Draft: efta02771872 · The Epstein Index

IN THE CIRCUIT COURT OF THE 111 thENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA¶

CASE NO.: 502009CA040800XMCCMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff,¶

VS.¶

SCOTT ROTHSTEIN individually, J. individually, and L.M., individually,¶

Defendant,¶

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REQUEST FOR PRODUCTION TO COUNTER-DEFENDANT (PUNITIVE DAMAGES'¶

J. by and through his undersigned counsel, and pursuant to¶

Florida Rule of Civil Procedure 1.350, hereby requests Production from JEFFREY EPSTEIN of the documents and Things described below for the purpose of inspection, copying, photographing, testing or sampling and any other purposes permitted under the Florida Rules of Civil Procedure at the office of the undersigned within thirty (30) days of service of this request.¶

DEFINITIONS AND INSTRUCTIONS:¶

A. The tam "documents" as used in this Request is defined as including, but not limited to, the original and any non-identical copy (which is different from the original because of notations on such copy or otherwise) of all correspondence, telegrams, teletype messages, contacts (including drafts, proposals and any and all exhibits thereto), draft minutes and addenda, memoranda (including inter and infra office memoranda), memoranda for file, pencil jottings, diary entries, desk calendar entries, reported recollections and other written form of¶

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notation of events or intentions, transcripts and recordings of conversations and telephone calls, books, records, photographs, reports, tabulations, charts, books of account, ledgers, invoices, fmancial statements, purchase orders, receipts, canceled checks and other documentary material not subject to attorney/client privilege, together with any documents thereto, or enclosures therewith. The term "document" shall include data stored, maintained or organized electronically or magnetically through computer equipment, translated, if necessary, by you into comprehensible form.¶

The term "document includes the complete file'or files within which any items constituting a "document" are found, including all such files within your possession, custody or control wherever located, including any branch, local or main offices, and including not only the contents of such files but also the folder, jacket, envelope or other container in which the file is kept or stored.¶

Each draft, final document, original, reproduction, and each signed and unsigned document and every additional copy of such document where such copy contains any commentary, note, notation or other change whatsoever that does not appear on the original or on the copy of the one document produced shall be deemed and considered to constitute a separate document.¶

B. As used herein, the following words shall have the meanings indicated:¶

(i) "Plaintiffs" in addition to the Plaintiffs named in the full style of this action, shall include any attorney, officer, director, employee or agent of¶

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Plaintiffs or any other persons acting under Plaintiffs' control or supervision, or in concert or association with Plaintiffs.
¶

(ii) "Defendant", in addition to the Defendant named in the full style of this action, shall include any attorney, officer, director, employee or agent of the Defendant or any other persons acting under Defendant's control or supervision, or in concert or association with the Defendant.
(iii) "You" shall include the person (as defined below) or party to whom this Request is addressed and additionally, all of his/her/its agents, officers, directors, employees, and other persons acting or purporting to act on his/her/its behalf; and includes also, to the extent there is no actual privilege, his/her/its attorneys.
(iv) "Person" means any natural individual in any capacity whatsoever or any entithaprganization, including divisions, departments, and other tmibesein, and shall include, but not be limited to, public or private (cvrporattons, partnerships, joint ventures, voluntary or unincorporated O associations, organizations, proprietorships, trusts, estates, governmental agencies, commissions, bureaus, or departments, and the agents, servants and employees of same.
(v) "Concerning" includes referring to, responding to, relating to, connected with, regarding, discussing, analyzing, showing, describing, reflecting, employing and constituting.
(vi) "Evidencing" means having a tendency to show, prove, or disprove.
(vii) "Communication" means any oral or written statement, dialogue, colloquy, discussion or conversation, and also means any transfer of thoughts or ideas between persons by means of documents and includes any transfer of data from one location to another by electronic or similar means.me 14/ i... )
(viii) "Including" shall mean including but not limited"
(ix) The words "and" and "or" as used herein shall be construed either disjunctively or conjunctively as required by the context to bring within the scope of this production request any answer that might be deemed outside its scope by another construction.
(x) "Related to" or "relating to" shall mean directly or indirectly, refer to, reflect, describe, pertain to, arise out of or in connection with, or in any wady, logically, or factually be connected with the matter ( discussed.

C. ete's quest calls for production of all responsive documents in your possession, custody •r • 0, •i without regard to physical location of said document.¶

Control means in your possession, custody or control or under your direction, and includes in the possession, custody or control of those under the direction of you and your employees, subordinates, counsel, accountant, consultant, expert, parent or affiliated corporation, and any person purporting to act on your behalf.¶

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D. All documents shall be originals unless otherwise indicated. If your original is a photocopy or other copy, then the photocopy shall be produced as the original.¶

E. Unless another time period is specified, this Request is addressed to documents created in the past five years from the date of this Request, and ending on the date of compliance with this Request.¶

F. If you possess no documents responsive to a paragraph in this Request, state this fact, specifying the paragraph concerned.¶

G. If you object in part to any Request, produce the portion of the documents requested to which you do not object, and state your objections to the remainder.¶

