IN THE CIRCUIT COURT OF THE
15th JUDICIAL CIRCUIT IN AND
FOR PALM BEACH COUNTY,
FLORIDA¶
JEFFREY EPSTEIN,¶
Plaintiff,¶
Complex Litigation, Fla. R. Civ. Pro.1201¶
Case No. 50 2009CA040800XXXXMB AG¶
v.¶
SCOTT ROTHSTEIN, individually, [REDACTED] J.
[REDACTED], individually, and L.M., individually,¶
Defendants.¶
PLAINTIFF JEFFREY EPSTEIN'S NOTICE OF FILING SUPPLEMENTAL EXHIBIT
TO HIS RESPONSE TO [REDACTED] MOTION FOR SUMMARY JUDGMENT¶
Plaintiff, Jeffrey Epstein, by and through his undersigned counsel and pursuant to the Florida Rules of Civil Procedure files this his notice of his intention to rely on the attached exhibit as part of his Response to Defendant [REDACTED] Motion for Summary Judgment.¶
CERTIFICATE OF SERVICE¶
I HEREBY CERTIFY that a true and correct copy of the foregoing was faxed and mailed this 30+ day of December, 2010 to Jack Scarola, Searcy Denney Scarola Barnhart & Shipley,¶
FILED
11 JAN - 4 AM 10: 43
SHARON R. BUCK, CLERK
PALM BEACH COUNTY, FL
CIRCUIT CIVIL 2¶
Attorneys for [REDACTED] J. [REDACTED], 2139 Palm Beach Lakes Boulevard, West Palm Beach, FL 33409 and Marc S. Nurik, Law Offices of Marc S. Nurik, Attorneys for Scott Rothstein, One E. Broward Blvd., Ste 700, Fort Lauderdale, FL 33301.¶
Respectfully submitted,¶
Joseph L. Ackerman, Jr.
Fla. Bar No. 235954¶
777 South Flagler, Suite 901
West Palm Beach, FL 33401
Telephone: (561) 802-9044
Facsimile: (561) 802-9976¶
[mah] W:\80743\NOF Supplemental Exhibit to Epstein's Response to Edw' MSJ{12/30/10-15:39}¶
other relief described below, and states: Trustee, Herbert Stettin, through his undersigned counsel, moves this Court to fix the amount of attorneys fees and sanctions to be awarded infer, Ate debtor and against Qtask, Inc. ("Qtask"), arising out of this Court's Order of,Cont p against Qtask (D.E. 776), and for \ IC¶
I. INTRODUCTION.¶
UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION www.tlsb.uscourts.gov¶
IN RE:¶
ROTHSTEIN ROSENFELDT ADLER, P.A.,¶
Debtor.¶
CASE NO.: 09-34791-RBR¶
Chapter 11¶
TRUSTEE'S MOTION TO FIX AND COMPEL PAYMENT BY QTASK OF ATTORNEYS FEES AND SANCTIONS FOR ITS CONTEMPT OF COURT¶
As the Court no doubt re already has been found in contempt of court for failing to comply with a Rule su poena issued by the Trustee on December 8, 2009 (D.E. 95). In the Order of C (i) the Trustee's tome fees and costs calculated from February 9, 2009 and continuing thereafter, 1) $5000 per day sanction to the Trustee for continued non-compliance, effective y 9, 2010. In addition, to assist the Court in ascertaining the degree of Qtask's non-co liance with the Trustee's outstanding discovery and in conjunction with the Order of Contempt, the Court appointed Robert Moody ("Moody") as its expert to review and report back to the Court. mpt, the Court found both that Qtask would be responsible for paying¶
On December 13, 2010, Moody submitted his Expert Report, docketed on December 17, 2010 as DE #1241. That report unequivocally and thoroughly supports the positions the Trustee had taken before the Court for the many months of Qtask's non-compliance, therefore reaffirming the basis for all of the Court's preceding orders, including the awarded sanctions.¶
II. THE EXPERT REPORT PROVES OTASK'S NONCOMPLIANCE.¶
Verbatim highlights of the findings from the Expert Report include:¶
Qtask Has Not Complied with the Subpoena [D.E. 095] or the March 8, 2010 Order ID.E. #411 k¶
"Based upon a review of the record, the interviews conducted provided to me, it is clear that the Trustee has not received the has not been provided the information necessary to be able received as true and correct." er materiaUsoftware ation it has requested and it on the information it has¶
Report, at page 6.¶
Qtask's Productions to Date Rave Not Complied with the Subpoena or the March 8, 2010 Order:¶
"Initial productions were uselesa¶
The initial productions b Qtask were CD/DVDs containing what essentially exists as the computer data version of a ru on seltanCe. The initial production consisted of a lot of computer code and data but no format o tructLre for the Trustee to use.¶
The second pro n as reported by Qtask, did provide structure through specialized programming but, s re a by the Trustee, did not have the functionality or ease of use that the Trustee needed to work with the data set."¶
Report, at pa'¶
Qtask Has Prevented Compliance with the Subpoena by Blockina the Trustee's Access to the Shadowbox:¶
"Access to the "shadowbox" has been blocked. The Trustee still does not have the passwords associated with the individual user accounts.¶
