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Record

Draft: efta02759876

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

Complex Litigation, Fla. R. Civ. P. 1.201

Case No. 50 2009CA040800XXXXMB AG

JEFFREY EPSTEIN,

Plaintiff,

V.

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

Defendants.

BANKRUPTCY TRUSTEE'S SUPPLEMENTAL MOTION FOR PROTECTIVE ORDER

Herbert Stettin, Trustee of the Bankruptcy Estate of Rothstein Rosenfeld Adler, P.A. ("Trustee"), hereby files this Supplemental Motion for Protective Order pursuant to Rule 1.410 and 1.280(c), and states:

  1. On November 10, 2009, the law firm of Rothstein Rosenfeldt Adler, P.A. ("RRA") was placed into involuntary bankruptcy, with a case pending in the United States Bankruptcy Court for the Southern District of Florida. On November 20, 2009, Herbert Stettin was appointed Trustee of RRA by the bankruptcy Court.

  2. On April 16, 2010, Plaintiff caused a subpoena duces tecum ("Subpoena") to be served on the Trustee seeking documents from a lawsuit that is currently active and pending, being litigated by ex-RRA lawyers. A copy of the Subpoena is annexed hereto as Exhibit A.

FILED
10 JUN 25 PM 1:12
SHARON R. BOCK, CLERK
PALM BEACH COUNTY, FL
CIRCUIT CIVIL ?

FILED

  1. On May 19, 2010, the Trustee filed a Motion for Protective Order addressing issues primarily relating to costs associated with reviewing and compiling responsive documents to the subpoena. A copy of the Motion for Protective Order is annexed hereto as Exhibit B.

  2. On June 18, 2010, counsel for L.M. filed a Motion for Protective Order. A copy of the Motion for Protective Order is annexed hereto as Exhibit C.

  3. Within the bankruptcy court, the Trustee obtained a protective order dealing with its production of documents. The Trustee believes that the documents requ the Subpoena are subject to the attorney-client privilege and/or work product doedoctr are simply, actually the clients documents, even though the Trustee holds the atto -client privilege as to RRA.

  4. However, since the former RRA attorneys nev ned their files from RRA when the firm was closed, the Trustee is effectively standing/in the shoes of the former RRA attorneys and clients, and thus the Subpoe iitumot request discovery from the Trustee to somehow circumvent the attorney-client

WHEREFORE, for the foe : ,ns, the Trustee requests this Court to grant this Motion and enter an Order o p o on prohibiting Plaintiff from obtaining the discovery sought in the Subpoena. zer (s, Respectfully submitted,

BERGER SINGERMAN Counsel for the Trustee 200 S. Biscayne Blvd. Tenth Floor Miami, Florida 33131 305.755.9500 305.714.4340 (facsimile)

By:

harles H. chtman Florida Bar No. 501050

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served by U.S. Mail and facsimile on Mr. Robert D. Critton, Jr., Burman Critton Luttier & Coleman, 303 Banyan Blvd., Suite 400 West Palm Beach FL; Mr. Marc Nurik, Esq., Law Offices of Marc S. Nurik, One East Broward Blvd., Suite 700, Ft. Lauderdale, FL 33401; Mr. Jack Scarola, 2139 Palm Beach Lakes Blvd., West Palm Beach, FL; Mr. Gary [REDACTED], Esq., Farmer Jaffe Weissing, et al., 425 N. Andrews Ave., Suite 2, Fort Lauderdale, FL 33301 and Mr. Jack Goldberger, Esq., Atterbury Goldberger et al., 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401-5012; and to Rodney Janis, Esq., [REDACTED], [REDACTED] Burnett, P.A., [REDACTED] Point, West Tower, 777 S. Flagler Dr., Ste 901, West Palm Beach, Florida 33401 this 24th day of June, 2010.

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

JEFFREY EPSTEIN

Complex Litigation, Fla. R. Civ. Pro.1201

Plaintiff,

Case No. 50 2009CA040800XXXXMB AG

v.

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

Defendants.

SUBPOENA DUCES TECUM FOR DEPOSITION – DOCUMENTS ONLY

THE STATE OF FLORIDA

TO: Herbert Stettin, Trustee in Bankruptcy for Roth [REDACTED] Rosenfeldt Adler, PA
C/O James C. Cunningham, Jr., Esq.
Berger Singerman, P.A.
200 South Biscayne Blvd., Suite 1000
Miami, FL 33131

YOU ARE COMMANDED to appear at P [REDACTED] Court Reporting, 101 NE 3rd Avenue,
Suite #1500, Ft. Lauderdale, FL 33301, on May 19, 2010, 4:00 p.m., bring with you the
following:

See attached Exhibit A

If you fail to appear, you may be in contempt of court.

You are subpoenaed by the attorney whose name appears on this subpoena and unless
excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as
directed.

DATED this 16th day of April, 2010.

ROBERT D. CRITTON, JR.
(Attorneys for Defendant Jeffrey Epstein)
Burman, Critton, Luttier & Coleman
303 Banyan Blvd., Suite 400
West Palm Beach, FL 33401
561-842-2820

![](_page_3_Picture_168.jpeg)

EXHIBIT A

DEFINITIONS AND INSTRUCTIONS

A. "Document" means any written or graphic matter or other means of preserving thought or expression, and all tangible things from which information can be processed or transcribed, including the originals and all non-identical copies, whether different from the original by reason of any notation made on such copo otherwise, including, but not limited to, correspondence, memoranda, notes, messages, letters, purchase orders, telegrams, teletype, telefax bulletins, eitiails,1 electronic data, meetings, reports, or other communications, interoffice and intra-office telephone calls, diaries, chronological data, minutes, books, r rts, charts, ledgers, invoices, worksheets, receipts, returns, trade informatiaNga ing fabric, carpets, samples 4 etc..., computer printouts, prospectuse 'financial statements, schedules, affidavits, contracts, cancelled checks, transkripp, statistics, surveys, magazine or newspaper articles, releases (and any and all drafts, alterations and modifications, changes and amendments of any of the foregoing), graphs or aural records or representations of any kind, including, without limitation, photographs, charts, graphs, microfiche, microfilm, video tape, recordings, rotion pictures and electronic, mechanical or electric recordings or representations of any kind (including, without limitation, tapes, cassettes, discs and record s), and including the file and file cover.

The term "Document" also means any and all computer records, data, files, directories, electronic mail, and information of whatever kind whether printed out or stored on or retrievable from floppy diskette, compact diskette, magnetic tape, optical or magnetic-optical disk, computer memory, hard drive, zip drive, jaz drive, orb drive, microdisk, external memory stick, software, or any other fixed or removable storage media, including without limitation, all back-up copies, dormant or remnant files, and any and all miscellaneous files and/or file fragments, regardless of the media on which they reside and regardless of whether the data consists in an active file, deleted file, or file fragment.

