described conduct in order to facilitate the activities of the Enterprise and to conceal and promote the scheme to defraud investors. Defendant RIO(HSTEMI and other co-conspirators utilized funds illegally obtained through the "Ponzi" scheme to make political contributions to local, state and federal political candidates, in a manner designed to conceal the true source of such funds and to circumvent state and federal laws governing the limitations and contribution of such funds. Defendant ROTHSTEIN and other co-conspirators distributed lavish gifts, including exotic cars, jewelry, boats, loans, cash and bonuses, to individuals and to members of RRA in order to engender goodwill and loyalty and to create the appearance of a successful law firm. Defendant ROTHSTEIN and other co-conspirators made large charitable contributions to public and private charitable institutions, including hospitals and other legitimate charitable and nonprofit organizations, using funds derived from the "Ponzi" scheme. "Ponzi" scheme funds were also used to provide gratuities to high-ranking members of police agencies in order to curry favor with such police personnel and to deflect law enforcement scrutiny of ftRA( Th Defendant ROTHSTEIN and other co-conspirators utilized funds obtained through the "Ponzi" scheme in order to purchase controlling interests in restaurantstocated in the Southern District of Florida. Such restaurants were used in part as a mechanism to give gratuities to individuals, including politicians, business associates andNomeys, in order to goodwill and loyalty, as locations to solicit potential invest() feure locations for conspiratorial meetings. Defendant ROTHSTEIN and o nspirators associated with well known politicians, in public forums and elsewhere, in gain greater notoriety and to create the appearance of wealth and legitimacy. Such act calculated in part to enhance defendant ROTHSTEIN and other co-conspirators' abili6Y to solicit potential investors in the "Ponzi" scheme. Defendant itig; STEIN and other co-conspirators used funds derived from the "Ponzi" scheme to maintain the appearance of affluence and wealth, by purchasing expensive real and _ \\ personal prwerty, in order to convince potential investors of the legitimacy of RRA and of the purported investment opportunities. Defendant ROTHSTEIN purchased expensive real property, personal property, business interests, vessels, vehicles and other indicia of success and wealth. The government's evidence would establish that Defendant ROTHSTEIN and coconspirators, through the use of RRA as the criminal Enterprise, knowingly and intentionally engaged in the above-described pattern of racketeering activity in order to generate proceeds for their enrichment through various criminal activities, including mail fraud, wire fraud and money laundering. The government's evidence would establish that the activities of the Enterprise affected interstate commerce through the transmission of funds among and between financial insttions and across state boundaries, among other means. The Enterprise maintained offices in Broward County, Florida, and elsewhere and the pattern of racketeering activity emanated from the Southern District of Florida. Investors were solicited tawthrough wire and mail transmissions through the United States and elsewhere. In order to further the fraud scheme, Defendant ROTHSTEIN and other rs caused to be transmitted wire communications, in interstate and foreign commerce, including an interstate wire transfer sent from TD Bank to Gibraltar Bank on or about December 2, 2008 and an interstate wire transfer sent to TD Bank from JP= Chase on or about October 16, 2009. The proceeds derived from the "Ponzi" scheme were laundered through the fa maintained at several financial institutions in order to promote, carry on and conceal the criminal activities of RRA. Had the forfeiture portion of the case proceeded to trial, the government would have established, at least by a preponderance of the evidence, the standard of proof required for sentencing, that the properties listed for forfeiture in the forfeiture allegations of the Information and in the Bill of Particulars for Forfeiture, were properly sought for forfeiture because the defendant acquired or maintained an interest therein or were derived from proceeds obtained directly and indirectly through the commission of the above-described racketeering activity. The government would have further established that the properties were involved in and/or were traceable to the money laundering activity described above, and that such properties were also the proceeds of, or were derived from, the mail and wire fraud activity described above. The undersigned hereby stipulate and agree that the aforesaid facts are true and correct and that they encompass all of the necessary elements to establish the guilt of the defendant to the charges of Conspiracy to Violate the RICO Act, in violation of Title 18, United States Code, Section 1962(d); Conspiracy to Commit Money Laundering, in violation of Title 18, United States Code, Section 1956(h); Conspiracy to Commit Mail Fraud and Wire Fraud, in violation of Title 18, United States Code, Section 1349; and Wire Fraud, in violation of Title 18, United States Code, Section 1343. JEFFREY H. SLOMAN\ UNITED STATES ATTORNEY Date: 1/25/10 Paul F. Schwartz PAUL F. SCHWARTZ\ ASSISTANT UNITED STATES ATTORNEY Date: 1/25/10 Jeffrey N. Kaplan JEFFREY N. KAPLAN\ ASSISTANT UNITED STATES ATTORNEY Date: 25 Jan 10 Lawrence B. LaVecchio LAWRENCE B. LAVECCHIO\ ASSISTANT UNITED STATES ATTORNEY Date: 1/25/10 Mark Nurik MARK NURIK\ ATTORNEY FOR DEFENDANT Date: 1/25/10 SCOTT W. ROTHSTEIN SCOTT W. ROTHSTEIN\ DEFENDANT # UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION www.flsb.uscourtssov IN RE: CASE NO.: 09-34791-RBR ROTHSTEIN ROSENFELDT ADLER, P.A., CHAPTER 11 Debtor. # PRIVILEGE