Access to the shadowbox has not been provided. During the initial interviews, the Trustee disclosed that the passwords on the "shadow box" had not been reset and that there were users and projects that the Trustee could not access. Shortly after this interview, this information was shared with Qtask. Qtask responded that this was the first they had heard of the problem. As of this date, it is my understanding that this issue still remains."¶
Report, at page 7.¶
Qtask has Prevented the Trustee from Understanding the Universe of Data Available so the Trustee can Narrow its Search:¶
"Cannot determine the total universe of potential or responsive data.¶
The size of the responsive data universe can only be resolved through a review of the Qtask environment. The Trustee has stated that it is requesting that Qtask only, comply with its subpoena and provide access to the information which is responsive to this sub poss,¶
Qtask has stated that it is complying with the Court's order and p m. t e data within the limits set by the Court.¶
From my interviews and review of the information prow' ed, rustee appears to be asking for a broader range of access. This need for bro r a ss is a byproduct of the investigative process and the lack of information which ha ved to date."¶
Report, at page 8.¶
The Court Has AlrekProvided a Proper Mechanism to Protect Individual Users' Rights:¶
"If the Trustee identifies a pat ar user or project, the Court through its order has already provided a mechanism to prgtcc er, the user's projects and the user's specific data."¶
Report at page 8.¶
"Qtask has raised the that many of its clients have customer, private or highly sensitive data that cann viewed or accessed without appropriate clearance.¶
As previously addressed, the concern of Qtask regarding their client's data must not be taken lightly. No matter the source, highly sensitive data must be protected and where possible be excluded. f e"Sn a casual review, if determined that the information is not relevant to the Trustee's itiyesti tion. Based upon the March 8, 2010 order, the Trustee and the Court have, made pr igloos for the owner of the data to be informed and to object to the production, if nec¶
Report, at page II.¶
Qtask Can Monitor the Trustee's Investigation through the Shadowbox:¶
"Qtask is monitoring the Trustee's investigation.¶
Through interviews, Qtask has acknowledged that it knows what and when the Trustee has accessed on Qtask because they are part of the same projects as the Trustee and they maintain administrative and technical control over the workspace the Trustee is conducting its investigation in.¶
A review of the Qtask environment shows that this is an inherent feature of Qtask and not something that was created to monitor the Trustee. Regardless of how it came into existence, the fact is this feature does exist. Furthermore, the "shadow box" being hosted on the Qtask network does offers a significant security risk to the Trustee's investigation."¶
Qtask Has Stopped Even Attempting to Comply With the Trustee's Requests for Information from °task:¶
'The Trustee and Qtask have both acknowledged that Qtask has stopped complying with . these subsequent requests because Qtask feels that they are too burdensome and it*ould not be made to "run back to the warehouse numerous times" to meet the Trustees demands."¶
Report, at page 9.¶
"The Trustee must be able to make requests for ad targets of interest. The Trustee must be able to rely on the ' it requests." nformation as it identifies nd the accuracy of the data¶
Report, at page 9. / el\¶
Qtask Has Used Wrongfully Assertions of 3rd Parties' Rights to Obstruct the Trustee's Investigation:¶
"Qtask has repeatedly claim that-the information contained within their system does not belong to them, it belongs to their client. They have stated that they are the gatekeepers and that they are not able to provide,iec ause they do not own the information.¶
Qtask's classification o ,,data is correct but its role in its protection is flawed.¶
Qtask operates a o pany very similar to many other service bureaus such as America Online, Hotmail,ennail, yahoo, etc. Each of these companies has procedures in place to produce information tharis requested.¶
"fr an obligation to secure the information when properly requested and should follow t dures to produce the information as required.¶