H. As required by Florida Rule of Civil Procedure 1.280(b)(5), if you (including your attorneys and agents) are withholding information otherwise discoverable under these rules by claiming that it is privileged or subject to protection as trial preparation material, you (including your attorneys and agents):¶

(i) Shall make the claim expressly and shall describe the nature of the documents, communications, or things not produced or disclosed in a manner that, without revealing the information itself privileged or protected, will enable the party seeking discovery through this Request to assess the applicability of the privilege or protection.
¶

(ii) Provide a brief description of the document, including (a) the date of the document; (b) number of pages, attachments and appendices; (c) the names of its author, authors, preparers and an identification by employment and title of each
¶

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such person; (d) the name of each person who has sent, shown, or blind carbon copies of the documents, or has had access to or custody of the documents, together with an identification of each such person, and (e) in the case of any document relating or referring to a meeting or conversation, an identification of such meeting or conversation.
¶

I. When appropriate, the singular form of a word should be interpreted in the plural as may be necessary to bring within the scope hereo documents which might otherwise be construed to be outside the scope hereof. %¶

CONTINUING RF.X, ,.rE¶

This is a continuing request for the production of documents to the extent allowed by Florida Rule of Civil Procedure 1.280(e). At such time as you become aware of the existence of any additional documents responsive to this Request so that your response was not complete when made, you are hereby requested to produce such documents promptly.¶

DESTROYED DOCUMENTS¶

If any docunfC responsive to this Request were at one time in existence, but have been lost or destroyed, a list should be provided of the documents so lost or destroyed stating the following information for each such document: (a) the type of document; (b) the date on which it ceased to exist, (c) the circumstances of its loss or destruction; (d) the identity of all persons having knowledge; and (e) the identity of all persons having knowledge of its contents.¶

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MANNER OF PRODUCTION¶

Pursuant to Rule 1.350, you should produce the original documents in the form, order and manner in which they are maintained in your files or the files of other persons under your control. In this connection, and for purposes of illustration, documents are to be produced in the file folder and file cartons in which they have been maintained or stored, clipped, stapled or otherwise arranged in the same form and manner as they were found. In the alternative, you should segregate all documents according to the specifications of this Request, and should organize and label each group of documents with the appropriate specifications prior to production. If any document is responsive to more than one specification of this Request, it should be labeled to reflect each specification to which it is responsive.¶

REQUESTS FOR PRODUCTION¶

Please produce all Financial Statements prepared for or submitted to any Lender or Investor for the past five (5) years by you personally or on your behalf or on behalf of any entity in which you hold a controlling interest
Please produce the W-2's and any other documents reflecting any income (including salary, bonmes, dividends, profit distributions, and any other form of income), including all gross and net revenue received by you directly or indirectly for the past five (5) years.
All tax returns filed with any taxing entity during the past five (5) years by you or on your behalf, or on behalf of any entity in which you hold or held a controlling interest at the time of filing.
All bank statements or other financial statements which were prepared by or received by you, or on your behalf or by or on behalf of any entity in which you had an ownership interest of 10% or more at any time during the past five (5) years.
MI financial statements which were prepared by you or on your behaA-6M41 or on behalf of any entity in which you held an ownership interest of 10% or more at any time during the past five (5) years.
The deeds and titles to all real property owned by you or held on your behalf either directly or indirectly at any time during the past five (5) years, x .)

L, -, 7. All passbooks with respect to all sa accounts, checking accounts and savings and loan association share accounts owned by yodr \o n which you hold a right or have a held a right to withdraw funds at any time during the past five years.¶

All passbooks with respect to all savings accounts, checking accounts and savings 7 loan association share accounts, owned)by you in whole or in part jointly as co-partner, or joint venture, in any business enterprise, or owned by an entity in which you have or have had a controlling interest OS time during the past 5 years.
The most recent bank ledger sheets in your possession, or accessible by you on the intemet, with respect to all bank accounts in which you have a right to withdraw funds.
The most recent bank ledger sheets in your possession, or accessible by you on the intemet, with respect to all bank accounts owned by you solely, or jointly as co-partner, or joint venture, in any business enterprise, or owned by any entity in which you have a controlling interest.

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All checkbooks for all accounts on which you were authorized to withdraw funds for the past five (5) years.
All corporate securities (stocks or bonds) owned by you, directly or indirectly.
The latest available balance sheets and other financial statements with respect to any and all business enterprises of whatever nature in which you poccass any ownership interest of 10% or more, whether as partner, joint venture, stockholder, or otherwise.
Your accounts receivable ledger or other company records which sets forth the names and addresses of all persons or business enterprisesthact)indebted to you and the amounts and terms of such indebtedness.
Copies of the partnership or corporst41ncome Tax Returns for any partnership or corporation in which you do possass or have possessed any ownership interest of 10% or more whether as partner, joint venture, stockholder or otherwise, for the last five (5) years.
The title certificates, registration certificates, bills of sale, and other evidences of ownership possessed by you or held for your beneficial interest with respect to any of the following described property owned by you or held directly or indirectly for your beneficial interest:

a. Motor vehicles of any type;
b. Commercial, business or construction equipment of any type; and
c. Boats, launches, cruisers, planes, or other vessels of any type.