Gi n JAFFE. WEISSING. FISTOS & LEHRMAN Dated: February 23, 2011 Total of 159 pages # Privi e e Lo — Dat d 2-23-2011 Jaffe WeissinJt, Fistos & Lehrman | a | DATE | TO | FROM | DESCRIPTION | OBJECTION | | ----------- | ---------- | ------------- | --------------- | --------------------------------- | ----------------- | | 08076-08089 | 08/04/2009 | | | | | | | | | Spencer Kuvin | Transcript of Alfredo Rodriguez | | | 08311-08318 | 05/26/2009 | | Katherine Ezell | WPB-Confidential-General- | ' | | | | | | | Joi W/P Priv. | | 08319-08324 | 10/16/2009 | a | Amy Ederi | WPB-General-Confidential 14tatie | / Joint W/P Priv. | | 08398 | 09/01/2009 | | Kikka Claudio | C.M.A. vs. | Epstein, | | 08402 | 09/17/2009 | M | Paul Cassell | Report this as a parole violation | Joint W/P Priv. | | 08415 | 09/16/2009 | | Margaret Berk | Scanned document | from | | 08422 | 08/11/2009 | | Katherine Ezell | Subpoena directed | to the | | 10060 | 08/03/2009 | Adam Horowitz | Jacquie | Epstein-Depo-New York | Joint W/P Priv. | | 10069-10074 | 08/04/2009 | 7= | Spencer Kuvin | RE:Tra nscript | of Alfredo | | 10077-10079 | 08/06/2009 | | Merce | RE:Epstein vs. Jane Doe No.101 | | | 10099.10102 | 08/27/2009 | | Speyer Kuvin | RE: Epstein Depo | Joint W/P Priv. | | 10192 | 08/11/2009 | Adam Horowitz | | | | | | | | Jacquie | Trump Depo moved 08/18 to | | | 10194-10195 | 08/11/2009 | la in.tsion | Kikka Claudio | FW: Out of state subpoenas | Joint W/P Priv. | | 10264.10266 | 08/09/2009 | Adam Horowitz | Jacquie | RE:Epstein-Letter | regarding | # 11 Fistos&Lehrman | | DATE TO | FROM | DESCRIPTION | OBJECTION | | ---------------------- | -------------------------- | ------------------ | -------------------------------- | -------------------- | | 10279-10291 08/10/2009 | Adam Horowitz | Jacquie | RE: Epstein-Notice of production | | | 10372-10373 | 09/17/2009 | Katherine Ezell | RE: Leslie Wexner | t W/P Priv. | | 10490-10493 | 09/21/2009 | Amy Eden | FW: Epstein Depo | Orrn W/P Priv. | | 10592-10593 | 09/29/2009 | Katherine EzeU | RE: Leslie Wexner | | | | | | | t aill, | | 10604-10620 | 10/01/2009 | Katherine Ezell | FW:meeting w/ tty ft wexner | Joint W/P Priv. | | 10639.10643 | 10/06/2009 | Stuart Mermelstein | Meeting | xner Joint W/P Priv. | | 10700-10702 | 10/13/2009 Adam Horowitz | Jacquie | | Joint W/P Priv. | | 10724.1073 | 10/14/2009 Adam Horowitz | Jacquie Johnson | Epstein-depo of Alan Dershowitz | Joint W/P Priv. | | 10897 | 10/29/2009 | Stuart Mermelstei | Leslie Wexner | Joint W/P Priv. | | 10992-11005 | 06/22/2009 | Amy Ederi | RE:Regular Monthly Cong. Call | Joint W/P Priv. | | 11011-11021 | 06/23/2009 | Katherine Ezell | RE:Regular Monthly Cong. Call | Joint W/P Priv. | | 11026-11032 | 07/09/2009 | Spencer Kuvin | RE:Epstein | commissioner | | 11072-11074 | 07/28/2009 Bradley Edwards | Katherine Ezell | Possible witness | from | | 11166.11169 | 06/23/2009 Katherine Ezell | | | | | | | | RE:Article:Bear Stearns | Joint W/P Priv. | # Privilege Log — Dated -23-2011 # Jaffe. Weissing. Fistos&Lehrman | | DATE | TO FROM | DESCRIPTION | OBJECTION | | ---------------------- | ---------- | --------------- | ------------------------------ | ----------------- | | 11240-11245 | 06/22/2009 | Katherine Ezell | Article:Bear Stearns | Joint W/Vpriv. | | 11248.11250 | 06/22/2009 | Amy Ederi | Article:Bea r Stearns | Joint W/P Priv. | | 11255-11259 | 06/23/2009 | Katherine Ezell | USAO Chose | Edwards | | 11269-11281 06/30/2009 | | Stuart | | | | | | | RE:Epstein | Depo;pOssible | | | | | deponents | , | | 11316-11319 | 06/28/2009 | Katherine Ezell | Discussion about | possible | | 11332-11336 | 08/04/2009 | Spencer Kuvin | | | | | | | FW:Transcript | of Alfrefo | | | | Adam Horowitz | Edwards RE:Motion for | protective | | 11430-11434 | 08/27/2009 | Spencer Kuvin | Edwards Discussion | RE:Wexner | | 11443 | 09/17/2009 | Katherine Ezell | Wexner served subpoena | ■ Joint W/P Priv. | | 11541 11542 | 09/29/2009 | Katherine Ezell | RE:Leslie Wexner & Bob | Joint W/P Priv. | | 11551.11559 | 10/01/2009 | Spencer-Kuvin | RE:Meeting w.Stanely Arkin | Joint W/P Priv. | | 11585.11586 | 10/14/2009 | Adam Horowitz | RE:Epstein;Larry | Visoski | | 11675-11676 | 10/29/2009 | Stuart | | | | | | | RE:Leslie Wexner attorney info | Joint W/P Priv. | # Privilege Log — Dated 2-23-2011 # Jaffe, Weissing, FistOS & Lehrman | | DATE | TO | FROM | DESCRIPTION | OBJECTION | | ----------- | ---------- | ------------- | --------------- | ------------------------------- | --------------- | | 15981.15988 | 08/04/2009 | Spencer Kuvin | Jacquie | Attachment:Kellen & Trump | | | 15999.16007 | 08/05/2009 | Bert Patton | Jacquie | RE:Epstein Depo-New York | Joint W/P Priv. | | 16057.16065 | 08/06/2009 | Mercedes | Jacquie | Trump and Maxwell Dep dates | Joint W/P Priv. | | 15918.15949 | 08/04/2009 | Adam Horowitz | Jacquie | RE:Epstein Depo's 08/14,1748 in | | | 16066.16069 | 08/06/2009 | Adam Horowitz | Jacquie | Ma Trump convo | | | 16095-16098 | 08/11/2009 | Adam Horowitz | Jacquie | maxwensTrumo, r Convo | | | 15813.15814 | 10/29/2009 | Stuart | | | | | | | | | Weider Lawyers info | Joint W/P Priv. | | 15856 | 08/03/2009 | Adam Horowitz | Jacquie | Afin Depo-NY;2 Attachments | Joint W/P Priv. | | 15866-15881 | 08/03/2009 | Adam Horowitz | Jacquie) | Ep stein Depos 08/14,17,18 in | | | | | | | PDF of | | | 15893.15901 | 08/03/2009 | Kikka Claudio | Jacqu | Depo &subpoena notice for | | | 15360-15363 | 09/01/2009 | Jacquie | e | RE:Alan Dershowitz:Harvard Law | | | 15394-15397 | 09/09/2009 | Jacquie | Katherine Ezell | RE:E stein-De s of | Joint W/P Priv. | | 15413-15428 | 09/10/2009 | Adam Horowitz | Mamie | RE:Esptein-Notice of Prodcution | | | 15434-15437 | 09/10/2009 | Jacquie | Katherine Ezell | Notice Of Production from Non | | # Privilege Log—Da e 2-23-2011 Jaffe, Weissing. Fistos&Lehrman | | DATE | TO | FROM | DESCRIPTION | OBJECTION | | ----------- | ---------------------- | --------------- | --------------- | -------------------------------- | -------------------------- | | 15454-15475 | 09/15/2009 | Adam Horowitz | Jacquie | Critton's notice of depo;Epstein | | | 01465 | 07/13/2009 | Katherine Ezell | | Epstein | o /P Priv. | | 15485-15492 | 09/17/2009 | Jacquie | Mercedes | RE:Epstein Depo | t--A-- Joint W/P Priv. | | 15493.15500 | 09/18/2009 | Jacquie | Katherine Ezell | RE:Deposition | of Jean We Joint W/P Priv. | | | 15501-15555'09/18/2009 | Jacquie | Adam Horowitz | RE:Epstein De | Joint W/P Priv. | | 15556-15564 | 09/22/2009 | Jacquie | Margaret Berk | Epsteth | Joint W/P Priv. | | 15565-15575 | 09/25/2009 | Jacquie | Lisa | FW:Depo‘lon | of Jean Luc | | 15687-15688 | 10/01/2009 | Jacquie | Lisa | Depo of David Hart Rogers | Joint W/P Priv. | | 15692.15707 | 10/01/2009 | Jacquie | Katherine Ezell | FW:Meeting w/Sranley Arkin | Joint W/P Priv. | | 15708-15709 | 10/06/2009 | Jacquie | Mercedes | RE:Jane Does 2-8v. Epstein-Cross | | | 15033-15032 | 08/05/2009 | Jacquie | Mercedes | RE:Epstein-Depo for 8/17 | Joint W/P Priv. | | 15087-15093 | 08/06/2009 | Jacquie | Mercedes | RE:Epstein-Depo for 8/17 | Joint W/P Priv. | | 15094.15100 | 08/06/2009 | Jacquie | Kikka Claudio | RE:Epstein Depo-New York | Joint W/P Priv. | | 15109-15112 | 08/10/2009 | imp\* | Adam Horowitz | RE:Epstein | Depositions for | | | | | | 8/14,17,18 in NY & | ■ | # Privile e — Dated 2-23-2011 # =, Jaffe. Weissinit. Fistos & Lehrman | | DATE | TO | FROM | DESCRIPTION | | | ----------- | ---------- | ------------- | ------------- | ------------------------------ | --------------- | | | | | | RE: Ms. Maxwell Depo | | | 15122-15125 | 08/11/2009 | Jacquie | Kikka Claudio | | Joint W/P Priv. | | 15142-15158 | 08/11/2209 | | Kikka Claudio | FW:out of state subpoenas | Joint W/P Priv. | | 15166-15170 | 08/11/2009 | Jacquie | Kikka Claudio | RE:out of state subpoenas | Joint W/P Priv. | | 1517145172 | 08/11/2009 | Jacquie | Kikka Claudio | RE:Epstein | Joint W/P Priv. | | 15178-15182 | 08/12/2009 | Jacquie= | Kikka Claudio | RE:Epstein | Joint W/P Priv. | | 15306-15355 | 08/25/2009 | Jacquie | Kikka Claudio | FW:Epst in Depo Notices & Subs | | | 14951-14952 | 08/03/2009 | Jacquie | Kikka Claudio | RE: po-New York | Joint W/P Priv. | | 14954-14972 | 09/16/2009 | Adam Horowitz | Jacquie | e | | | | | | / a• | | | | 14979-14981 | 08/03/2009 | Jacquie | Kikka CI | | | | | | | | RE:Epstein Depo-New York | Joint W/P Priv. | | 14983-15015 | 08/04/2009 | Jacquie | Adam rrooitz | | | | 16501-16519 | 09/15/2009 | Adam Horowitz | 'ale | Epstein Hearing | Joint W/P Priv. | | 16520-16547 | 09/09/2009 | Spencer Kbvi | Jacquie | RE:Epstein-Deposition of Jane | | | 16355-16384 | 08/24/2009 | Adam Horowitz | Jacquie | Epstein Depo Notices and Subs | Joint W/P Priv. | | 16554-16568 | 09/16/2009 | Kikka Claudio | Jacquie | RE:Epsteln Depo | Joint W/P Priv. | # Iv' e e L 2 2 11 Fistos & Lehrman | | DATE | TO | FROM | DESCRIPTION | OBJECTION | | ----------- | ---------- | --------------- | --------------- | ------------------------------- | ---------------- | | 16574-16577 | 09/17/2009 | Adam Horowitz | Jacquie | RE:Epstein Depo | Joint W/P Priv. | | 16396-16398 | 09/01/2009 | Margaret | 'acquit | Alan Dershowitz | Joint W/P Priv.\_ | | 16578-16581 | 09/17/2009 | Katherine Ezell | Jacquie | RE:Depo | Joint W/P Priv. | | 16582-16585 | 09/18/2009 | Adam Horowitz | Jacquie | RE:Deposition of Jean pf Luc | | | 16585-16611 | 09/18/2009 | Adam Horowitz | Jacquie | RE:Epstein Depo | Joint W/P Priv. | | 16612-16439 | 09/18/2009 | Adam Horowitz | Jacquie | RE:Epstein Depo of Mark Epstein | Joint W/P Priv. | | 16440 | 08/18/2009 | Spencer Kuvin | Jacquie | RE:Epstein Sub to Bear Steam | Joint W/P Priv. | | 16740.16753 | 09/22/2009 | Margaret Berk | Jacquie | RE:Epstein Depos | Joint W/P Priv. | | 16443-16452 | 09/09/2009 | Katherine Ezell | Jacquie | \`RE:Epstein-Depos of | Joint W/P Priv. | | 16777-16786 | 09/30/2009 | Adam Horowitz | Jacquie Johnson | RE:Epstein | Joint W/P Priv. | | 16793-16794 | 10/01/2009 | Lisa | Jacquie | RE:Depo of David Hart Rogers | Joint W/P Priv. | | 16462-16477 | 09/10/2009 | Adam Horowi | Jacquie | RE:Epstein-Notice of Production | | | 16802-16823 | 10/02/2009 | Marga | 'Jacquie\_ | RE:Epstein depos | Joint W/P Priv. | | 16483.16486 | 09/10/2009 | zell | Jacquie | RE:Epstein-Notice of Production | | # Pri e e Lo — Dat d -23-2011 # Jaffe. Weissinll. Fistos & Lehrman | | DATE | TO | FROM | DESCRIPTION | OBJECTION | | ----------- | ---------- | -------------- | --------------- | ----------------------------- | --------------- | | 16874-16880 | 10/13/2009 | Adam Horowitz | Jacquie | Depo | Joint W/P Priv. | | | 10/14/2009 | Spencer Kuvin | Jacquie | RE:Epstein | Joint rrPil | | 16945 | 10/26/2009 | Kikka Claudio | Jacquie | RE:Epstein depos on 10/28 i | | | 17033-17034 | 10/26/2009 | Kikka Claudio | Jacquie | RE:Epstein depos on 10/28 IlL | | | 02065-02068 | 06/08/2009 | | Mercedes | FW:Epstein-Confirming AT&T | | | 02070 | 09/02/2009 | Jacquie | Spencer Kuvin | FW:E.stein-Depos of | | | 02071 | 08/18/2009 | Adam Horowitz | Jacquie | RE:Epstein Sub to Bear Sterns | Joint W/P Priv. | | 02072-02078 | 09/04/2009 | Jacquie | Spencer Kuvin | FW:E .stein-Depoos of | | | 03466-03468 | 05/14/2009 | Spencer Kuvin | Edwards | RE:Actvity in Case 9:08-cv | | | 02301.02302 | 09/09/2009 | Paul Cassel | | FW:Epstein | Joint W/P Priv. | | 03122.03123 | 06/10/2009 | Adam Horowitz | Bradley | FW: Motion to Dismiss | Joint W/P Priv. | | 02805-02806 | 05/26/2009 | Susan Stirling | Katherine Ezell | RE:WPB-Confidential-Genereal | | | 02670-02671 | 10/21/2009 | | Spencer Kuvin | FW:Subpoena Info | Joint W/P Priv. | | 02517-02519 | 10/02/2009 | Bradley | Katherine Ezell | FW:Meeting w/Stanley Arkin | Joint W/P Priv. | Jane, wetssInt tistos ist Lehrman | | DATE TO | FROM | DESCRIPTION | OBJECTION | | ----------- | ------------------------ | ----------------------- | ----------------------------------- | ---------------- | | 02614-02617 | 08/05/2009 | Kikka Claudio | FW:Proposal Request | Joint W/P Priv. | | 15702-15704 | 10/02/2009 | Katherine Ezell | FW:Meeting w/Stanley Arkin | Joint W/P PrIS, | | 15581.15585 | 09/28/2009 | Amy Ederi | FW:Epstein Depo | ,Toint W/P Priv. | | 15431.15433 | 09/10/2009 Adam Horowitz | Jacquie | RE:Epstein-Notice of Production | | | | | | from Non Parties | "K\`:!