task should not be taking the position of questioning the Trustee as to why the information is needed or what they will be doing with the information. They are the intermediary between the housed data and the requesting party.¶
Report, at page 10.¶
Qtask's argument and justification for failing to produce client data, takes the form that they are the gatekeeper to the data and not the owner and cannot produce what they do not own, is flawed."¶
Report, at page 11.¶
Qtask Has Wrongfully Obstructed the Trustee's Investigation by Attempting to Filter the Trustee's Requests for Data:¶
"Qtask has requested that they be informed as to all data the Trustee desires access to and once they have been informed of the data targets, they will determine if it is appropriate and provide access.¶
Once again, Qtask is attempting to fulfill a role greater than that of the gate . As the gatekeeper, their role is to provide a process to facilitate the request and delivery ata. k¶
Determination as to appropriateness falls first on the Trustee and questioned, it then must fall on the Court." ateness is¶
Otask Cannot be Permitted to Control the Production Process:¶
"Additionally, since Qtask is the target of the Tr Qtask's word as to which users and projects are responsiv ,S ) the Trustee, "they cannot afford to get this wrong." \ 's Investigation, acceptance of problematic. As stated by¶
Report, page 12.¶
III. THE TRUSTEE REOUESTS SWIF'fC RT RESOLUTION.¶
The actual prejudice and impa_cro c ......, the Estate and its creditors by Qtask's willful and continued noncompliance with thi'itrt's, any court orders is measurable. In economic terms, the Estate has already spent o $100,000 in attorneys fees for rehashing and revisiting the same meritless arguments with task for a one year period. The Trustee will shortly provide the Court with an updated omeys ? ee and cost affidavit to liquidate these sums.¶
In c terms (but which may well impact Estate recoveries), the Estate has not bee conclude critical investigations. One example of actual, existing prejudice is the inability conclude the Qtask Adler ("Adler") data review and investigation where the Trustee has a specially set trial on Adler's adversary proceeding scheduled before Judge Cohn on February 14, 2011. The potential data being hidden by Qtask pertaining to Adler could be a pot of gold. The Trustee has already submitted to the Court the Scott Rothstein internal e-mail imagination. What are they hiding? where he directed his partners to use Qtask because the RRA servers were less than secure. In deposition, Adler makes no secret, in fact brags about being the RRA architect who brought Qtask in house to RRA. Robert Buschel ("Buschel"), a former RRA partner, Qtask shareholder and present Qtask lawyer has been the front man in keeping the Trustee away from Qtask's data during the last year. It is no coincidence that the deposition transcript that Busc used to support his recent frivolous and bad faith motion to disqualify Berger as en in the Adler adversary. To say Adler and Buschel are working in conce is stretch of t s'•¶
But additionally, even after the appointment of Mood 4S? hold firm and not comply with the Court's orders. The I no reason why at any time since the Order to Compel or the Order of Cont t iv,t task couldn't have modified its position and provided compliance on such ira s ' *lc o tter as obeying a subpoena. What did and Buschel continued to Qtask ever have to gain by not complyi that Moody spoke to Buschel an preview of where the Expert Per ps even worse, the Expert Report makes clear ut all of the pending issues and both sides had a heading. Instead, Qtask has continued to dig in its heels.¶
Based upon the) ord as it exists and the unique timing circumstances of the Trustee needing to prom ( c con o ude all of his investigations, the Trustee asks the Court to expedite granting all fo wing relief:¶
-
Holding a status conference or other hearing to set procedures for going forward based upon the Expert Report and the Trustee's requested relief set forth below.
-
- Liquidating the accrued attorneys fees and the $5000 per day non-compliance fine to a final judgment.
-
- Increasing the $5000 per day fine to $25,000 per day for continued noncompliance.
-
- Ordering the immediate incarceration of any Qtask officer who directed the contempt of court until full compliance by Qtask occurs.
-
- Because it is cost and time effective to do so, appointing Moody as t Court's monitor with obligations to regularly report back to the Court on an extremely e ited sis.