All records pertaining to the transfer of any money or property interests or financial interests made by you in the past 5 years.

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Any and all memoranda and/or bills evidencing the amount and terms of all of your current debts and obligations.
All records indicating any and all income and benefits received by you from any and all sources for the past 5 years.
Copies of any and all brokerage account statements or securities owned by you individually, jointly with any person or entity or as trustee, guardian or custodian, for the past 5 years, including in such records date of purchase and amour certificates of any such securities. for such securities, and
All records pertaining to the acquisiti and sale of all securities by you or on your behalf for the past 5 years, such records to include any and all information relative to gains or losses realized from transactions involving such securities.
All policies of insurance in which you or any entity controlled by you is the " owner or beneficiary.
Copies of an trust agreements in which you are the settlor or beneficiary together with such documents necessary and sufficient to identify the nature and current value of the trust res. c.t.)

[REDACTED] adv. Epstein¶

Case No.: 502009CA040800XXXXXMBAGr¶

Request to produce to Jeffrey Epstein (Punitive Damages)¶

Page 11 of 12¶

I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list, this 21^st day of December, 20 12.¶

JACK SCAROLA¶

Florida Bar No.: 169440¶

Primary E-mail: jsx@searcylaw.com ¶

Secondary E-mail(s): mep@searcylaw.com ¶

Searcy Denney Scarola Barnhart & Shipley, P.A.¶

2139 Palm Beach Lakes Boulevard¶

West Palm Beach, Florida 33409¶

Phone: (561) 686-6300¶

Fax: (561) 383-9451¶

Attorney for [REDACTED] J. [REDACTED]¶

NOTA CERTIFIED¶

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COUNSEL LIST¶

Jack A. Goldberger, Esquire jgoldberger@agwpa.com; smahoney@agwpa.com Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein¶

J. M, Esquire bje.efile®pathtojustice.com; staff.efile@pathtojustice.com Jaffe, Weissing, Fistos & Lehrman, FL 425 North Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954) 524-2820 Fax: (954) 524-2822 Attorneys for Jeffrey Epstein¶

Fred Haddad, Esquire Dee@FredHaddadLaw.co haddadfm®aol.com Fred Haddad, P.A. One Financial Plaza, Suite 2612 Fort Lauderdale, FL 33394 Phone: (954)467-6767 Fax: (954)-467-3599 Attorneys for Jeffrey Epstein¶

Marc S. Nurik, Esquire marc®nurildaw.com Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556 Attorneys for Scott Rothstein¶

Lilly Ann M, Esquire Isanchez@thelsfirm.com The L-S Law Firm 1441 Brickell Avenue, 15th Miami, FL 33131 O Phone: O05)-503-55R Fax: (305)-503-6801— Attorneys for Jeffity Epstein¶

Tonja Haddad Coleman, Esquire tonja@tonjahaddad.com; Debbie®Tonjahaddad.com Tonja Haddad, PA. 415 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Phone: (954)467-1223 ax: (954)-337-3716 Attorneys for Jeffrey Epstein¶

IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND
FOR PALM BEACH COUNTY, FLORIDA¶

CASE NO.: 502009CA040800XXXXMBAG¶

JEFFREY EPSTEIN,¶

Plaintiff(s),¶

vs.¶

SCOTT ROTHSTEIN, individually,
[REDACTED] J. [REDACTED], individually, and
L.M., individually,¶

Defendant(s).¶

NOTICE OF SERVICE OF INTERROGATORIES TO COUNTERDEFENDANT¶

Counterplaintiff, [REDACTED] J. [REDACTED], hereby gives notice that pursuant to Rule 1.340(e), Florida Rules of Civil Procedure, that Net Worth Interrogatories numbered 1 through 13 have been directed to Counterdefendant, JEFFREY EPSTEIN, this 21st day of December, 2012.¶

I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list, this 21st day of December, 2012.¶

Jack Scarola
Florida Bar No.: 169440
Primary E-mail: jsx@searcylaw.com
Secondary E-mail(s): mep@searcylaw.com
Searcy Denney Scarola Barnhart & Shipley, P.A.
2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
Phone: (561) 686-6300
Fax: (561) 383-9451
Attorney for [REDACTED] J. [REDACTED]¶

ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG¶

COUNSEL LIST¶

Jack A. Goldberger, Esquire¶

jgoldberger@agwpa.com;¶

smahoney@agwpa.com ¶

Atterbury, Goldberger & Weiss, P.A.¶

250 Australian Avenue South, Suite 1400¶

West Palm Beach, FL 33401¶

Phone: (561)-659-8300¶

Fax: (561)-835-8691¶

Attorneys for Jeffrey Epstein¶

J. Esquire bje.efile@pathtojustice.com;¶

staff.efile®pathtojustice.com¶

M, Jaffe, Weissing, Fistos & Lehrman, FL¶

425 North Andrews Avenue, Suite 2¶

Fort Lauderdale, FL 33301¶

Phone: (954) 524-2820¶

Fax: (954) 524-2822¶

Fred Haddad, Esquire¶

Dee@FredHaddadLaw.com;¶

haddadfin@aol.com ¶

Fred Haddad, P.A.¶

One Financial Plaza, Suite 2612¶

Fort Lauderdale, FL 3339¶

Phone: (954)467-6767¶

Fax: (954)467-3599¶

Attorneys for Jeffrey Epstein¶

onja Haddad Coleman, Esquire¶

AS Ial Debbie@Tonjahaddad.com ¶

tonja@tonjahaddad.com;¶

Tonja Haddad, P.A.¶

315 SE 7th Street, Suite 301¶

Fort Lauderdale, FL 33301¶

Phone: (954)-467-1223¶

Fax: (954)-337-3716¶

Attorneys for Jeffrey Epstein¶

Marc S. Nurik, Esquire¶

marc@nurildaw.com ¶

Law Offices of Marc S. Nurik¶

One E Broward Blvd., Suite 700¶

Fort Lauderdale, FL 33301¶

Phone: (954)-745-5849¶

Fax: (954)-745-3556¶

Attorneys for Scott Rothstein¶

Lilly Ann M, Esquire¶

Isanchez@thelsfirm.com ¶

The L-S Law Firm¶

1441 Brickell Avenue, 15th Floor¶

Miami, FL 33131¶

Phone: (305)-503-5503¶

Fax: (305)-503-6801¶

( s ASkttorneys cr for Jeffrey Epstein¶

ADV. EPSTEIN¶

Case No.: 502009CA040800XXXXMBAG¶

NET WORTH NTERROGATORIES TO JEFFREY EPSTEIN¶

1. What is your full name?
1. How are you currently employed?

coAs¶

State the amount of your current -annual income from all sources for each of the past 3 years and describe all additional benefits received by you or payable to you for each of the past 3y ears including bonuses, allowances, pension and profit sharing participations, options, deferred compensation, insurance benefits and other prerequisites of your employment including the dollar amount or dollar value of each.
1673No or have any beneficial interest in any stocks, bonds, mutual funds, or other securities of any class in any government, governmental organization, company, firm or corporation, whether foreign or domestic, please state:

(a) The name and address of the entity in which you own or have any beneficial property or security interest of any sort;

ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG¶

(b) The date and cost of acquisition;
(c) The current fair market value of each such inte
(d) The manner in which

As to each income s return filed by you or on your behalf with any taxing authority for the years 2009 through 2012, identify as specifically as identified in your tax return the source of all reported income and the separate amounts derived from each source

(""\ .1\¶

Nkil¶

1. For each parcel of real property in which you hold any interest, state:

ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG¶

(a) The address,
(b) The legal description of the property;
(c) The assessed value of the property fo

( S"¶

(d) The date and prid'o insition;

C S/¶

'1 114Pr¶

(eo&ether, when, by whom, why and at what amount the property has been appraised since the time of purchase;¶

(f) Whether, when, and at what price the property has been offered for sale since the time of purchase;
(g)
(h)
(1) The name and address of each real estate agent with whom the property has been listed for sale since the time of purchase; 40A* C, The cost of any improvements made to the property since purchase; The nature of your interest in the property.
(j) The currentairtW)ket value Y of the property and a description of the manner in which that value was calculated
1. List each item and state the estimated value of all personal tangible, and intangible property in which you have an interest which personal property was acquired at a cost in excess of $10,000 or which personal property has an estimated present value in excess of $10,000, and as to each state:
- (a) The date of acquisition;

ADV. EPSTEIN¶

Case No.: 502009CA040800)OOCXMBAG¶

(b) The cost of acquisition;
(c) The current estimated fair market value; 4 :C)
(d) The manner in which th Se "Saar tit value was estimated.

If any of the real or personal property owned by you, either individually, jointly or otherwise, is encumbered by either a real estate mortgage, chattel mortgage, or any other type of lien, then for each item of property, state a description of the nature and amount of the encumbrance, the date the encumbrance arose, whether the encumbrance is evidenced by any written document and, if so, a description of that document.
If you have an ownership interest in any businesses, for each business state:

ADV. EPSTEIN Case No.: 502009CA040800)CCOMBAG¶

(a) The name and address of the business;
(b) The present book value and the present market value of yot s terest in the business, and its percentage of the total value of the b O •
(c) A description of the manner in Wic ii,e 'f c stated fair market value was calculated.

N--¶

,cs- 10. Identify all banks, credit union and savings and loan accounts, in which you have an interest or right of withdrawal and for each account state:¶

Nk..) Where the account is located;
(b) The highest and lowest balance in the account during the 365 day period immediately preceding your receipt of these interrogatories.