-\_ | | 15797-15798 | 10/14/2009 Spencer Kuvin | | RE:Epstein | Joint W/P Priv. | | 11560-11562 | 10/02/2009 | Katherine | Jacqule FW:MeetIng vy/Stanley Arkin | Joint W/P Priv. | | 11444-11448 | 09/28/2009 | Amy Ederi | FW:Epsteln Deno | Joint W/P Priv. | | 05823 | 09/04/2009 Adam Horowitz | Jacquie | RE:teteine- | Joint W/P Priv. | | 05832 | 09/08/2009 Adam Horowitz | Jacquie Johnso , | RE-:Epstein | | | 05838 | 09/08/2009 Jacquie | Jack | \\\`‘,/ | | | | | | RE:Epstein | Joint W/P Priv. | | 05847 | 09/09/2009 Jacquie\_ | Katherine Ezell | RE:Epstein | Joint W/P Priv. | | 05859 | 07/23/2009 | Edwards Katherine Ezell | RE:Epstein | Joint W/P Priv. | | 65863-05864 | 07/23/2009 | Edwards Katherine Ezell | RE:Epstein | Joint W/P Priv. | | 05886-05887 | 07/ 24/2009 | Katherine Ezell | RE:Epstein | Joint W/P Priv. | | | DATE TO | FROM | DESCRIPTION | OBJECTION | | ----------- | ------------------ | --------------- | ----------- | --------------- | | 05902-05903 | 07/28/2009 | Katherine Ezell | RE:Epstein | Joint W/P Priv. | | 05906-05907 | 07/28/2009 | Katherine Ezell | RE:Epstein | Joint W/P PrIv. | | 05912 | 08/27/2009 | Spencer Kuvin | RE:Epstein | Joint W/P Priv. | | 05928-05930 | 07/28/2009 | Katherine Ezell | RE:Epstein | Joint W/P Priv. | | 05933.05934 | 09/18/2009 | Spencer Kuvin | RE:Epstein | Joint W/P Priv. | | 05936 | 09/18/2009 | Spencer Kuvin | RE:Epstein | Joint W/P Priv. | | 05938 | 09/18/2009 | Adam Horowitz | RE:Epst | Joint W/P Priv. | | 05940-05941 | 09/18/2009 | Spencer Kuvin | ,ttit | Joint W/P Priv. | | 05951 | 05/29/2009 | Spencer Kuvin | stein | Joint W/P Priv. | | 05957-05960 | 09/09/2009 | Kikka CI | RE:Epstein | Joint W/P Priv. | | 05970-05971 | 10/21/2009 Jacquie | Margaret | RE:Epstein | Joint W/P Priv. | | 05982-05983 | 10/28/2009 | Spencer Kuvin | RE:Epstein | Joint W/P Priv. | | 05993-05994 | 09/09/2009 ands | Adam Horowitz | RE:Epstein | Joint W/P Priv. | | 05997 | 08/06/2009 | Kikka Claudio | RE:Epstein | Joint W/P Priv. | | | | gm, | Jane. weissma.mm mstos a Lenrman | | | ----------- | ------------------------- | ------------------ | ----------------------------------------------------------------------------------------- | ----------------- | | | DATE | FROM TO | DESCRIPTION | OBJECTION | | 01029 | 10/08/2009 | Carolyn | Brian Ryalls | Joint W/P P v. | | 07707 | 09/03/2009 BradleyEdwards | Kikka Claudio | RE:Regarding:C.M.A. vs. Epstein. Et al.(Filerf 281849) | Joint | | 07708.07709 | 06/22/2009 | Amy Ederi | RE:Regular Monthly Cong. Call | Jo W/P Priv. | | 07734 | 07/24/2009 | | RE:Release | point W/P Priv. | | 07218-07219 | 10/02/2009 | Katherine Ezell | RE:Meeting w/Stan | Arm Joint W/P PS. | | 06861-06863 | 05/12/2009 | Katherine Ezell | RE:Jane Doe II v. Epstein' | Joint W/P Priv. | | 06876.06879 | 05/12/2009 7= | Stuart Mermelstein | RE:Jane Doe 11 v. Epstein | Joint W/P Priv. | | 06891-06897 | 05/12/2009 | Katherine Ezell | PE•Jane are II v. Epstein | Joint W/P Priv. | | 06901 | 09/11/2009 | Mercedes | Re:Jane Doe No. 101 & Jane Doe No. 102 vs. Epstein-Cross Notice Of Depos | Joint W/P Priv. | | 06902 | 09/15/2009 | Mercedes Estrada | RE: Jane Doe No.101 & Jane Doe NO.102 vs. Epstein | Joint W/P Priv. | | 06903 | 09/04/2009 | Mercedes | RE: Jane Doe No.101 & Jane Doe NO.102 vs. Epstein-Cross-Notice of Taking Video Deposition | Joint W/P Priv. | | 06806-06807 | 09/09/2009 | Adam Horowitz | RE:Epstein | Joint W/P Priv. | | 06712 | 10/19/2009 | Kikka Claudio | RE: Igor Zinoview depo | Joint W/P Priv. | | 06713-06714 | 09/15/2009 | Robert Josefberg | RE:Epstein | Joint W/P Priv. | Jane. weissma.mm mstos a Lenrman nue. weissint p ristos at tenrrodo | | DATE | TO | FROM | DESCRIPTION | OBJECTION | | ----------- | ---------- | --------------- | ------------------ | ------------------------------- | --------------- | | 06720-06727 | 10/14/2009 | | Jack r | RE: Igor Zinoview depo | Joint W/P Priv. | | 06728 | 09/09/2009 | | Kikka Claudio | RE:Epstein | Joint_W/P Priv. | | 06711 | 09/09/2009 | Kikka Claudio | | RE:Epstein II, I | | | 06472 | 05/08/2009 | Spencer Kuvin | | RE:FYI Epstein Depo l | Joint W/P Priv. | | 06460-06464 | 05/08/2009 | | Spencer Kuvin | RE:FYI Epstein De | Joint W/P Priv. | | 06455.06459 | 05/08/2009 | Spencer Kuvin | | RE:FYI Epste: | Joint W/P Priv. | | 06448.06452 | 05/08/2009 | Spencer Kuvin | | RE:FYI Epstein Depo | Joint W/P Priv. | | 06420-06427 | 05/08/2009 | Spencer Kuvin | | RE:FYI Epstein Depo | Joint W/P Priv. | | 06416.06419 | 05/08/2009 | Spencer Kuvin | | RE:FYI Epstein Depo | Joint W/P Priv. | | 05925.05926 | 07/28/2009 | Katherine Ezell | Edwards | FW:Epstein | Joint W/P Priv. | | 05883-05584 | 07/24/2009 | Katherine Ezell | | RE:Epstein | Joint W/P Priv. | | 05022-05025 | 09/10/2010 | Adam Horowitz | | | | | | | | Jacoute | RE:Epstein-Notice of Production | | | 04724.04725 | 05/27/2009 | | Katherine Ezell | RE:Epstein Cases-depostions in | | | | | .4, ,,,L, | | | | | | DATE | Ta \_\_ | FROM | DESCRIPTION | OBJECTION | | | 06/11/2009 | Brad | Katherine W. Ezell | June 10th hearing-WPB | | | | 06/26/2009 | Amy Ederi | Brad | June 25th hearing-WPB- | Joint-privilege | Jane Weissin: vistos a nrman | | DATE | TO | FROM | DESCRIPTION | OBJECTION | | ----------- | ---------- | ------------------------- | ------------------ | ----------------------------- | --------------- | | 07030 | 09/22/2009 | J. | Spencer Kuvin | L.M. v. Epstein — defendant, | | | | | | | Jeffrey Epstein's response to | | | 07090-07091 | 9/29/2009 | J. | Katherine W. Ezell | Leslie Wexner | | | 07092 | 10/29/2009 | Stuart | | | | | | | | 1 | Leslie Wexner | NOW-privilege | | 07093 | 09/17/2009 | J. | Katherine W. Ezell | Leslie Wexner | Joint-privilege | | 01484 | 05/21/2009 | Robert C. | | | | | | | | J. | Epstein | Joint-privilege | | 01503 | 08/24/2009 | Spencer Kuvin | 1. | Epstein | Joint-privilege | | 01517 | 09/18/2009 | Adam Horowitz; | | | | | | | | 1. | Epstein | Joint-privilege | | 01514 | 08/26/2009 | Spencer Kuvin | 1 | E\$tein | Joint-privilege | | 01515 | 08/27/2009 | Spencer Kuvin | 1 | Epst!