-
- Liquidating the amount of fees incurred by Moody for hi wo a the Court's expert and entering a judgment against Qtask for same.
-
- Granting leave of court to the Trustee to file a priate motion to determine the culpability of Buschel in these proceedings, so as to to is assess on a joint and several basis the total attorneys fee award and fine against sch n Qtask.
!t¶
& BE ER SINGERMAN, P.A. torneys for the Chapter I I Trustee 200 S. Biscayne Blvd., Ste. 1000 Miami, FL 33131 Telephone: (305) 755-9500 Facsimile: (305) 714.4340¶
Dated: December 29, 2010. t y submitted,¶
By: /s/ Charles H. Lichtman¶
Charles H. Lichtman c I ichtman@herxersingerman.com Florida Bar No. 501050¶
CERTIFICATE OF SERVICE¶
I HEREBY CERTIFY that a true and correct copy of the foregoing was served via Regular U.S. Mail, postage prepaid, fax, email and/or overnight delivery, as indicated, upon all parties on the attached Service List this 29th day of December, 2010.¶
/s/ Charles H. Lichtman¶
Charles H. Lichtman¶
aS S¶
iS 9¶
SERVICE LIST CASE NO.: 09-34791-BKC-RBR¶
Marianella Morales, Esquire Authorized Agent For Joining Creditors Avenida Francisco de Miranda Torre Provincial "A" Piso 8 Caracas, Venezuela (VIA CM/ECF and EMAIL)¶
John H. Genovese, Esq Robert F. Elgidely, Esq. Theresa M.B. Van Vliet, Esq. Genovese Joblove & Battista, PA Bank Of America Tower at International Place 100 S.E. 2nd Street, Suite 4400 Miami, Florida 33131 (VIA CM/ECF and EMAIL)¶
Kendall Coffey, Esq. Coffey Burlington, Office in the Grove Penthouse 2699 South Bayshore Drive Miami, Florida 33133 kcoffev@coffeyburlington.com (VIA CM/ECF and EMAIL)¶
The Honorable Herbert M. Ste One Biscayne Tower Suite 3700 Two South Biscayne B Miami, Florida 33131 (VIA U.S. MAIIAttd E IL)¶
John G. Bi John M. Tripp S 110 Sixth Street Fifteen oor Fort Lauderdale, Fl. 33301 jgb@trivpscott.com (VIA CM/ECF and EMAIL)¶
Alison W. Lehr, Esq. Grisel Alonso, Esq. Assistant United States Attorney 99 N.E. 4th Street, 7th Floor Miami, Florida 33132 Alison.Lehr@usdoj.gov Grisel.alonso@usdoi.gov (VIA CM/ECF and EMAIL)¶
Jeffrey R. Sonn, Esq. Sonn & Erez, PLC Broward Financial Cente 500 E. Broward Boule Suite 1600 Fort Lauderdale, orida 394 jsonn @sonnerez. (VIA C nd EMAIL)¶
Trustee First Avenue anu, orida 33130 CM/ECF and EMAIL)¶
Tew Esq. Tew- LISP Four Seasons Tower 15th Floor 1441 Brickell Avenue Miami, Florida 33131-3407 tt@tewlaw.com (VIA CM/ECF and EMAIL)¶
Conrad & Scherer, LIP 633 South Federal Highway Fort Lauderdale, FL 33301 bs@conradscherer.com JSilver@conradscherer.com (VIA CM/ECF and EMAIL)¶
Michael D. Seese, Esq. Hinshaw & Culbertson, LLP 1 E Broward Blvd Ste 1010 Ft Lauderdale, Florida 33301 mseese@hinshawlaw.com (VIA CM/ECF and EMAIL)¶
Internal Revenue Service Centralized Insolvency Operations P.O. Box 21126 Philadelphia, PA 19114 (Via US. Mail)¶
Internal Revenue Service Special Procedures - Insolvency 7850 SW 6th Court Plantation, FL 33324 (Via US. Mail)¶