B. "Communications" means any oral or written staterrni, dialogue, colloquialism, discussion, conversation or agreement.

C. "Plaintiff' means L.M. (LM. v. Jeffrey Epstehereach County Case #502008CA028051)OOC(MB), E.W. (E.W. v. Jeff Epstein, Palm Beach County Case #502008CA028058)OOC(MB), Jane Doell e Doe v. Jeffrey Epstein, United States District Court Case #08-civ-latare), and any other person who Is or was represented by Rothstein Rosenfeldt & Adler that has not yet filed an action against Jeffragetein, and any employee, agent or attorney for any plaintiff and/or any other person acting for or on behalf of any plaintiff, or under her authority and control.

D. "RRA" means Rothstein Rosenfeldt & Adler, P.A.

E. 'Money' rrteans any tangible thing of value.

include, but are not limited to, court costs, filing fees, Sheriffs servigaenY any other necessary service of legal papers or notices or subpoenas, court reporters' charges, long distance telephone charges, postage, courier services or Federal Express or UPS, investigative costs, photocopies, faxes, Westlaw computerized research, travel expenses, and witness fees and expert witness fees and costs.

1 If you are unable to identify each Plaintiff, please contact Robert D. Critton, Jr. at their names will be provided pursuant to a confidentiality agreement

G. "Trustee" means Herbert Stettin as bankruptcy trustee for RRA.

DUCES TECUM2

  1. For the time period from March 1, 2009 to present, any and all documents between, or on behalf of RRA, its employees or agents or clients, and any third party regarding a purported settlement of any litigation between Jeffrey Epstein and a RRA client or Plaintiff, or the financing of any litigation between Jeffrey Epstein and a RRA client or Plaintiff, (whether existing clients or fabricated clients), including but not limited to:

  2. a. Documents indicating that litigation with Jeffrey Epstein has been settled;

  3. b. Soliciting or receiving money in return for settlement funds allegedly paid or to be paid by Jeffrey Epstein;

  4. c. Soliciting money to help finance ongoing litigation against Jeffrey Epstein;

  5. d. Soliciting money to be given to, or used on behalf of, the Plaintiffs in litigation against Jeffrey Epstein;

  6. e. Communication between third party investors or potential investors and the Plaintiffs or their attorneys involved in litigation against Jeffrey Epstein;

  7. f. Payments made by RRA to or on behalf of any Plaintiff.

  8. Any and all fee agreements that exist or have existed between the following:

  9. a. Any Plaintiff and [REDACTED] J. [REDACTED] or any entity with which he has been associated;

  10. b. Any Plaintiff and the law firm RRA.

  11. All emails, data, correspondence, memos, or similar documents between [REDACTED] J. [REDACTED], Scott W. Rothstein, William Berger and [REDACTED] Adler and/or any attorney or representative of RRA and any investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, [REDACTED] or Rick (Rich) Fandrey).

  12. All emails, data, correspondence, memos, or similar documents between [REDACTED] J. [REDACTED], Scott W. Rothstein, and/or any attorney or representative of RRA regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, [REDACTED] or Rick (Rich) Fandrey).

2 Due to the potential volume of documents involved, the parties and the Court should consider appointment of a special [REDACTED] and/or an in camera inspection to address any objections, claims of privilege and generally manage the production of documents.

  1. All agreements or documents of any nature which were provided to or received from an investor or potential investor relating to any case (real or fabricated) involving Jeffrey Epstein and any of the following:
  • a.
  • b.
  • c.
  • J.
  • e. any entity formed by RRA or J. or Scott W. Rothstein to create investment opportunities for third party investors to invest in any plaintiff's case against Jeffrey Epstein.

7 6. All fee sharing agreements between J. or Scott W. Rothstein and/or any other attorney or investor relating to -n aspect of any 'EIS A, Plaintiff's case.

cuments made available to any investor Or potential investor by, RRA, Scott W. Rothstein or any of Scott W. Rothstein's entities to solicit "investors" for any case involving Jeffrey Epstein.

  1. All document reflecting the names and addresses of all individuals or entities who invested or purported to invest in any aspect of any case against Jeffrey Epstein.

  2. All documents evidencing payment of any bill or cost in each Plaintiff's case against Jeffrey Epstein, and the x tivirce(s) for said payments of any Costs.

  3. All documents wherein the Trustee of RRA has asserted a lien for attorney's fees or Costs arising out of work done and Costs incurred related to the Plaintiffs' cases during the time Plaintiffs' cases were represented by RRA.

  4. All documents and tangible things retrieved from the trash at 358 El Brillo Way, Palm Beach, Florida which is alleged to be the home of Jeffrey Epstein.

  5. All conversations recorded from any telephones which purported to be that of Jeffrey Epstein that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives or any other electronic format and any written transcriptions)

  6. All conversations recorded from any telephones which purported to be from Jeffrey Epstein's attorneys including Roy Black, Alan Dershowitz or Jack Goldberger, that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives or any other electronic format and any written transcriptions)

  7. All intercepted phone conversations authorized by RRA including but not limited to any one of its attorneys or investigators or anyone retained by or working for RRA related to Jeffrey Epstein that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives or any other electronic format and any written transcriptions).

  8. All intercepted or acquired electronic mail (e-mails) to and from Jeffrey Epstein authorized by RRA including but not limited to any one of its attorneys or investigators or anyone retained by or working for RRA.

  9. All intercepted or acquired electronic mail (e-mails) to and from the attorneys for Jeffrey Epstein including but not limited to: Roy Black, Alan Dershowitz or Jack Goldberger, authorized by RRA including but not limited to any one of its attorneys or investigators or anyone retained by or working for RRA.

  10. All documents related to the amount of Costs that wetre incuffed by RRA in its representation of Jane Doe, L.M. and E.W. and is claimini cit- slaimed

  11. All documents which purport to evidence any transfer of funds or property from Jeffrey Epstein to RRA, Rothstein or any Rothstein-related entity for the settlement of any case (real or fabricated) against Jeffrey Epstein.

  12. All documents which purport to mention any transfer of hinders or property from Jeffrey Epstein to RRA, Rothstein or any Rothstein-related entity for the settlement of any case (real or fabricated) against

'to Ed.. N_ 20. All documents relating lo y>investment, joint-venture or business enterprise involving RRA, Rothstein or 9 othstein-related entity that reference any claim (real or fabricated) against Epstein.