-n | Joint-privilege | | 01477 | 07/21/2009 | Adam Horowitz; | | | | | | | | 1 Edwards | f Epst n | Joint-privilege | | 01489 | 08/03/2009 | Adam Horowitz | | | | | | | | | Epstein | Joint-privilege | | 07110.07112 | 09/25/2009 | | | | | | 07113-07114 | | Spencer Kuvin | J. | LM v EPSTEIN hearing 9/22/09 | Joint-privilege | | 07115-07116 | 09/25/2009 | J. | | | | | | | | Spencer Kuvin | LM v EPSTEIN hearing 9/22/09 | Joint-privilege | | 07145-07146 | 09/22/2009 | Adam Nom itz | J. | Mark Epstein | Joint-privilege | | 07211-07213 | 10/01/2009 | J. | Spencer Kuvin | Meeting with Stanley Arkin | Joint-privilege | | 07210 | 10/06/2009 | Sport\\ | | | | | | | Mermelstein; N. Robert c. | | | | | | | | Katherine W. Ezell | Meeting with Leslie Wexner | Joint-privilege | # Privilege Log — Dated 2-23-2011 | Jaffe, Weissing, Fistos & Lehrman | | | | | | | | --------------------------------- | ---------- | ------------------ | --------------------- | ----------------------------------------- | --------------- | --- | | | DATE | TO | FROM | DESCRIPTION | OBJECTION | | | | | J. [REDACTED] | | | | | | 07214-07215 | 10/01/2009 | Robert Josefsberg | C. Katherine W. Ezell | Meeting with Stanley Arkin | Joint-privilege | | | 07216-07217 | 10/02/2009 | [REDACTED] | J. Katherine W. Ezell | Meeting with Stanley Arkin | Joint-privilege | | | 07220-07223 | 10/01/2009 | Spencer Kuvin | [REDACTED] | Meeting with Stanley Arkin | Joint-privilege | | | 07224-07225 | 10/02/2009 | Katherine W. Ezell | [REDACTED] | Meeting with Stanley Arkin | Joint-privilege | | | 07226-07227 | 10/01/2009 | Robert Josefsberg | C. Spencer Kuvin | Meeting with Stanley Arkin | Joint-privilege | | | 07228-07229 | 10/01/2009 | [REDACTED] | J. Robert Josefsberg | C. Meeting with Stanley Arkin | Joint-privilege | | | 07280-07283 | 08/06/2009 | Adam Horowitz | [REDACTED] | J. Motion for protective order | Joint-privilege | | | 07633-07634 | 08/06/2009 | [REDACTED] | J. Kikka M. Claudio | Proposal Request | Joint-privilege | | | 07710-07733 | 06/23/2009 | Katherine Ezell | W. [REDACTED] | J. Regularly Monthly Cong. Call | Joint-privilege | | | 07740-07746 | 09/18/2009 | [REDACTED] | J. Adam Horowitz | Report this as a parole violation | Joint-privilege | | | 07748-07757 | 09/18/2009 | Adam Horowitz | [REDACTED] | J. Report this as a parole violation | Joint-privilege | | | 07913-07915 | 08/27/2009 | [REDACTED] | J. Spencer Kuvin | [REDACTED] | Joint-privilege | | | 07917-07918 | 08/27/2009 | Spencer Kuvin | Jacquie | [REDACTED] | Joint-privilege | | | 07965-07966 | 08/12/2009 | Katherine Ezell | W. [REDACTED] | J. Subpoena directed to the investigators | Joint-privilege | | | 07977-07978 | 10/09/2009 | [REDACTED] | J. Spencer Kuvin | Subpoena Info | Joint-privilege | | | 01716 | 09/15/2009 | Adam Horowitz | Elizabeth Villar | Epstein: Forensics/Investigations INVOICE | Joint-privilege | | | 01768 | 07/13/2009 | Richard Willits | [REDACTED] | J. Epstein Investigator | Joint-privilege | | | 01771-01772 | 08/06/2009 | Adam Horowitz | [REDACTED] | J. Epstein Investigator | Joint-privilege | | | 01931 | 08/11/2009 | [REDACTED] | J. Lisa | Alfredo Rodriguez | Joint-privilege | | Jane. weissing. FISTOS a Lenrman | | DATE | TO | FROM | DESCRIPTION | OBJECTION | | ----------- | ---------- | ------------- | ------------------ | ------------------------------------------ | --------------- | | 01998-01999 | 09/21/2009 | Adam Horowitz | Margaret Berk | Correct Number — Epstein | | | 02021 | 05/14/2009 | J. | Mercedes C. | Doe v. Epstein | JointIJNvilege | | | | | | | ---...z. ,, | | 02044 | 09/04/2009 | Katherine W. | | | | | | | | J. | E.W., L.M. Doe v. Epstein — it:Vali:Allege | | | | | | | Letter from Bob Critton | i | | 102048 | 09/04/2009 | Robert C. | | | | | | | | J. | E.W., L.M. Doe v. Epst — | | | 02054 | 05/12/2009 | Spencer Kuvin | J. | Emailing Epstein deposition | | | 02062 | 10/05/2009 | J. | Amy Ederi | Epstein — Confirming AT&T Dial | | | | | | | in Tel. Conf. for\` Monday, | | | 02087 | 09/17/2009 | Spencer Kuvin | 1. | Epstein- Hearing | Joint-privilege | | 02140 | 08/04/2009 | Spencer Kuvin | J. | Epstein Depo — New York | Joint-privilege | | 02147-02149 | 09/21/2009 | J. | Amy Eden | Epstein Depo | JoInt-privilege | | 02174 | 07/20/2009 | Adam Horowitz | 1. Edwards | t Epstein Matter — Cross Notice of | | | 02209-02210 | 07/01/2009 | Bert Patton | William). Berger | Epstein v. State of Florida — | | | 02215-02217 | 07/24/2009 | J. | Mercedes C. | Epstein | Joint-privilege | | 02290 | 09/18/2009 | | | | | | | | J. | Spencer Kuvin | Epstein | Joint-privilege | | 02355.02356 | | Mercedes C. | | | | | | | | Susan K. Stirling | Hearing taken on 06/10/09 | | | 02362.02363 | 06/09/2009 | | | | | | | | Spencer Kuvin | Katherine W. Ezell | Hearing to Un-seal | Joint-privilege | | 02374.02375 | | Jack | 1. | Igor Zinoview depo | Joint-privilege | # Privii lo — Dated 2-23-2011 illild Jaffe, I sit s et hrmn | | DATE | TO | FROM | DESCRIPTION | OBJECTION | | ---------------------- | ---------- | -------------- | ------------------ | --------------------------------- | ----------------- | | 02420-02421 05/08/2009 | | J. | Mercedes C. | Jane Doe II v. Epstein | Joint-privilege | | 02435 | 09/15/2009 | J. | Lisa | Jane Does v. Epstein | Joint-privilege \_ | | 