Special Asst. U.S. Attorney P.O. Box 9, Stop 8000 51 SW Ist Avenue, #1114 Miami, Fl 33130 (Via US. Mail)¶
United Healthcare Dept. CH 10151 Palatine, IL 60055 (Via US Mail)¶
Special Asst. U.S. Mto IRS District Counsel 1000 S. Pine Isla d., 340 Plantation, FL (Via U.S.¶
SERVICE LIST CASE NO.: 09-34791-BKC-RBR¶
Honorable Jeffrey H. Sloman, Acting U.S. Attorney 99 NE 4th Street Miami, Fl 33132 (Via US. Mail)¶
Daniel Mink Ovadia Levy do Renato Watches, Inc 14051 NW 14th Street Sunrise, Florida 33323 (Via U.S. Mall)¶
William Moskowitz Mand 800 Corporate Dr Fort Laud wsalim (V orida 33334 corn and EMAIL)¶
I thony Gruppo est Cypress Creek Road Nite 500 * 7 Fort Lauderdale, FL 33309 Anthonv.eruovo@usi.biz (VIA EMAIL)¶
•¶
The Hon 'c H. Holder, Jr. Att ral of the U.S. 950 Pen lvania Avenue, NW Room 4400 Washington, DC 20530-0001 (Via US. Mail)¶
Marc Nurik, Esq. 1 East Broward Blvd Suite 700 Fort Lauderdale, FL 33301 mare@nuriklaw.com (VIA EMAIL)¶
BAST AMRON LLP SunTrust International Center One Southeast Third Avenue Suite 1440 Miami, Florida 33131 bamron@bastamron.com ibast@bastantron.com (VIA CM/ECF and EMAIL)¶
SERVICE LIST CASE NO.: 09-34791-BKC-RBR¶
Mark Bloom, Esq. John B. Hutton, Esq. Greenberg Traurig, LLP 333 Avenue of the Americas, Suite 4400 Miami, FL 33131-3238 bloommegtlaw.coin hudoW@atlaw.com (VIA CM/ECF and EMAIL)¶
Robert D. Critton, Esq. Burman, Critton, Luttier & Coleman 303 Banyan Blvd., Suite 400 West Palm Beach, FL 33401 rcrit@bciclaw.com (VIA CM/ECF and EMAIL)¶
Roth & Scholl Ann: Jeffrey C. Roth, Esq. Attorneys For Creditor Blue Capital Us East Coast Properties, L.P. 866 South Dixie Highway Coral Gables, Fl 33146 ieff@rothandscholl.com (VIA CM/ECF and EMAIL)¶
Rogers, Morris & Ziegler, LLP 1401 East Broward Blvd Suite 300 Fort Lauderdale, FL 33301 mtbooth@rinzlaw.com (VIA CM/ECF and E¶
Arthur C. Neiw Esq. One E Brow Suite 1400 Ft. Lauderda I 3 1 aneiwinh@u w (VIA CM/f: w.com nd EMAIL)¶
The Florida Bar Adria E. Quintela, Esq. Man Anthony Pascal, Esq. Lake Shore Plaza 11 1300 Concord Terrace, Suite 130 Sunrise, FL 33323 aciuintel@flabar.org apascal@flabar.org (VIA CM/ECF and EMAIL)¶
Micheal W. Moskowitz, 800 Corporate Drive, Su Ft. Lauderdale, FL 33 mmo k witz@mm (VIA CM/ECF a¶
Francis L. Katz B 2699 M. Esq. ro Faust Drive, 7th Floor a 33133 .c m CF and EMAIL)¶
dley S. Shraiberg, Esq. 2385 NW Executive Drive Suite 300 Boca Raton, Florida 33431 bshraibera@sfl-pa.com (VIA CM/ECF and EMAIL)¶
Henry S. Wula. CARLTON P.A. 525 Okeechobee Blvd., Suite 1200 West Palm Beach, Florida 33401 E-Mail: bwulf@curItonfields.com (VIA CM/ECF and EMAIL)¶
EMESS Capital, LLC c/o Bruce A. Katzen, Esq. 201 S. Biscayne Blvd., 17ik Floor Miami, Florida 33131 E-Mail: bkatzen@klucerkartlan.com jbermaneklucerkaolan.com (VIA CM/ECF and EMAIL)¶
SERVICE LIST CASE NO.: 09-34791-BKC-RBR¶