  1. All emails exchanged between any of the following individuals wherein Epstein, a Palm Beach billionaire or similar reference was mentioned:
  • a. othstein Adler am Berger Michael Fisten Kenneth Jenne David Boden Deborah Andrew Bamett Rocberts is and (Rick) Fandry Christina Kitterman Brad
  1. All documents related to or referencing potential deponents in the Jane Doe, L.M. or E.W. cases.
    1. All Q-Task Projects" that refer to Jeffrey Epstein.
    1. AU Q-Task Projects that refer to L.M., E.W., or Jane Doe.

  1. All documents that identify all individuals who were granted access (invited guests) or who had access to the Q-Task Projects referred to in request nos. 23 and 24.

  2. All documents, communications and letters sent by you assessing liens against the recoveries in:

  • a. L.M. v. Epstein, Case No. 502008CA028051XXXXMB
  • b. E.W. v. Epstein, Case No. 502008CA028058XMXMB
  • c. Jane Doe v. Epstein, Case No. 08-CV-80119- RN
  1. All documents related to the Costs that you, as bankruptcy Trustee, are claiming related to L.M., E.W. and Jane Doe's cases against Epstein. This includes any data or electronic printout of Costs which the Trustee of RRA is claiming.

V describing compensation and benefits for 28. itiar mnent agreements or le during his employment with RRA.

  1. All documents from the "Fortress" software program that refer or relate to Jeffrey Epstein.

  2. All documents from the "Fortress" software program that refer or relate to L.M., E.W., or Jane Doe.

  3. For the time period April 1, 2009 through November 5, 2009, all emails to and from any employee, partner, shareholder, attorney, agent or client of RRA that reference anyAthe forting:

  • A.J. DiScala; D3 Capital Club, LLC Bill Clinton;
  • d. Alan Dershowitz;
  • e. David Copperfield;
  • f. Kevin Spacey;
  • g. Chris Tucker;
  • h. Prince Andrew
  • i. Jean-Luc Brunel;
  • j. Tommy Motolla;
  • k. Bill
  • I. Donald Trump.

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA

CASE NO. 09-61780-OV-2LOCH/ROSENBAUM

UNITED STATES OF AMERICA,

Plaintiff,

v.

VARIOUS REAL PROPERTIES PURCHASED BY OR WITH OR ON BEHALF OF SCOTT W. ROTHSTEIN, SPECIFICALLY:

  • ( I) REAL PROPERTY AND APPURTENANCES, LOCATED AT 2307 CASTILLA ISLE, FORT LAUDERDALE, FLORIDA;
  • (2) REAL PROPERTY AND APPURTENANCES, LOCATED AT 2308 CASTILLA ISLE, FORT LAUDERDALE, FLORIDA;
  • (3) REAL PROPERTY AND APPURTENANCES, LOCATED AT 2316 CASTILLA ISLE, FORT LAUDERDALE, FLORIDA;
  • (4) REAL PROPERTY AND APPURTENAN LOCATED AT 30 ISLA BAHIA DRIVE, FORT LAUDERDALE, FLORIDA;
  • (5) REAL PROPERTY AND APPURTENANCES, LOCATED AT 29 ISLA BAHIA DRIVE, FORT LAUDERDALE, FLORIDA;
  • (6) REAL PROPERTY AND APPURTENANCES, LOCATED AT 350 SE Te STREET, UNIT 2840, FORT LAUDERDALE, FLORIDA;
  • (7) REAL PROPERTY AND APPURTENANCES, LOCATED AT 380 CARRINGTON DRIVE, WESTON, FLORIDA;
  • (8) REAL PROPERTY AND APPURTENANCES, LOCATED AT 2133 IMPERIAL POINT DRIVE, FORT LAUDERDALE, FLORIDA;

AND INCLUDING THE FOLLOWING REAL PROPERTIES ("RP"), VEHICLES & VESSELS ("VV"), TANGIBLES ("T"), BANK ACCOUNTS ("BA"), BUSINESS

CO

AS 5)

![](_page_10_Picture_9.jpeg)

INTERESTS ("Br) AND CONTRIBUTIONS ("C"), SPECIFICALLY:

(RP9) REAL PROPERTY AND APPURTENANCES, LOCATED AT 2627 CASTILLA ISLE, FORT LAUDERDALE, FLORIDA;

(RP I 0) REAL PROPERTY AND APPURTENANCES, LOCATED AT 10630 NW 14TM STREET, APT. 110, PLANTATION, FLORIDA;

(RP I 1) REAL PROPERTY AND APPURTENANCES, LOCATED AT 227 GARDEN COURT, LAUDERDALE BY THE SEA, FLORIDA;

(RP12) REAL PROPERTY AND APPURTENANCES, LOCATED AT 708 SPANGLER BOULEVARD, BAY 1, HOLLYWOOD, FLORIDA;

(RP13) REAL PROPERTY AND APPURTENANCES, LOCATED AT 1012 EAST BROWARD BOULEVARD, FORT LAUDERDALE, FLORIDA;

(RPI4) REAL PROPERTY AND APPURTENANCES, LOCATED AT 950 N FEDERAL HIGHWAY, FORT LAUDERDALE, FLORIDA;

(RP15) REAL PROPERTY AND APPURTENANCES, LOCATED AT 350 LAS OLAS BOULEV COMMERCIAL UNIT 2, FORT LAUDERDALE, FLORID )

(RP I 6) REAL PROPERTY AND APPURTENANCES, LOCATED AT 361 SE 9Th t$NE, BOCA RATON, FLORIDA;

(RP17) REAL PROPERTY AND APPURTENANCES, LOCATED AT 1198 N. OLD DIXIE HIGHWAY, BOCA RATON, FLORIDA;

(RP 18) REAL PROPERTY AND APPURTENANCES, LOCATED AT 1299 N. FEDERAL HIGHWAY, BOCA RATON, FLORIDA;

(RN 9) REAL PROPERTY AND APPURTENANCES, LOCATED AT 151 EAST 58 STREET, APARTMENT 42D, NEW YORK, NEW YORK;

(RP20) REAL PROPERTY AND APPURTENANCES, LOCATED AT 11 BLUFF -COVE FARM,

NARRAGANSETT, RHODE ISLAND;

(RP2I ) REAL PROPERTY AND APPURTENANCES, LOCATED AT 15 BLUFF COVE FARM, NARFtAGANSETT, RHODE ISLAND;

(VV I) 1990 RED FERRARI F40 COUPE, VIN: ZFFMN34A5L0087066;

(VV2) 2009 CONVERTIBLE, VIN: SCBDR33W29C059672;

(VV3) 2008 YELLow McLAREN MERCEDES BENZ SLR, VIN: WDDAK76F98M001788; (VV4) 2007 BLACK LIMOUSINE MI EXPEDMON, VIN: I FIFK15557LA59223;

U s."