02438 | 09/18/2009 | J. | Adam Horowitz | Jeffrey Epstein DCII W35755 | Joint-privilege | | 02462 | 09/22/09 | Spencer Kuvin | BradleyJ. | L.M. v. Epstein — Defendant, | | | | | | | Plantiff L.M."s Motion for | | | 02476-02477 | 09/25/2009 | S. encer Kuvin | J. | 1M v EPSTEIN hearing | Joint-privilege | | 02516 | 10/06/2009 | 1. | Katherine W. Ezell | Meeting with Leslie Wexner | Joint-privilege | | 02554-02559 | 08/03/2009 | Adam Horowitz | J. | NEW ASSIGNMENT — NEW | | | 02584 | 08/11/2009 | J. | Kikka M. Claudio | Out of state subpoenas | Joint-privilege | | 02618 | 08/04/2009 | J. | Kikka M. Claudio | Proposal Request | Joint-privilege | | 02627-02628 | 09/18/2009 | J. | Adam Horowitz - | Report this as a parole violation | Joint-privilege | | 02672 02673 | 10/09/2009 | Spencer Kuvin | J. | Subpoena Info | rJoint-privilege | | 02727 | 08/03/2009 | Spencer Kuvin | J. | Transcript of Alfredo Rodriguez | | | 02896 | 06/08/2009 | J. | Spencer Kuvin | Hearing to Unseal | Joint-privilege | | 03009-03010 | 08/07/2009 | Adam Horowitz | Jacquie | | | | | | | | Motion to stay | Joint-privilege | | 03028-03029 | 09/21/2009 | ,' J. | Adam | Mark Epstein | Joint-privilege | | 03038 | 10/06/2009 | J. | Stuart Mermelstein | Meeting with Leslie Wexner | Joint-privilege | | \` 03131-03132) | 08/06/2009 | Adam Horowitz | 1. | Epsteins assets | Joint-privilege | nia fie Weissine. . Fistos &Lehrman # Pri Ile Lo - | M | DATE | TO | FROM | DESCRIPTION | OBJECTION | | ----------- | ----------- | ------------- | ------------------ | ------------------------------- | ----------------------------------- | | 03243.03244 | 09/09/2009 | J. | Adam Horowitz | EPSTEIN | Joint-privilege | | 03397-03400 | 09/29/2009 | Adam Horowitz | 1 | Activity in case 9:08-cv-80119- | Joint-privilege | | 03407-03414 | 09/29/2009 | J. | Adam Horowitz | Activity in case 9:08-cv-80119- | | | 03451-03452 | 05/14/2009 | J. | Spencer Kuvin | Activity in Case 9:08-cv-80893- | | | 03477-03479 | 05/15/2009 | 1 | Spencer Kuvin | Activity in Case 9:08-cv-80893- | | | 03619-03627 | 09/ 15/2009 | 1 | Spencer Kuvin | BB v. E | EW v. Epstein Joint-privilege | | 03631-03633 | 09/15/2009 | Jac. we | William J. Berger | BB v | st in/EW v. Epstein Joint-privilege | | 03646-03656 | 10/19/2009 | J. | Katherine W. Ezell | Bill | Subpoena & Depo | | 03677-03687 | 07/08/2009 | J. | Adam HoroWitz., | | | | | | | | Can you send | me those | | 03719-03736 | 09/04/2009 | J. | Spencer Kuvin | CMA — depo notices attached. | Joint-privilege | | 03840.03847 | 08/02/2009 | Stuart | | | | | 03938.03939 | 09/29/2011 | Katherine W. | | | | | | | | J. | Deposition of Bil | Joint-privilege | | 03943-03945 | 09/18/2009 | Adam Horowitz | Jacquie | Deposition of Jean Luc Bruhnel | Joint-privilege | | 02911-02912 | 09/15/2009 | , J. | Jack P. | Igor Zinoview depo | Joint-privilege | | 02939 | 07/14/2009 | J. | Adam Horowitz | Jane Does 2-7 v. Epstein | Joint-privilege | | 02977 | 10/16/2009 | Katherine | | Leslie Wexner | Joint-privilege | # Privilege Lo — ated 2-23-2011 . Jaffe. Weissing, , Fistos & Lehrman | | DATE | TO | FROM | DESCRIPTION | OBJECTION | | ----------- | ---------- | ----------------------- | ----------------------- | ------------------------------------------------ | --------------- | | | | Ezell | | | | | 02978 | 10/29/2009 | [REDACTED] | J. Stuart Mermelstein | Leslie Wexner | Joint-privilege | | 02994 | 06/10/2009 | [REDACTED] | J. Mercedes | C. Preservation of evidence | Joint-privilege | | 07060 | 10/16/2009 | Sid [REDACTED] | J. [REDACTED] | L.M. v. Epstein | Joint-privilege | | 06202 | 07/13/2009 | Richard Willits | Bradley J. [REDACTED] | Scheduling various depositions regarding Epstein | Joint-privilege | | 06409-06415 | 04/15/2009 | [REDACTED] | J. Katherine W. Ezell | FYI | Joint-privilege | | 06428-06447 | 05/06/2009 | Spencer Kuvin | [REDACTED] | FYI | Joint-privilege | | 06453-06454 | 04/15/2009 | Spencer Kuvin | J. [REDACTED] | FYI | Joint-privilege | | 06465-06471 | 04/15/2009 | Katherine W. Ezell | J. [REDACTED] | FYI | Joint-privilege | | 06476-06490 | 05/08/2009 | [REDACTED] | J. Spencer Kuvin | FYI | Joint-privilege | | 06630-06632 | 09/09/2009 | Spencer Kuvin | [REDACTED] | Hearing to Un-seal | Joint-privilege | | 06636-06639 | 09/09/2009 | [REDACTED] | J. Robert C. Josefsberg | Hearing to Un-seal | Joint-privilege | | 06702-06705 | 09/16/2009 | [REDACTED] | J. Kikka M. Claudio | Igor Zinoview & Tommy Matola depos | Joint-privilege | | 06706-06708 | 10/14/2009 | [REDACTED] | J. Kikka M. Claudio | Igor Zinoview depo | Joint-privilege | | 06715-06719 | 10/09/2009 | Jack P. [REDACTED] | J. [REDACTED] | Igor Zinoview depo | Joint-privilege | | 06729-06735 | 10/13/2009 | [REDACTED] | J. Jack P. [REDACTED] | Igor Zinoview depo | Joint-privilege | | 06763 | 08/19/2009 | [REDACTED] | J. Stuart Mermelstein | IME's | Joint-privilege | | 06764-06766 | 09/10/2009 | [REDACTED] | J. Stuart Mermelstein | IME's | Joint-privilege | | 06770-06781 | 09/10/2009 | Stuart Mermelstein | Bradley J. [REDACTED] | IME's | Joint-privilege | | 06811-06812 | 08/20/2009 | Katherine W. [REDACTED] | J. [REDACTED] | Is Mark Epstein JE's brother? | Joint-privilege | # Privilege Log — Dated 2-23-2011 al Matte, a w sAjgaMEU isit tos moan | | DATE | TO | FROM | DESCRIPTION | OBJECTION | | ----------- | ---------- | ----------------- | ------------------ | ---------------------------- | --------------------- | | 06817-06819 | 09/23/2009 | Adam Horowitz | J. | Is your client being deposed | | | 06820-06822 | 07/02/2009 | | | | | | | | | Margaret Berk | Jane Doe 2 | ) v. Epstein Jo ilege | | 06841-06r0 | | | Spencer Kuvin | Jane Doe II v. Epstein | privilege | | 06864-06875 | 05/12/2009 | S encer Kuvin | J. | Jane Doe II v Epstein | Joint-privilege | | 06880-06890 | 05/12/2009 | J. | Katherine W. Ezell | Jane Doe II v. Epstein | Joint-privilege | | 06898-06900 | 05/12/2009 | J. | Stuart