ADV. EPSTEIN Case No.: 502009CA040800=MBAG¶

1. Identify all other assets of a value in excess of $10,000 which assets were not previously identified and as to each state:
- (a) The date of acquisition;
- (b) The cost of acquisition;
- (c)
- (d) O (SThe means utilized to estimate the current fair market value. The e* estimated fair market value; 40A

Identify all other liabilities of an amount in excess of $10,000 not previously identified and as to each state:

(a) The date the liability arose;¶

(b) The amount of the liability at inception;¶

(d) The current outstanding balance.¶

ADV. EPSTEIN¶

Case No.: 502009CA0408003OOOCMBAG¶

1. As to any calculation or estimate of your net worth at any time in the five years immediately preceding your receipt of these interrogatories, state:
(a) the date of the calculation or estimate;
(b) the name and address of the person or entity responsible for performing the work
(c) the reason for performing the calculation ate; . 4 . . A. (d) the amount of net worth calculated or` estimated
1. What is your present net worth?
1. As to all transfers of anything of a value in excess of $10,000 made by you or on your behalf within the past 5 yearsileate:
(a) (Cdescoption of the transferred property; 4 14 the reason for the transfer;
- (c) the value of the item(s) transferred at the time of transfer;
- (d) the date and cost of your acquisition of the item(s);

ADV. EPSTEIN Case No.: 502009CA040800)OOOCMBAG¶

(e) whether you received anything of value in exchange for the transferred item(s) and, if so, a description of what you received and the dollar value of what you received; (0 the name and address of the recipient of each transferred item A.,

STATE OF COUNTY OF )¶

The foregoing instrument was acknowledged before me this day of, 20_, by who is personally known to me or who has produced as identification and who did did/ not take an oath.¶

(SEAL) (Notary signature)¶

(Notary name - print) NOTARY PUBLIC, State of Florida (Serial number, if any)¶

theguardian TheObserver¶

Prince Andrew's link to sex offender Jeffrey Epstein taints royalty in US¶

The of York's friendship with billionaire convicted paedophile Jeffrey Epstein has put him on American front pages¶

![](_page_24_Picture_5.jpeg)¶

Paul Harris in New York The Observer, Saturday 12 March 2011 co¶

![](_page_24_Picture_7.jpeg)¶

Prince Andrew is finding his fjiendships under international examination. Photograph: Facundo Arrizabalaga/EPA¶

The British press as a new admirer. Spencer Kuvin, a Florida lawyer who has fought several cases for young women alleging sexual abuse by the disgraced billionaire Jeffrey Epstein, is delighted — and relieved — that newspapers are now examining Prince Andrew's relationship with the convicted paedophile.¶

"I am glad the British press has picked this up," Kuvin told the Observer. "The British people have a right to ask why he [Prince Andrew] is hanging out with a convicted paedophile. I think that is a very good question to be asking."¶

Kuvin has been asking it for a while. He believes Epstein has in effect got away with most of his crimes because of his wealth and his connections with the powerful and well-connected across America and the world.¶

"He's fine. He has a great life," he said of the man who spent less than two years in jail after pleading guilty to child sex offences.¶

That is probably true. Florida law allows anyone to find out the whereabouts of a convicted sex offender via an online database. According to the website last week Epstein's location was St in the US Virgin Islands in the Caribbean. He owns a private island there: one that Prince Andrew has visited. "Epstein is probably sunning himself on a beach right now," Kuvin said.¶

The same cannot be said for the of York. This weekend, as he considers the parlous state of his international reputation, he is likely to feeling a lot less comfortable than his one-time party friend.¶

It was not meant to be this way for the prince. Amerk upposed to be a happy hunting ground for the British family. It is a plac.Nhere the people see them as exotic celebrities to be feted, admired and pla tngside the homegrown "royalty" of Hollywood.¶

American citizens and politicians — freeAlifthe burdens of paying for a civil list of their own — can indulge in the so of ircent worship of monarchical "glam" that typified Britain in the 1950s.¶

So recent headlines in the tedia have come as a bit of a shock. "Seen around town: Prince Andrew and Pery Billionaire," blared the New York Post. "Duchess of York apologises for accepting money from sex offender," read the New York Daily News. So much for the eager anticipation of a slew of good publicity around the marriage of Prince William and Kate Middleton.¶

It was not just the American tabloids. Even the Wall Street Journal ran a lengthy piece last week prompted by the fallout from Prince Andrew's long friendship and close relations with Epstein, 58, who served i8 months for sexual offences involving underage girls. No wonder New York Post columnist Andrea Peyser weighed in on the controversy about what she called a "bromance" between the pair. Prince Andrew, she concluded, was an "idiot prince".¶

It is hard to fathom the depths of the PR disaster that continues to unfold around the prince because of his links to Epstein. After he was snapped walking side by side with Epstein through Central Park last December, Andrew has seen his entire globetrotting existence as a trade ambassador put under the microscope. It has not borne up well.¶

Suddenly his life and times partying with Epstein have become public knowledge, complete with sordid details of being surrounded by young women and being present at topless pool parties. A woman, , who provided sexual services for Epstein and his rich friends while underage, saw the photograph and decided to speak about her experiences. Another picture rapidly surfaced, of side by side with the prince. To cap it all, Andrew's links to a whole series of unpleasant developing world autocrats and dictators have also come under fresh examination.¶