(VV5) 2009 RED FERRARI 430 SPIDER, VIN: ZFFEW59A380163011;

VIN: SCA I L68557UX23044; 4 AC) (VV6) 2007 SILVER ROLLS ROYCE CONVERTIBLE,

(VV7) 2006 SILVER HUMMER HI, VIN: I 37PH84396E220665;

(VV8) 2008 CADILLAC ESCALADE, VIN: IGYEC63858R234458;

(VV9) 1967 RED CONVERTIBLE C9R, VIN: 1946775104745;

(VV10) 2009 BLACK BucATTi VEYRON EB 16.4, VIN: VF9SA25C28M79515,04,".

(VV I 1)2008 BLUE ROLLS ROYCE DROPHEAD CONVERTIBLE, VIN: SCA2D68528UX 16071;

(VV12) 2006 RED FERRARI F430 SPIDER, VIN: rFFEW59A560148863;

(VV 13) 2008 CHEVROLET CoavErrE, VIN: IGIYY26W485120085,

(VV 14) 2009 CHEVROLET CORVE I I t Z06, VIN: 1G I Y226E9951 11923;

(VV 15)2009 BLUE GRAY MASERATI GRANTURISMO COUPE, VIN: ZAMG145A090042326;

(VV 16) 2009 MERCEDES BENZ, WDBSK71F159F49477;

(VV17) 2007 8T a HULL # WAR87777B707;

(VV18) 33' AQUARNA, HULL # XFA33R74G405;

(VV19) 2009 II' YAMAHA JET SKI, HULL N YAMA366 11809;

(VV20) 2009 II' YAMAHA VS, HULL if YAMA3626I809;

(VV2 I )2009 1 P YAMAHA VS, HuU. NYAMA2679G809;

(VV22) 1999 5Y SEA RAY 540 SUNDANCER, HULL H SERY001899;

(VV23) 2009 YAMAHA JET SKI, HULL tl YAMA4288K809.

(VV 24) 2010 LAMBORCHINI LP-670SY, VIN: ZliWBU8AHXALA03837;

(VV2S) MERCEDES BENZ S65 VR BYTURBO, VIN: WDDEJ79XX8A015189, FLORIDA TAG FIHV490;

(VV26) 2009 RED BMW CONVERTIBLE, VIN: WBALM53529E160836;

(VV27) 2009 MERCEDES BENZ SLK 350 CONVERTIBLE, YIN: WDBWIC58F19F190779, 304 4ECES OF JEWELRY;

1 PONT LIGHTERS;

'SpECES SPORTS MEMORABILIA;

$271,160 IN UNITED STATES CURRENCY;

$1,500 IN UNITED STATES CURRENCY;

(T6) $30,000 IN AMERICAN EXPRESS GIFT CARDS;

CO'S

4 49

(T7) $50,000 IN AMERICAN EXPRESS GIFT CARDS;

(T8) 5 ADDITIONAL WATCHES;

(T9) GUITAR COLLECTION;

(BA I) FIDELITY INVESTMENTS ACCOUNT, IN THE NAME OF SCOTT W. ROTHSTEIN, VALUED AT APPROXIMATELY $1,263,780;

(BA2) GIBRALTAR BANK ACCOUNT IN THE NAME OF WAWW 3 LLC, IN THE APPROXIMATE AMOUNT OF $11

(BA3) GIBRALTAR BANK ACCOUNal IN THE APPROXIMATE AMOUNT OF $53,448.51;

(BA5) GIBRALTAR BANK ACCOUNT- 1< r) /49 IN THE APPROXIMATE AMOUNT OF $995,521.426;

(BA6) BANK POPULAIRE, MOROCCO, BANK/` ACCOUNT 178780211819923220000187, IN THE NAME OF SCOTT ROTHSTEIN, IN THE APPROXIMATE AMOUNT OF $12,000,000;

(BA4) GIBRALTAR BANK ACCOUNT I IN THE APPROXIMATE AMOUNT OF $71,793.06;

(BA7) BANK POPULAIRE, MO IN THE NAME OF AHNICK KHALID, UP TO THE AMOUNT OF

(BA8) BANK POPULAIRE, MOROCCO, ACCOUNT IN THE NAME OF STEVE CAPUT', UP TO THE AMOUNT OF $1,000,000;

(BI 1 ) STOCK CERTIFICATES OR BENEFICIAL T IN 50,000 SHARES OF CAPITAL IN GIBRALTAR PRIVATE BANK & TRUST;

(812) SCOTT W. ROTHSTEIN'S Eourre INTEREST IN QTASK;

(BB) SCOTT W. ROTHSTEIN'S EQUITY INTEREST N BROWARD BANK OF COMMERCE;

(B14) SCOTT W. ROTHSTEIN'S EQUITY INTEREST IN BOVA RISTORANTE;

(B15) SCOTT' W. ROTHSTEIN'S EQUITY INTEREST IN

BOVA CUCINA;

(816) SCOTT W. ROTHSTEIN'S EQUITY INTEREST IN BOVA PRIME;

(B17) SCOTT W. ROTHSTEIN'S EQUITY INTEREST IN CAFE IGUANA, PEMBROKE PINES, FLORIDA;

(818) SCOTT W. ROTHSTEIN'S EQUITY MEREST IN CART SHIELD USA, LLC;

(B19) SCOTT W. ROTHSTEIN'S EQUITY INTEREST TN RENATO WATCHES;

(B11 0) SCOTT W. ROTHSTEIN'S EQUITY INTEREST IN EDIFY LLC;

(BIII) SCOTT W. Roms-rerN's EQUITY INTEREST IN V GEORGIO VODKA;

(8112) SCOTT W. ROTHSTEIN'S EGUrrY INTEREST IN SEA CLUB;

(B113) SCOTT W. ROTHSTEIN'S EQUITY INTEREST IN NORTH STAR MORTGAGE;

(BI14) SCOTT W. ROTHSTEIN'S EQUITY INTERE4TI>Se KM, BUNTER MARKETING;

(B11 5) SCOTT W. ROTHSTEIN'S EQUITY INTEREST IN RRA SPORTS AND ENTERTAINMENT, LLC;

(BI I 6) SCOTT W. RGINSTEIN'S EQUITY INTEREST IN VERSACE MANSION/CASA CASUARINA, INCLUDING I 0 YEAR OPERATING AGREEMENT WITH 2 TEN YEAR OPTIONS;