Ira Sochet, Trustee Revocable Intervivos Trust of Ira Sochet do Phil Hudson, Esq. 200 South Biscayne Blvd, Suite 3600 Miami, Florida 33130 E-Mail: pinhudson@arnstein.com (VIA CM/ECF and EMAIL)¶
Coquina Investments do Patricia A. Redmond, Esq. 150 West Hagler Street, Suite 2200 Miami, Florida 33130 E-Mail: predmond@steamsweaver.com (VIA CM/ECF and EMAIL)¶
Michael I. Goldberg, Esq. Las Olas Centre - Suite 1600 350 East Las Olas Blvd Fort Lauderdale, FL 33301 E-Mail: Michael.eoldbere@akerman.com Eval.bereer@akennan.com (VIA CM/ECF and EMAIL)¶
LMB Funding Group do Robert C. Furr, Esq. 2255 Glades Road, Suite 337W Boca Raton, Florida 33431 E-Mail: rfurr@furrcohen.com (VIA CM/ECF and EMAIL¶
A. Gordich, Melissa Alagna, Esq. SEGALUGORDJCH P.A 801 Brickell A Suite 900 Miami, Flo P' Email: lag crordich.com Email: m ma illgordich.com (VIA F and EMAIL)¶
Broward County Attn: Hollie N. Hawn, Esq. Government Center 115 South Andrews Avenue Fort Lauderdale, FL 33301 E-Mail: hhawn@broward ore (VIA CM/ECF and EMAIL) Steven J. ,Esq. Gray P.A. 1221 Brickell Ave, Suite 1600 Miami, Florida 33131 E-Mail -- (VIA CM/ECF and EMAIL)¶
Peter F. Valori, Esq. DAMIAN & VALORI LLP 1000 Brickell Avenue, Suityt 0 Miami, FL 33131 E-mail: .valori@dvll (VIA CM/ECF an¶
ff Canon Financial 'cat, Inc. 158 Gaith • e, #200 Mount Si 08054 (Via¶
ology Financing Services I, \1 01 Centurion Parkway North sonville, FL 32256 (Via US Mail)¶
Gibraltar Private Bank & Trust Company 220 Alhambra Circle, Suite 500 Coral Gables, FL 33134 (Via US Mail)¶
Inter-Tel Leasing, Inc. 1140 West Loop North Houston, TX 77055 (Via US Mail)¶
Florida Department of Revenue 501 S. Calhoun Street Room 201 Carlton Building Tallahassee, FL 32399 (Via US Mail)¶
CASE NO. SERVICE LIST : 09-34791-BKC-RBR¶
County Tax Collector 315 S. Calhoun Street Suite 210 Tallahassee, FL 32301 (Via US Mail)¶
Miami-Dade County Tax Collectors 140 West Flagler Street, 14th Floor Miami, FL 33130 (Via US Mail)¶
Palm Beach County Tax Collector P.O. Box 3715 West Palm Beach, FL 33402-3715 (Via US Mail)¶
THE LAW OFFICES OF GEOFFREY D. ITTLEMAN, P.A. 440 North Andrews Avenue Fort Lauderdale, Florida 33301 (Via US Mail)¶
Carpenter & Berger, PL 6400 N. Andrew Ave, suite 370 Fort Lauderdale, FL 33309 (Via US Mail)¶
F. McGinn, Esq. Bartlett Feinberg, P 155 Federal Street, 9m Floor Boston, E 02110 ffm@bostonbusinesslaw. CM/ECF E¶
Darol H. M 99 Nesli Punta 3950 (VIA C CF and EMAIL)¶
Jane A. Bee, Esq. Blank Rome LLP 130 North 18th Street Philadelphia, PA 19103-6998 Pee@blankrome.com (VIA EMAIL)¶
Roderick F. Coleman, Esq. 400 South Dixie Highway, Suite 121 Boca Raton, FL 33432 rfc@colemanattorrievs.com (VIA CM/ECF and EMAIL)¶
Mark S. Haltzman, Esq. Lamm Rubenstone, LLC 3600 Horizon Blvd, Suite 200 Trevose, PA 19053 mhaltzman@lammrubensto m (VIA CM/ECF and EMS¶
Robert C. Busshel, 100 S.E. Third A Fort Lauderdale, busshel (VIA nd EMAIL)¶
Belo ck Pollack & Brant blic Accountants & Consultants, Biscayne Boulevard, Sixth Floor iami, FL 33131-2310 Atm: Richard Pollack (Via Email and U.S. Mail)¶