None of it has made a pretty picture and the royals — perhaps typically — have been slow to react in any meaningful way. First, the problem was ignored. Then it was dismissed. Only now, belatedly, have they begun to address it with reports that the Queen has talked to Andrew privately. It feels too little, too late.¶

Like many Europeans, perhaps, Andrew enjoyed the US because of the freedom and opportunities it afforded. The social scene in glittering hotspots like Manhattan and Florida's Palm Beach allowed him to free himself from the stuffy world of aristocratic Britain. He was courted and won over by the rich elite and he repaid the compliment.¶

No one knows why the prince carried on such a close friendship with a figure like Epstein for so long or why he refused to end it after Epstein went to jail. The facts alone should have been a warning sign. Epstein, a working class Brooklyn boy who became a super-wealthy money manager, was one of the world's most renowned playboys. But in 2008, after a three-year investigation into the young women he and his entourage procured, he wound up in jail. Nor was it an isolated incident. Epstein's case was ended via a plea bargain where he admitted guilt on a charge of felony solicitation of prostitution involving a minor. Yet as many as 40 young women had made allegations against him and, unusually, his plea deal allowed other accusers to sue him in civil court. So far at least 17 of them have settled civil cases against him.¶

The American drama is far from over for the prince. Instead the legal wranglings around Epstein and his exotic lifestyle threaten to drag the family right into the US court system.¶

" Epstein is now suing Brad, a lawyer for some of the girls from the original investigation. In turn is counter-suing Epstein, alleging that the billionaire is using his vast resources to pursue expensive legal cases and thus intimidate other victims and their legal representatives. Either way, Andrew could be pulled into the mess as a witness. lawyer, Jack Scarola, said last week that his team intended to try and get a statement from the prince about what he may or may not have seen while attending parties with Epstein.¶

Though the prince is likely to claim diplomatic immunity, that step will not keep his name out of the court papers or the headlines: it will just keep his presence out of the courtroom.¶

The same thing goes for previous cases involving Epstein. They amoaa potential source of PR torture for the family as media scrutiny continues. Recently released documents from a different case showed that two of Epstein's closest confidantes - his PA Sarah Ellen and an on-off girlfriend, M va — were repeatedly questioned by Kuvin about whether the prince had been involved in sexual acts with any of Epstein's entourage of young women. Both Ellen and Marcinkova declined to answer the questions and instead took the Fifth Ame s nt, which allows their legal silence. / Int,¶

there Of course, is no evidence or suggestion s th Andrew was involved. But in PR terms there does not need to be. There is even a small chance that the FBI will use some of the new revelations emerging in the media to reopen the criminal case against Epstein, though legal experts think it unlikely.¶

Even the hint of a possibilty of a federal probe is another reason for the headline writers to start sharpening tIrt pens for those with links to Epstein.¶

Prince Andrew is not one. Epstein has partied in New York with numerous people since he left jail, including big names and celebrities like Katie Couric, Stephanopoulos and Woody M. Perhaps they too should have known better.¶

CONNECTIONS¶

• Ghislaine Maxwell, 49, youngest daughter of Robert Maxwell, the former Daily Mirror proprietor, is considered one of Prince Andrew's more controversial friends. A decade ago, he was reported to have accompanied her to a "hookers and pimps" party in New York. Ghislaine moved to the US in 1991 after the death of her father and became a¶

Goga Ashkenazi, 31, a glamorous Kazakh oil tycoon, claims to be a "close friend" of Prince Andrew. Ashkenazi, an Oxford-educated socialite and entrepreneur, said: "Britain is very lucky to have him." She was introduced to Andrew in 2001 and they have been friends since. She was his guest at Ascot in 2007, although she denies rumours that they have ever been a couple.
Tarek Kaituni, a convicted Libyan gun smuggler, is an old friend . In 2008 he and Andrew enjoyed a four-day holiday to Tunisia. Kaituni was convicted of buying a machine gun in 2005 and secretly attempting to transport it from Holland to France.

O) X.¶

Legal Notice from U.S. District Court¶

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www.DiscoTextSettlement.cona ¶

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Federal Warrants¶

Find Anyone's Federal Warrant Now! Instantly Search Warrants Online.¶

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Jaffe Weissing¶

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Farmer Jaffe Weissing shared a link. Yesterday¶

Learn how Jaffe Weissing attorneys help victims of violent crimes and those injured due to inadequate security.¶

Negligent Security I Crime Victims Jaffe Weissing www.justicetovictims.com ¶

Are you the Victim of a Violent Crime or Injured Due To Inadequate Security, Stabbing, Shooting, Assault, Rape, Sexual Assault¶

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Jaffe Weissing shared a link, Yesterday¶

The figures supplied by the nation's thousands of police agencies showed that overall violent crime increased 1.90/0 over the comparable period for 2011.¶

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Jaffe Weissing licandaY¶

U.S. violent crimes statistics: Number of violent crimes increased slightly In first half of 2012 www.wptv.com ¶

U.S. violent crimes statistics' violent crimes increased¶

We are proud thetr's & Colitis Foundation of America's A Touch¶

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it Amy likes I want to go to there's photo.¶