(0117) SCOTT W. ROTHSTEIN'S EQUITY INTEREST, AND LICENSING RIOT-ITS, TN ALTERNATIVE BIOFUEL COMPANY;

(BB 10 SCOTT W. Rants-run EQUITY INTEREST IN RRA GOAL LINE MANAGEMENT;

re (8119) SCOTT W. ROTHSTEIN'S EQUITY INTEREST IN IRON STREET MANAGEMENT, LLC;

(8120) SCOTT W. ROTHSTEIN'S EQUITY INTEREST IN, AND LOAN TO, AFRICAT EQUITY IG DECIDE;

(B12 I ) SCOTT W. ROTHSTEIN'S EQUITY INTEREST TN, AND RENTS DERIVED FROM DUCKY'S BBQ, LOCATED AT I !98 N. OLD DIXIE HIGHWAY, BOCA RATON, FLORIDA;

(8122) Scan W. ROTHSTEIN'S EQUITY INTEREST IN, AND RENTS DERIVED FROM THE CAR WASH LOCATED AT 1299 FEDERAL HIGHWAY, BOCA RATON, FLORIDA

(B123) PROMISSORY NOTE BY UNIGLOBE IN FAVOR OF SCOTT W. ROTHSTEIN;

(B124) ALL EQUITY INTEREST HELD BY OR ON BEHALF OF SCOTT W. ROTHSTEIN, IN VARIOUS CORPORATIONS AND ENTITIES;

(CI) $6,000 IN CAMPAIGN CONTRIBUTIONS MADE TO ALEX SINK ;AND VOLUNTARILY OFFERED, AND TURNED OVER, TO THE UNITED STATES ON BEHALF OF ALEX SINK;

(C2) $40,000 IN CAMPAIGN CONTRIBUTIONS TO REPUBLICAN PARTY OF FLORIDA, "FLORIDA" ACCOUNT AND VOLUNTARILY OFFERED, AND TURNED OVER, TO THE UNITED STATES BY THE REPUBLICAN PARTY OF F

(C3) $10,000 IN CAMPAIGN CONTRIBUTIONS TO REPUBLICAN PARTY OF FLORIDA, "FEDERAL" ACCOUNT AND VOLUNTARILY OFFERED, AND TURNED OVER, TO THE UNITED STATES BY THE REPUBLICAN PARTY OF FLORIDA;

(C4) $90,000 IN CAMPAIGN CONTRIBUTIONS TO REPUBLICAN PARTY OF FLORIDA AND VOLUNTARILY OFFERED, AND TURNED OVER, TO THE UNITED STATES BY THE REPUBLICAN PARTY OF FLORIDA;

(CS) $5,000 IN CAMPAIGN CONTRIBUTIONS TO REPUBLICAN PARTY OF FLORIDA BY ROTHSTEIN BUSINESS WITTY KNOWN AS WAWW AND VOLUNTARILY OFFERED, AND TURNED OVER, TO THE UNITED STATES BY THE REPUBLICAN PARTY OF FLORIDA;

(C6) $800,000 CHARITABLE DONATION TO JOE DIMAGGIO CHILDREN'S HOSPITAL, WHICH HOSPITAL ADVISED THE UNTIED STATES OF THE DONATION FROM THE ROTHSTEIN FAMILY FOUNDATION;

(CT) $1 ,000,000 CHARITABLE DONATION TO HOLY CROSS HOSPITAL, WHICH HOSPITAL. ADVISED THE UNITED STATES OF THE DONATION FROM THE ROTHSTEIN FAMILY FOUNDATION;

Vr

(O1) S9,600 IN CAMPAIGN CONTRIBUTIONS TO GOVERNOR CHARLIE CRIST AND VOLUNTARILY OFFERED, AND TURNED OVER, TO THE UNITED STATES BY THE OFFICE OF CHARLIE CRIST;

AND

(C9) ALL FUNDS VOLUNTARILY TURNED OVER TO THE UNITED STATES (RS/FBI) SINCE. IN OR ABOUT OCTOBER 28, 2009 IN RESPONSE TO PUBLICITY INVOLVING SCOTT W. ROTHSTEIN,

Defendants.

WARRANT OF ARREST IN REM FOR NON-REAL P4OPEcrIES

TO: THE INTERNAL REVENUE SERVICE, THE UNITED STATES MARSHALS OR ANY OTHER AUTHORIZED FEDERAL LAW EN,OKEMENT OFFICER

WHEREAS, on November 27, 2009, the United Stales)Mf America filed an Amended Verified Complaint for Forfeiture in Rcm against e' ve-named defendants, also referred to as "defendant properties," for the violations of law enumerated in said Complaint [DE #19]; and

WHEREAS, the Court has found that probable cause exists that the defendants are subject to forfeiture;

NOW THEFtE.FORICTeuYre ) hereby commanded to take the defendants into your possession for safe the character or situation of the property is such that the taking of actual possession itpracticable, you shall execute this process by affixing a copy thereof to the in a conspicuous place and/or by leaving a copy of the Amended Verified Complaint and proctivith the person having possession or his agent.

YOU ARE FURTHER commanded to cite and admonish the owner and/or possessor of the defendants, and any person or firm known to claim any interest therein, to file in the United States District Court, 400 North Miami Avenue, Miami, Florida 33128-7788, within thirty (35) days

following receipt of this Warrant, a Verified Claim in accordance with Rule G(5), Supplemental Rules for Admiralty or Maritime Claims and Asset Forfeiture Actions, and to therewith or within twenty (20) days thereafter file an Answer or other responsive pleading to the Amended Verified Complaint, a copy of which Complaint you shall supply with this Warrant, and to serve copies of said Claim and Answer upon the United States Attorney, 99 NE 4th Street, Miami, Florida 33132, Attention: Alison W. Lehr, Assistant United States Attorney, and that upon failure of the owner, possessor or any party claiming an interest in the defendant properties to do so, that the defendant properties may then be forfeited to the United States by default and without further notice or hearing.

AND YOU ARE FURTHER commanded to make due and prompt return of this Warrant to this Court upon its execution.

WITNESS THE HONORABLE

WILLIAM J. ZLOCH
UNITED STATES DISTRICT JUDGE

DATE: 12/12/09

STEVEN LARIMORE, CLERK
UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF FLORIDA

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

Complex Litigation, Fla. R. Civ. P. 1.201

Case No 50 2009CA040800)OOOCMB AO

JEFFREY EPSTEIN,

Plaintiff;

V.

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

CCP)<*/

Defendants.