MELAND RUSSIN & BUDWICK, P.A. 3000 Wachovia Financial Center 200 South Biscayne Boulevard Miami, Florida 33131 Ann: James C. Moon, Esq. 'moon@ melandrussin.com Attn: Peter D. Russin, Esq. prussin@melandrussin.corn Attn: Michael S. Budwick, Esq. mbudwick@melandrussin.com (VIA CM/ECF and EMAIL)¶
Gary S. Blake, Esq. 1499 W. Palmetto Park Rd Suite 300 Boca Raton, FL 33486 gblake@iglawmet (VIA CM/ECF and EMAIL)¶
Melinda S. Thornton, Esq. Assistant County Attorney County Attorney's Office 2810 Stephen P. Clark Center 111 N.W. First Street Miami, Fl 33128-1993 Email: eao.bkc@miarnidade.eov (VIA CM/ECF and EMAIL)¶
SLATKIN & P.A. Attorneys for Adler and Katie Adler One East Broward Boulevard, Suite 609 Fort Lauderdale, Florida 33301 Telephone 954.745.5880 Facsimile 954.745.5890 islatkin@slatkinrevnolds.com (VIA CM/ECF and EMAIL)¶
ASSOULINE & BERLOWE, P.A. 213 East Sheridan Street, Ste. 3 Dania Beach, FL 33004 Ann: Eric N. Assouline, Esq. ena@assoulineberlowe.corn (VIA CM/ECF and EMAIL)¶
Steven J. Reisman, Esq. CURTIS, MALLET-PREVOST COLT & MOSLE LLP 101 Park Avenue New York, NY 10178 1 E-mail: sreisman (Via Email and¶
Turner P. CURTIS COLT 101 New Yo E-mail: tsinith@curtis.com (Via Email and U.S. Mail) -PREVOST, LLP ue NY 10178-0061¶
Maryann Gallagher, Esq. CURTIS, MALLET-PREVOST, COLT & MOSLE LLP 101 Park Avenue¶
SERVICE LIST CASE NO.: 09-34791-BKC-RBR¶
New York, NY 10178-0061 E-mail: maallaeher@cunis.com (Via Email and U.S. Mail)¶
ILEANA CRUZ BONGINI, ESQ. icruz@stearnsweave STEARNS WEAVER WEISSLER ALHADEFF & SITTERSON, P.A. Coquina Investments Museum Tower, Suite 2200 150 West Flagler Street Miami, Florida 33130 (VIA CM/ECF an¶
Maynard G ollin@ LP wer ell Avenue 33131 CM/ECF and EMAIL)¶
Paul J. McMahon, Esq. Paul McMahon, P.A. 2840 S.W. Third Ave Miami, Florida 33129 pjm@pjmlawmiami.com (VIA CM/ECF and EMAIL)¶
Robert P. Avolio, Esq. Crossroads Corporate Center 3150 Brunswick Pike, Ste. 120 Lawrenceville, NJ 08648 ravolio@avoliohanlon.com (Via Email and U.S. Mail)¶
Mark S. Shipman, Esq. 20 Batterson Park Road, Suite 120 Farmington, CT 06032 mark @shiriso.com (Via Email and U.S. Mail)¶
-SERVICE LIST CASE NO.: 09-34791-BKC-RBR¶
Heather L Ries, Esq. Fox Rothschild, LLP 222 Lakeview Ave, Suite 700 West Palm Beach, Fl 33401 hries@foxrothschild.cum (VIA CM/ECF and EMAIL)¶
Geoffrey S. Aaronson, Esq., Geoffrey S. Aaronson, P.A., Local Counsel for FEP and the FEP Victims Group, Miami Tower. 100 SE 2nd Street, 27th Floor, Miami, Florida 33131 gaaronson@aaronsonpa.com (VIA CM/ECF and EMAIL)¶
Michael Paris, Esq. William C. Nystrom, Esq. Nystrom, Beckman & Paris, LLP Lead Counsel for FEP and the FEP Victims Group 10 Saint James Avenue, 16th Floor Boston,. 02116 moaris@nboaris.com wnvstrom@nboaris.com (Via Email and U.S. Mail)¶
Scott L. Baena, Esq. Bilzin Sumberg Baena Price 1450 Brickell Avenue, Suite 2 Miami, FL 33131-3238 c i SBaena@bilzin.com (VIA CM/ECF? Mt +0¶
s Co¶