Mermelstein | Jane Doe li v. E | e n | | 06933-06934 | 07/14/2009 | Adam Horowitz | J. | Jane Does 2-ittz,E | ein Joint-privilege | | 06937-06938 | 10/05/2009 | Spencer Kuvin | Jacquie | Jane poes.2-8 | v. Epstein — Cross | | 06944.06952 | 09/22/2009 | J. | Adam Horowitz | Jeffrey Epstein DCN W35755 | Joint-privilege | | 16107 | 08/11/2009 | Adam Horowitz | i Jacquie Johnson | Maxwells deposition | Joint-privilege | | 16123.16124 | 08/11/2009 | Kikka M. Claudio | Jacquie Johnson | Maxwells deposition | Joint-privilege | | 16799.16801 | 10/02/2009 | Robert C. | | | | | | | | Jacquie JohnSon | Meeting with Stanley Arkin | Joint-privilege | | 02947-02948 | 08/03/2009 | Spencer Kuvin | Jacquie | Epstein Depo — New York | Joint-privilege | | 02891-20906 | 10/01/2009 | 1. | Katherine W. Ezell | Meeting with Stanley Arkin | Joint-privilege | | 20880-20882 | 10/02/2009 | J. | Katherine W. Ezell | Meeting with Stanley Arkin | Joint-privilege | | | 07/02/2009 | William J. Berger | Spencer Kuvin | Ew 09-22784 certedca | Joint-privilege | | | 06/10/2009 | J. | Katherine W. Ezell | Hearing to Un-seal | Joint-privilege | | | 09/15/2009 | Adam Horowitz | Jacquie | Epstein Hearing | Joint-privilege | | | 07/30/2009 | Adam Horowitz | Jac. uie | Epstein Depositions | Joint-privilege | | 01331 | 06/30/2009 | Stuart | J. | Epstein depositions | Joint-privilege | aff WeIs in •Fistos&Lehrman # -23-2011 | | DATE | TO | FROM | | DESCRIPTION | OBJECTION | | ----------- | ---------- | ------------- | ------------- | --- | ------------------------------ | --------------- | | 01319 | 08/11/2009 | Adam Horowitz | la ui | | | | | 01316 | 08/27/2009 | Spencer Kuvin | | | | Joint-privilege | | 01314 | 10/30/2009 | Stuart | | | | | | | | | Jacqu | | Epstein Depo of Wexner | Joint-privilege | | 01298 | 05/26/2009 | J. | Adam Horowitz | | Epstein cases — depositions in | | | 01294 | 08/10/2009 | Jack P. | 1. | | Epstein Assets | int-privilege | | 01273 | 07/13/2009 | Katherine W. | | | | | | | | | 1. | | Epstein 2255 claims | Joint-privilege | | 01250 | 05/13/2009 | J. | Mercedes | C. | | | | | | | | | Epstein | Joint-privilege | | 01246 | 04/08/2009 | J. | Mercedes | C. | Epstein —Ti to onference | Joint-privilege | | 01233-01234 | 07/31/2009 | 1 | Mercedes | C. | Epstein — Monday, 8/3/09 — | | | | | | | | Monthly call in telephone | | | | | | | | (877) 468.2136 — participant | | | 01224 | 06/16/2009 | J. | Mercedes | C. | Epstein — Monday, 8/3/09 — | | | | | | | | Monthly call in telephone | | | | | | | | (877) 468-2136 — participant | | | 01185 | 10/30/2009 | J. | Mercedes | C. | Epstein — Confirming AT&T dial | | | 01186 | 10/02/2009 | J. | Mercedes | C. | Epstein — Confirming AT&T Dial | | | | | | | | in Tel. Conf. for Monday, | | | 01187 | 05/19/2009 | Bradley J. | | | | | | | | | Mercedes | C. | Epstein — Confirming AT&T Dial | | | | | | | | in Telephone Conference for | | # privilege log— Dated 2-23-2011 Jane. weissing, Fistos St Lenrman | | DATE | —TO | FROM | DESCRIPTION | OBJECTION | | ----------- | ---------------------- | ------------- | ------------------ | --------------------------------- | ------------------------------- | | 01188 | 05/12/2009 | J. | Mercedes | C. Epstein — Confirming AT&T Dial | | | | | | | in Telephone Conference | for | | 01189 | 09/08/2009 | Illi J. | Diana Yarzabal | Epstein — Confirming AT&T Dial | | | | | | | in Telephone Conference | for | | 01095.01096 | 04/15/2009 | Spencer Kuvin | M | | | | 01045 | 07/23/2009 | J. | Richard Willits | CMA vs. Epstein | Joint-privilege | | 01649 | 07/08/2009 | J. | Mercedes | C. Epstein | Joint-privilege | | 01641 | 06/11/2009 | J. | Mercedes | C. Epstein | Joint-privilege | | 01639 | 05/29/2009 | J. | Mercedes | C. Ep2 | Joint-privilege | | 01619 | 10/28/2009 | J. | Spencer Kuvin | EpAtin | Joint-privilege | | 01660 | 07/22/2009 | J. | Adam Horowitz | Epstein | Joint-privilege | | 01666 | 04/20/2009 | Spencer Kuvin | 1. | Epstein | Joint-privilege | | 01671 | 07/23/2009 | Katherine W. | | | | | | | | J. | Epstein | Joint-privilege | | 01680 | 08/24/2009 | Jack P | J. | Epstein | Joint-privilege | | 04355-04358 | 09/04/2009 | Jack Scarola | | | | | | | | 1. | Epstein - Depos of | | | 04446 | 09/03/2009 | | Iliana Yarzabal | Epstein | Monday 8/3/09 - | | | | | | Monthly Call | in Telephone | | | 04200-04201 09/04/2009 | Braille | Katherine W. Ezell | Letter from | Bob Critton Joint W/P Privilege | | | 09/04/2009 | | Spencer Kuvin | Letter from | Bob Critton Joint W/P Privilege | | 04222-04223 | 09/04/2009 | | Barry | Letter from Bob Critton | Joint W/P Privilege | aJane, vveissine, i tistos & Lenrman | | DATE | TO | FROM | DESCRIPTION | OBJECTION | | ---------------------- | ---------- | ----------------- | ----------------- | ------------------------------ | ------------------- | | 04264 | 05/12/2009 | | Spencer Kuvin | Epstein Dew) | Joint W/P Privilege | | 04298-04299 | 09/16/2009 | Jacquie | Adam Horowitz | Depo of Epstein | Joint W/P Privilege | | 04304 | 09/08/2009 | Jacquie | Adam Horowitz | Epstein | Joint WP PS. | | 04335 | 10/30/2009 | | Robert Josefsberg | Epstein- Confirming AT&T Tel. | | | 04359.04360 | 09/04/2009 | Jacquie | Katherine Ezell | Depos of & | (Join' W/P Priv. | | 04365 | 09/15/2009 | Jacquie | Adam Horowitz | Epstein- Depo in New York | Joint W/P Priv. | | 04417 | 09/17/2009 | | Spencer Kuvin | Epstein- Hearing | Joint W/P Priv. | | 04423-04424 | 09/09/2009 | Jacquie | Adam Horowitz | Letter regarding Leslie Wexner | Joint W/P Priv. | | | | Spencer Kuvin | | Monthly Call in Tele. Conf, | Joint W/P Priv. | | | | Jacquie | Mercedes | Monthly Call in Tel. Conf. | Joint W/P Priv. | | 04491-04518 | 04/08/2009 | | Jack Scarola | Epstein- Tel. Conf. | Joint W/P PS. | | 04518 | 04/08/2009 | | Robert Josefsberg | Epstein- TelConf.