BANKRUPTCY TRUSTEE'S SNO R PROTECTIVE ORDER

Pursuant to Rule 1.410, H "._ • trustee of the Bankruptcy Estate of Rothstein Rosenfeld Adler, P.A., files this Motion for Protective Order and states:

    1. On November 10, 2009, Rothstein Rosenfeldt Adler, P.A. ("RRA") was put into involuntary bankruptcy. That case is pending as In Re Estate of Rothstein Rosenfeld Adler, P.A., On November 20, 2009, Herbert Stettin was appointed Trustee of RRA. On November 30, 2009, an Order for Relief was entered by this Court.
    1. On April 16, 2010, Plaintiff caused a subpoena duces tecum to be served on the Trustee for production of documents. A copy of the subpoena duces tecum is annexed hereto as Exhibit A. 3 . The Trustee's responsibility under the involuntary bankruptcy filing is to winddown the business affairs of RRA. In that regard, the Trustee has three (3) people in his employ

![](_page_19_Picture_14.jpeg)

and has various professionals whose employment have been approved by the United States Bankruptcy County.

4 . Additionally, Scott Rothstein, who apparently managed the affairs of the law firm, has been criminally charged by the United States of America with various violations of federal law to which he has pled guilty. Associated with those charges, the United States of America seized the law firm's bank accounts. See Exhibit B annexed hereto.

  1. Consequently, the very limited financial resources are *Irlevoted to trying to bring money into the estate as opposed to expending money on unrelated mud party litigation, such as this one.

  2. While the Trustee has indicated in a differed[ t his willingness to try to produce to Mr. Epstein the documents he needs, in tar_ the Trustee's responsibility for '4. winding-up the affairs of the Estate is not • and because of the limited finances available 7 to the Trustee, he requests that the Court order ultall costs associated with responding to Mr. Epstein's subpoena duces tecum be borne by Mr. Epstein and that at least 50% of the estimated costs be paid to the Trustakuiri to any responsibility for undertaking a search for the documents.

  3. TritatdE also requests that the time for responding to the subpoena duces tecum be o until such time as this Court or Mr. Epstein and the Trustee arc able to resolve the issues raised in this Motion for Protective Order.

Wherefore, for the foregoing reasons, the Trustee requests this Court to grant this motion.

Respectfully submitted,

BERGER SINGERMAN
Counsel for the Trustee
200 S. Biscayne Blvd.
Tenth Floor
Miami, Florida 33131
305.755.9500
305.714.4340 (facsimile)

By:

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing was served by U.S. Mail and facsimile on Mr. Robert D. Critton, Jr., 303 Banyan Blvd., Suite 400 West Palm Beach Fl; Mr. Marc Nurik, One East Broward Blvd., Suite 700, Ft. Lauderdale, FL 33301; Mr. Jack Scarola, 2139 Palm Beach Lakes Blvd., West Palm Beach, FL; Mr. Gary [REDACTED], 425 N. Andrews Ave., Suite 2, Fort Lauderdale, FL 33301 and Mr. Jack Goldberger, 250 Australian Ave. South, Suite 1400, West Palm Beach, FL 33401-5012 this [REDACTED] day of May, 2010.

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

CASE NO.: 502009CA040800XXXXMBAG

JEFFREY EPSTEIN,

Plaintiff,

vs.

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

Defendant.
_____/

MOTION FOR PROTECTIVE ORDER

COMES NOW L.M., by and through undersigned counsel and pursuant to Florida Rule of Civil Procedure 1.280(c), and hereby files this Motion for Protective Order regarding the documents and information sought by Plaintiff Jeffrey Epstein in the Deposition Duces Tecum served on Herbert Stettin, Trustee in Bankruptcy for Rothstein Rosenfeldt Adler, PA, ("RRA"), and as grounds states as follows:

    1. L.M. is one of many victims of Epstein's sexual exploitation; as such, her civil lawsuit against Epstein is currently active and pending.
    1. L.M. was represented by attorneys at RRA prior to the collapse of that firm.
    1. Epstein served a deposition duces tecum on Herbert Stettin, trustee for RRA, requesting documents and information that are clearly protected by attorney-

![](_page_22_Picture_22.jpeg)

client and work product privilege. (See Exhibit A, depo duces tecum served on Herbert Stettin as RRA trustee).

    1. Epstein is attempting to use his lawsuit against L.M. as a vehicle to pierce the attorney client and work product privilege and gain access pr privileged information related to L.M.'s civil action against him.
    1. Epstein served Requests for Production on Brad, L.M.'s attomey, who Epstein also named as a Defendant in the instant action; that discovery requests identical information to that souQM ¢ythe Duces Tecum served on Herbert Stettin.
    1. Appropriate work-product and attorney-client privilege objections were made to those requests. (See Exhibit hltsgpsr tein's requests for Production to Brad and answers thereto).
    1. The trustee for RVect iively standing in the shoes of the former RRA attorneys and clients on issues such as this, and thus Epstein cannot request discovery fro RRA trustee to circumvent the privilege.
    1. The discovery Epstein is seeking should not be allowed as it is clearly protected by privilege.

WHEREFORE, L.M. and her counsel respectfully move this Court to enter an Order of protection preventing Epstein from obtaining the discovery he is seeking in his Subpoena Duces Tecum to Herbert Stettin.

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via U.S. Mail and email to all counsel on the attached list on June )2 • 2010.

Jr. Jaffe, Weissing, Fistos & Lehrman, PL, 425 N. Andrews Ave., Suite 2 Fort Lauderdale, FL 33301 (954) 524-2820 (954) 524-2822 fax Atto e Defendant LM.

+o

Gary rmer, Jr. Florida r No.: 914444

Case No.: 502009CA040800XXXXMBAG
Motion for Protective Order

COUNSEL LIST

Robert D. Critton, Jr., Esquire
Michael J. Pike, Esquire
Burman, Critton, Luttier & Coleman LLP
303 Banyan Boulevard, Suite 400
West Palm Beach, FL 33401
Phone: (561)-842-2820
Fax: (561)-844-6929
Attorneys for Jeffrey Epstein

Jack Goldberger
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

Jack Scarola
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
Attorneys for Defendant, Bradley
[REDACTED]

Marc Nurik
Law Offices of Marc S. Nurik
One East Broward Boulevard, Suite 700
Fort Lauderdale, FL 33301
Phone: 954-745-5849
Fax: 954-745-3556
Counsel for Scott Rothstein

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

JEFFREY EPSTEIN

Complex Litigation, Fla. R. Civ. Pro. 1201

Plaintiff,

Case No. 50 2009CA040800XXXXMB AG

v.

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

Defendants.