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Sharon _Hum commented on Alison i. Thiess link: sweet. Many, many prayers..¶

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Lawyers; La maggio and Greg Sheridan are now Mends.¶

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Take Justice Back cdAgiliaig WaltiLePadron¶

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Monday at 9:31pm via mobile · Like¶

Jaheadia Liburd Congratulations Mr. Jaffe!!¶

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Monday¶

No matter what you call it, the 'Move Over' campaign is about to get more aggressive...¶

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As officials push public awareness to the Move Over Law in Florida, critics say the campaigns are ti articles.sun-sentinel.com¶

Police agencies call it "public education." Drivers call it entrapment. But no matter¶

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Jaffe Weissing shared a link.
January 11¶

Jaffe Weissing to Review Mirena® IUD Injury Cases.¶

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Mirena Lawsuits | Mirena Attorneys | Mirena Lawyers | Mirena IUD Lawsuits
www.mirenalawsuits.com ¶

Mirena IUD Lawsuits¶

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Jaffe Weissing shared a link via HubSpot.
January 10¶

EUROPEAN HEALTH AUTHORITIES JOIN YAZ LAWSUITS 2013.
WHERE IS THE FDA? http://hub.am/ZLGfOg ¶

EUROPEAN HEALTH AUTHORITIES JOIN YAZ LAWSUITS 2013.
WHERE IS THE FDA?¶

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Join us in wishing Justin a Happy Birth Louise Storelli Fogarty likes Chris Caputo's photo.¶

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January 10¶

Victimology: Broward Man Pimped Te
http://hub.am/U7AdCN ¶

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1 Farmer Jaffe Weissing, U.S. Food and Drug Administration considered a regular in December 2011. http://wazrecall.com/fda-advisory-committee-vote-yaz-jawsuits Doing More to Protect Girls & Women from Dangers of Birth Control¶

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YAZ/YASMIN – FDA ADVISORY COMMITTEE VOTE
yazrecall.com
FDA's joint meeting of Reproductive Health Drugs Advisory Committee and Drug Saf...See More¶

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1 Jaffe Weissing shared a link.
January 7¶

The number of people dying in traffic crashes went up in Broward and Palm Beach counties¶

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Traffic deaths rise in Broward, Palm Beach counties
www.sun-sentinel.com ¶

It was a deadlier year on South Florida roads and highways last year compared to 2011.¶

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1 Jaffe Weissing
December 28, 2012¶

Wishing you a Safe & Happy New Year!¶

Happy New Year!¶

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Sharon Lywich Morgh: Bewar Girl Tutalo Notes Ways.¶

Sharon Murrah Likes Janie Swagu Desir-Jean's Victimology: Convicted Sentence. Find out how Murphy likes One Call Alert's photo.¶

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Sharon Murrah Accommodates on Standard a likes James's link: "So sweet. Many, many prayers..."¶

Arena Gatting Strough Fog and Sikes Chris Caputo's photo.¶

Karin Lee Copied in 24 adr Julia Sharon Ridwell www.usatoday.com Left and Greg Sheridan are now in the adults cay they retain And health official:¶

Adriana Alcalde-Padron Like · Comment · Share Allison Hester-Haddad¶

Amy Farmer Jaffe Weissing shared a like and Greg Sheridan are now in the adults cay they retain And health official:¶

Freddie Haddad An entital savings coming on the policy of a policy is so slight that it is Jeannie Coleman indicates in other parts of the coverage¶

Michael Finkelstein PIP rates unlike new law - Florid Miami Herald.com are Haddad-Dixon Herald Florida drivers loo from a new law di¶

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Jaffe Weissing shared a like December 27, 2012
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3affe Weissing 27, 2012¶

sfoirclgimpeopie, places and things¶

Did you know that nearly one out of every five on-the-job fatalities is the result of workplace violence.¶

To learn more about work place violence and your legal rights visit: http://www.justicetovictims.com/Work_Place_Safety.¶

![](_page_34_Picture_7.jpeg)¶

Stopping Workplace Violence¶

www3.cfo.com¶

Workplace violence is responsible for nearly one out of every five on-the-Job deaths.¶

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Jaffe Weissing¶

December 21, 2012¶

Season Greetings!¶

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7 people like this.¶

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ill Write a comment...¶

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LI Jaffe Webalny December 20, 2012¶

Happy Holidays'¶

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2011¶

Jaffe Weissing shared a link. December 27, 2011¶

Hazing on college campuses has taken an increasingly violent turn, experts say, and now may involve physical abuse, sexual assault, forced intoxication and can prove fatal.¶

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pp Jeff Maggio and Greg Sheridan are now friends.¶

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Adrian Aicalde-Padron¶

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Liked Cure for COWS &¶

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tossing eggs down someone's pants.¶

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Jaffe Weissing shared a link. December 20, 2011¶

Happy Hanukkah.¶

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Jaffe Weissing December IS, 2011¶

Hanukkah 2012--The real meaning behind the festival of lights Washington Times Communities communities.washingtontimes.com¶