- | Joint W/P Priv. | | 04524.04525 | 05/13/2009 | ' Katherine Ezell | I | Epstein Depo | Joint W/P Priv. | | 04580 | 10/14/2009 | Jacquie | Adam Horowitz | Depo of Larry Visoski | Joint W/P Priv. | | 04640.04641 10/14/2009 | | | Adam Horowitz | Depo of Larry Visoski | Joint W/P Priv. | | 04723 | 05/26/2009 | | Katherine Ezel | Epstein cases- Depos | Joint W/P Priv. | | 04726-04729 | 05/26/2009 | Adam Horowitz | | Epstein cases- Witness depos | Joint W/P Priv. | | 04750-04754 | 08/04/2009 | Spencer Kuvin | | Epstein depo- New York | Joint W/P Priv. | | 04763-04785 | 08/27/2009 | Spencer Kuvin | | Epstein Depo Notice | Joint W/P Priv. | | 04797.04799 | 09/18/2009 | Jacquie | Adam Horowitz | Epstein Depo | Joint W/P Priv. | | 04806.04813 | 07/28/2009 | Jacquie IIIII | Adam Horowitz | Epstein Depos in New York | Joint W/P Priv. | | 04819 | 07/30/2009 | jack • rola | Jacquie | Epstein Depos | Joint W/P Priv. | | 04831-04832 | 07/30/2009 | win | Jacquine | Epstein Depos | Joint W/P Priv. | | 04835-04836 | 07/25/2009 | Katherine Ezell | | Epstein Depos | Joint W/P Priv. | ffe Weisshit Fistos & Lehr | | DATE TO | FROM | DESCRIPTION | OBJECTION | | ------------------------- | -------------------------- | ----------------- | --------------------------- | ---------------- | | 04711 | 08/10/2009 | Jack | Epstein asserts | Joint W/P Priv. | | 04855.04858 | 08/18/2009 | Kikka Claudio | Epstein Depos | Joint W/P Pri v. | | 04861 | 07/24/2009 Lisa | Jacquie | Epstein Depos | Joint W/P Priv. | | 04876.04877 | 07/27/2009 | Spencer Kuvin | Epstein Depos | Joint W/P Priv. | | 04922.04923 | 09/16/2009 Adam Horowitz | Jacquie | Epstein Hearing | | | 04925.04926 -I-09/15/2009 | Adam Horowitz | Jacquie | Epstein Hearing/ X) | | | | | | 'V' I '? | | | 04929.04934 | 09/25/2009 | Adam Horowitz | Epstein Hearinjs y r | Joint W/P Priv. | | 04937-04938 | 09/15/2009 Adam Horowitz | Jacquie | Eps eftce Mg | Joint W/P Priv. | | 04969-04972 | 07/20/2009 Adam Horowitz | | Alfredo Rodriguez Depo | Joint W/P Priv. | | 05026-05027 | 09/10/2009 Adam Horowitz | Jacquie Johnson N | Notice of Production from Non | | | 05031 | 09/25/2009 | Spencer Kuvin | Epstein Order | Joint W/P Priv. | | 05037.05038 | 09/25/2009 | Sorter Kuvin | Epstein Order | Joint W/P Priv. | | 05042-05043 | 09/25/2009 Spencer Kuvinz- | Bradley | Epstein Order | Joint W/P Priv. | | 05046 | 09/25/2009 | Spener Kuvin | Epstein Order | Joint W/P Priv. | | 05074-05076 | 08/18/2009 Stuart | | | | | | | Jacquie | Epstein Sub. To Bears Stern | Joint W/P Priv. | # Privilege Log-\_ Dated 2-23- Fistos&Lehrman | | DATE | TO FROM | DESCRIPTION | OBJECTION | | ----------- | ---------- | --------------------------- | ------------------------------- | -------------------------------- | | 05100-05102 | 08/05/2009 | Mercedes | Improper Serving of Maxwell | Joint W/P Priv. | | 05105.05107 | 04/20/2009 | Spencer Kuvin | Hearing on Yellow Cab Objection | Joint W/P Priv. | | | 08/06/2009 | Adam Horowitz Kikka Claudio | Address for Nadia | rcinkova "IP Priv. | | | 09/09/2009 | Adam Horowitz | Motion for Protective Order\] | nt W/P Priv. | | 05157-05158 | 09/10/2009 | Adam Horowitz | Motion for Protecti | Or Joint W/P Priv. | | 05167.05168 | 05/29/2009 | Margaret Berk | Spencer Cross-E | Joint W/P Priv. | | 05171-05172 | 05/29/2009 | Mercedes | Transcripts | Joint W/P Priv. | | 05201.05202 | 09/10/2009 | Adam Horowitz | Rides on Doe no. 4 | Joint W/P Priv. | | 05222-05223 | 07/10/2009 | Katherine Ezell | File case | Joint W/P Priv. | | 05226 | 07/10/2009 | Spencer Kuvin | Epstein Sth | Amendment rights Joint W/P Priv. | | 05229 | 07/10/2009 | Adam Horowitz | Motions to Compel | Joint W/P Priv. | | 05232-05233 | 07/10/2009 | Adam Horowitz | Motions fully briefed | Joint W/P Priv. | | 05247 | 07/23/2009 | Katherine Ezell | Answers to the 1" set of ROGS | Joint W/P Priv. | | 05251-05252 | 07/24/2009 | Katherine Ezell | Depo dates | Joint W/P Priv. | | 05258 | 07/25/2009 | Katherine Ezell | | | | | — | \_ \\ | | | | 05265.05266 | 07/22/2009 | Adam Horowitz Spencer Kuvin | Alfredo Rodriguez depo | Joint W/P Priv. | **Privilege Log - Dated 2-23-2011** **Farmer, Jaffe, Weissing, [REDACTED], Fistos & Lehrman** | | DATE | TO | FROM | DESCRIPTION | OBJECTION | | ----------- | ---------- | ------------------- | ------------------- | ------------------------------------------------------------------- | --------------- | | 05286-05287 | 07/28/2009 | Katherine Ezell | [REDACTED] | Switzerland Witness regarding training of little girls as sex traps | Joint W/P Priv. | | 05293-05294 | 07/28/2009 | Katherine Ezell | [REDACTED] | Calling Switzerland witness | Joint W/P Priv. | | 05326-05327 | 08/24/2009 | [REDACTED] | Spencer Kuvin | Emails searchable | Joint W/P Priv. | | 05331 | 08/06/2009 | Kikka Claudio | [REDACTED] | Epstein address | Joint W/P Priv. | | 05334-05335 | 05/29/2009 | [REDACTED] | Mercedes [REDACTED] | TV Interview that is too explicit | Joint W/P Priv. | | 05347 | 08/24/2009 | [REDACTED] | Spencer Kuvin | Seeking Computers | Joint W/P Priv. | | 05350 | 08/10/2009 | Kikka Claudio | [REDACTED] | Current address for Nadia Marcinkova | Joint W/P Priv. | | 05353-05354 | 09/09/2009 | Katherine Ezell | [REDACTED] | Distribution of Costs | Joint W/P Priv. | | 05367 | 09/10/2009 | Jacquie [REDACTED] | [REDACTED] | Voicemail | Joint W/P Priv. | | 05373-05374 | 08/10/2009 | Kikka Claudio | [REDACTED] | Supoenas for depos | Joint W/P Priv. | | 05391-05393 | 04/20/2009 | Spencer Kuvin | [REDACTED] | Yellow Cab stuff | Joint W/P Priv. | | 05400-05401 | 10/19/2009 | Adam Horowitz | [REDACTED] | Religious Dildo Washer | Joint W/P Priv. | | 05414-05415 | 08/10/2009 | Kikka Claudio | [REDACTED] | [REDACTED] current address | Joint W/P Priv. | | 05437-05439 | 04/20/2009 | [REDACTED] Edwards | Spencer Kuvin | Yellow Cab stuff | Joint W/P Priv. | | 05444-05445 | 08/10/2009 | [REDACTED] | Kikka Claudio | Setting Depos | Joint W/P Priv. | | 05451 | 05/29/2009 | Mercedes [REDACTED] | [REDACTED] | Motion for Status Conf. | Joint W/P Priv. |