SUBPOENA DUCES TECUM FOR DEPOSITION - DOCUMENTS ONLY

THE STATE OF FLORIDA

TO: Herbert Stettin, Trustee in Bankruptcy for Roth [REDACTED] Rosenfeldt Adler, PA
C/O James C. Cunningham, Jr., Esq.
Berger Singerman, P.A.
200 South Biscayne Blvd., Suite 1000
Miami, FL 33131

YOU ARE COMMANDED to appear at Prose Court Reporting, 101 NE 3rd Avenue,
Suite #1500, Ft. Lauderdale, FL 33301, on May 19, 2010, 4:00 p.m., bring with you the
following:

See attached Exhibit A

If you fail to appear, you may be in contempt of court.

You are subpoenaed by the attorney whose name appears on this subpoena and unless
excused from this subpoena by the attorney or the Court, you shall respond to this subpoena as
directed.

DATED this 16th day of April, 2010.

BY:

ROBERT D. CRITTON, JR.
(Attorneys for Defendant Jeffrey Epstein)
Burman, Critton, Luttier & Coleman
303 Banyan Blvd., Suite 400
West Palm Beach, FL 33401
561-842-2820

![](_page_26_Picture_175.jpeg)

APR 14

EXHIBIT A

DEFINITIONS AND INSTRUCTIONS

A. "Document" means any written or graphic matter or other means of preserving thought or expression, and all tangible things from which information can be processed or transcribed, including the originals and all non-identical copies, whether different from the original by reason of any notation made on such copy ot otherwise, including, but not limited to, correspondence, memoranda, notes, messages, letters, purchase orders, telegrams, teletype, telefax bulletins, e-mails, electronic data, meetings, reports, or other communications, Interoffice and intra-office telephone calls, diaries, chronological data, minutes, books, reports, charts, ledgers, invoices, worksheets, receipts, returns, trade information regarding fabric, carpets, samples etc..., computer printouts, prospectuses, financial statements, schedules, affidavits, contracts, cancelled checks, transcripts, statistics, surveys, magazine or newspaper articles, releases (and any and all drafts, alterations and modifications, changes and amendments of any of the foregoing), graphs or aural records or representations of any kind, including, without limitation, photographs, charts, graphs, microfiche, microfilm, video tape, recordingsNotion pictures and electronic, mechanical or electric recordings or representations of any kind (including, without limitation, tapes, cassettes, discs and ay 7 recordings), including the file and file cover.

The term "Document" also means any and all computer records, data, files, directories, electronic mail, and information of whatever kind whether printed out or stored on or retrievable from floppy diskette, compact diskette, magnetic tape, optical or magnetic-optical disk, computer memory, hard drive, zip drive, jaz drive, orb drive,

microdisk, external memory stick, software, or any other fixed or removable storage media, including without limitation, all back-up copies, dormant or remnant files, and any and all miscellaneous files and/or file fragments, regardless of the media on which they reside and regardless of whether the data consists in an active file, deleted file, or file fragment.

B. "Communications" means any oral or written statement, dialogue, colloquialism, discussion, conversation or agreement.

C. "Plaintiff" means L.M. (LM. v. Jeffrey EpstelikPalm Beach County Case #502008CA028051)OOaMB), E.W. (E.W. v. Jeffrey Epstein, Palm Beach County Case #502008CA028058XXXXMB), Jane DOIjjane Doe v. Jeffrey Epstein, United States District Court Case #08-civ-80893-Marra/Johnson), and any other person who Is or was represented by Rothstein Rosenfeldt & Adler that has not yet filed an action against Jeffrey Epstein, and any employee, agent or attorney for any plaintiff and/or any other person acting for or on behalf of any plaintiff, or under her authority and control.

D. 'RRA' means Rothstein Rosenfeldt & Adler, P.A.

E. 'Money' means any tangible thing of value.

F. ?tints" include, but are not limited to, court costs, filing fees, Sheriff's ogler necessary service of legal papers or notices or subpoenas, court repokless charges, long distance telephone charges, postage, courier services or Federal Express or UPS, investigative costs, photocopies, faxes. Westlaw computerized research, travel expenses, and witness fees and expert witness fees and costs.

If you are unable to identify each Plaintiff, please contact Robert D Critton, Jr at their names will be provided pursuant to a confidentiality agreement

G. "Trustee" means Herbert Stettin as bankruptcy trustee for RRA.

DUCES TECUM2

  1. For the time period from March 1, 2009 to present, any and all documents between, or on behalf of RRA, its employees or agents or clients, and any third party regarding a purported settlement of any litigation between Jeffrey Epstein and a RRA client or Plaintiff, or the financing of any litigation between Jeffrey Epstein and a RRA client or Plaintiff, (whether existing clients or fabricated clients), including but not limited to:

  2. a. Documents indicating that litigation with Jeffrey Epstein has been settled;

  3. b. Soliciting or receiving money in return for settlement funds allegedly paid or to be paid by Jeffrey Epstein;

  4. c. Soliciting money to help finance ongoing litigation against Jeffrey Epstein;

  5. d. Soliciting money to be given to, or used on behalf of, the Plaintiffs in litigation against Jeffrey Epstein;

  6. e. Communication between third party investors or potential investors and the Plaintiffs or their attorneys involved in litigation against Jeffrey Epstein;

  7. f. Payments made by RRA to or on behalf of any Plaintiff.

  8. Any and all fee agreements that exist or have existed between the following:

  9. a. Any Plaintiff and [REDACTED] J. [REDACTED] or any entity with which he has been associated;

  10. b. Any Plaintiff and the law firm RRA.

  11. All emails, data, correspondence, memos, or similar documents between [REDACTED] J. [REDACTED], Scott W. Rothstein, William Berger and [REDACTED] Adler and/or any attorney or representative of RRA and any investor or third party (person or entity) regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, [REDACTED] or Rick (Rich) Fandrey).

  12. All emails, data, correspondence, memos, or similar documents between [REDACTED] J. [REDACTED], Scott W. Rothstein, and/or any attorney or representative of RRA regarding Jeffrey Epstein or which mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, [REDACTED] or Rick (Rich) Fandrey).

2 Due to the potential volume of documents involved, the parties and the Court should consider appointment of a special [REDACTED] and/or an in camera inspection to address any objections, claims of privilege and generally manage the production of documents.

  1. All agreements or documents of any nature which were provided to or received from an investor or potential investor relating to any case (real or fabricated) involving Jeffrey Epstein and any of the following:
  • c. 0. 11j.
  • b.
  • a. . Fill
  • e. any entity formed by RRA or J. or Scott W. Rothstein to create investment opportunities for third party investors to invest in any plaintiffs case against Jeffrey Epsteirj.

r W. Rothstein and/or any other attomey or investor relating 6. All fee sharing to ny aspect of any Plaintiff's case. agreements between J. Ill t i?A, or Scott r !