Sundown on December 20, 2011, begins Hanukkah. The festival of lights has a¶

Lawlapalooza 2011 - December 8, 2011¶

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31 Jaffe Weissing shared a link.¶

December 1, 2011¶

Connect with Attorney Matt Weissing via LinkedIn.¶

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Matt Weissing I Unkedin¶

www.linkedin.com ¶

1¶

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View Matt Weissing's professional profile on linkedin. Linkedin is the worlds largest business network, helping professionals like Matt Weissing discover inside connections to recommended Job candidates, Industry¶

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FYI _Jaffe 2WhisSin9 shared a link.¶

November¶

The risk of sexual abuse against child in ses when an institution's image is all important andelts use their power to manipulate the defenseless.¶

Institutions need to the on the issue of sex abuse onwe.minutemann .tom¶

• The message: E anything t s responsibility to stop predators and report to law enforcement.¶

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Jaffe Weissing¶

November 21, 2011¶

2011 Thanksgiving Turkey Basket Giveaway (29 photos)¶

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1¶

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pi Jeff Maggio and Greg Sheridan are now friends.¶

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Jaffe Weissing¶

November 23, 2011¶

thing you a Happy Thanksgiving!¶

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I November 17, Jaffe We na shakod a link.¶

( RN, News coverage of the negligent security case where attorneys Brad Edwards and Matt Weissing obtained a $4.26M award for their client.¶

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Shooting of football athlete results in $4.26M award - Daily Business Review www.dailybusinessreview.com ¶

A college football cornerback whose athletic career was cut short by a gunman¶

4¶

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Alerts photo.¶

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ovember 16, 2011¶

Tristan Haddad- DiCowden us in wishing Brad a Happy Birth'¶

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Jaffe Weissing shared a film photo, places and things November 15, 2011¶

Attorneys Brad [REDACTED] and Matt Weissing obtained a multi-million dollar verdict for a teenager, with a promising football career, who was shot as he left Boomers!.¶

Jury Awards $4.27 Million to Teen Shot Outside Boomers!
www.pathtojustice.com ¶

The attorneys of [REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman, P.L., are litigators and trial attorneys, who share an intense passion for the law and for our roles as legal advocates for our clients.¶

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5 2¶

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Amy [REDACTED]
Farmer Jaffe Weissing shared a life photo November 15, 2011
Dee Boyce Soli¶

Attorney Gary Farmer talks with "The Tall New York Hosts Steve Vancore and S Florence Jeanne Coleman" Justice Association, PIP Insurance Inc. Michael Finkelstein¶

Steve Farmer Coverage - Farmer [REDACTED], Fistos and Lehrman, P.L., are litigators and trial attorneys, who share an intense passion for the law and for our clients.¶

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Jaffe Weissing November 4, 2011¶

[REDACTED] Jaffe Weissing has challenged & Murphey law firm to see who can do the Boompano Beach Alumni Chapter¶

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Jaffe Weissing shared a link. October 24, 2011¶

Has Your Long-Term Care Insurance have information or concerns about term health insurance practices or fadlities, contact Steve Jaffe for additional information, click Denied? If you afice company's long of assisted living Fistos at (800) 400-1098 or k below.¶

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Jaffe Weissing shared a link. October 17, 2011¶

Saturday, October 22nd is "Make A Difference Day". We encourage you to get involved in the national day of doing good. Click the link below to find the DAYtaBank to find a project in your community.¶

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Make A Difference Day
1 Search for people, places and things
www.makeadifferenceday.com ¶

Now through October, read inspirational messages from NBC anchors here and learn more about Make A Difference Day during NBC Nightly News.¶

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1¶

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Jaffe Weissing¶

October 11, 2011¶

Attorney Steven M. Jaffe to give the opening remarks and introduction at the "Navigating the Maze: Identifying and Resolving Issues Inherent in The Personal Injury Case for Clients with a Disability or Special Needs" CLE presented by The Law Office of Stephanie L. Schneider PA and National Care Advisors today in Fort Lauderdale.¶

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2¶

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Jaffe Weissing¶

September 27, 2011¶

U.S. District Judge Ursula Ungaro has certified a class action law suit involving foreclosure attorney David J. Stern for violations of federal labor laws by his former employees. Our Law firm represents a class of approximately 800 former employees of the Law Offices of David J. Stern, P.A. and the DJSP Enterprises who were terminated without the 60 days notice required by federal law.¶

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1¶

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Jaffe Weissing shared a link.¶

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Sharon Schneider PA and Jaffe Weissing
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Sharon Schneider PA and Jaffe Weissing
1 Search for people, places and things
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Amy Murphy likes One Call Alert's photo.¶

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Amy Murphy likes I want to go to there's photo.¶

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FBI seeks to update definition of raping
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FBI seeks to update definition of raping
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FBI seeks to update definition of raping
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FBI seeks to update definition of raping
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Dee Boyce Soli
1 Search for people, places and things
www.deeboycesoli.com ¶

![](_page_41_Picture_102.jpeg)¶

Dee Boyce Soli
1 Search for people, places and things
www.deeboycesoli.com ¶

![](_page_41_Picture_104.jpeg)¶