J. cuments made available to any investor or potential investor by, RRA, Scott W. Rothstein or any of Scott W. Rothstein's entities to solicit "investors' for any case involving Jeffrey Epstein.

  1. All document reflecting the names and addresses of all individuals or entities who invested or purported to invest in any aspect of any case against Jeffrey Epstein.

  2. All documents evidencing payment of any bill or cost in each Plaintiffs case against Jeffrey Epstein, and the source(s) for said payments of any Costs.

  3. All documents wherein the Trustee of RRA has asserted a lien for attorney's fees or Costs arising out of work done and Costs incurred related to the Plaintiffs' cases during the time Plaintiffs' cases were represented by RRA.

  4. All documents and tangible things retrieved from the trash at 358 El Brillo Way, Palm Beach, Florida which is alleged to be the home of Jeffrey Epstein.

  5. All conversations recorded from any telephones which purported to be that of Jeffrey Epstein that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives or any other electronic format and any written transcriptions)

  6. All conversations recorded from any telephones which purported to be from Jeffrey Epstein's attorneys including Roy Black, Alan Dershowitz or Jack Goldberger, that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives or any other electronic format and any written transcriptions)

  7. All intercepted phone conversations authorized by RRA including but not limited to any one of its attorneys or investigators or anyone retained by or working for RRA related to Jeffrey Epstein that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives or any other electronic format and any written transcriptions).

  8. All intercepted or acquired electronic mail (e-mails) to and from Jeffrey Epstein authorized by RRA including but not limited to any one of its attomeys or investigators or anyone retained by or working for RRA.

  9. All intercepted or acquired electronic mail (e-mails) to and from the attomeys for Jeffrey Epstein including but not limited to: Roy Black, Alan Dershowitz or Jack Goldberger, authorized by RRA including but not limited to any one of its attomeys or investigators or anyone retained by or working for RRA.

  10. All documents related to the amount of Costs that were incurred by RRA in ds representation of Jane Doe, L.M. and E.W. and is claiming or has daimed

  11. All documents which purport to evidence any transfer of funds or property from Jeffrey Epstein to RRA, Rothstein or any Rothstein-related entity for the settlement of any case (real or fabricated) against Jeffrey Epstein.

  12. All documents which purport to mention any transfer of funders or property from Jeffrey Epstein to RRA, Rothstein or any Rothstein-related entity for the settlement of any case (real or fabricated) against Jef.4atein.

  13. All documents relating to any investment, joint-venture or business enterprise involving RRA, Rothstein or a Rothstein-related entity that reference any claim (real or fabricated) against Epstein.

  14. All emails exchanged between any of the following ind vlduals wherein Epstein, a Palm Beach billionaire or similar reference was mentioned:

  • a. S Rothstein
  • b. Adler
  • c. lam Berger
  • d. Michael Fisten
  • e. Kenneth Jenne
  • f. David B
  • g. Deborah
  • h. Andrew arne
  • i. Rocberts
  • j. t ard (Rick) Fandry
  • k. Christina Kitterman
  • I. Brad
  1. All documents related to or referendng potentie' deponents in the Jane Doe, L.M. or E.W. cases.
    1. All Q-Task 'Projects- that refer to Jeffrey Epstein.
    1. All Q-Task Projects that refer to L.M., E.W., or Jane Doe.

  1. All documents that identify all individuals who were granted access (invited guests) or who had access to the O-Task Projects referred to in request nos. 23 and 24.

  2. All documents, communications and letters sent by you assessing liens against the recoveries in:

  • a. L.M. v, Epstein, Case No. 502008CA028051XXXXMB
  • b. E.W. v. Epstein Case No. 502008CA028058XXXXMB
  • c. Jane Doe v. Epstein, Case No. 08-CV-80119-MARla

  1. All documents related to the Costs that you, as bankruptcy Trustee, are claiming related to L.M., E.W. and Jane Doe's cases against Epstein. This includes any data or electronic printout of Costs which the Trustee of RRA is claiming.

  2. nt agreements or letters describing compensation and benefits for during his employment with RRA.

  3. All documents from the 74114/tress" software program that refer or relate to Jeffrey Epstein.

  4. All documents frptlkt J6ttress" software program that refer or relate to L.M., E.W., or Jane Doe. )

  5. For the time period April 1, 2009 through November 5, 2009, all emails to and from any employee, partner, shareholder, attorney, agent or client of RRA that reference any of the following:

  • a. A.J. DiScala;
  • b. D3 Capital Club. LLC
  • c. Bill Clinton;
  • d. Alan Dershowitz;
  • e. David Copperfleld;
  • f. Kevin Spacey;
  • g. Chris Tucker,
  • h. Prince Andrew
  • i. Jean-Luc Brunel;
  • j. Tom II ;
  • k. Bill
  • I. Donald rump.

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

JEFFREY EPSTEIN

v. Plaintiff,

J. individually, ar7L7rirdividually,

Defendants.

Complex Litigation, Fla. R. Civ. Pro.1201

Case No. 50 2009CA040800X)=MB AG

EPSTEIN'S REQUEST TO PRODUC

Defendant, JEFFREY EPSTEIN rEpstein to Fla. R. Civ. P. 1.350, requests that Defendant, J. ), produce or make available for inspection documents responsive to the requests below within thirty (30) days from the date of service: DEER( ri NS AND INSTRUCTIONS

A. 'Document" meant,K y written or graphic matter or other means of preserving thought or expression, and all tangible things from which information can be processed or transcribed, including the originals and all non-identical copies, whether different the original by reason of any notation made on such copy or otherwise, includiric. s ot limited to, correspondence, memoranda, notes, messages, letters, purchase orders, telegrams, teletype, telefax bulletins, e-mails, electronic data, meetings, reports, or other communications, interoffice and intra-office telephone calls, diaries, chronological data, minutes, books, reports, charts, ledgers, invoices, worksheets, receipts, returns, trade information regarding fabric, carpets, samples

![](_page_33_Picture_11.jpeg)

etc..., computer printouts, prospectuses, financial statements, schedules, affidavits, contracts, cancelled checks, transcripts, statistics, surveys, magazine or newspaper articles, releases (and any and all drafts, alterations and modifications, changes and amendments of any of the foregoing), graphs or aural records or representations of any kind, including, without limitation, photographs, charts, graphs, microfiche, microfilm, video tape, recordings, motion pictures and electronic, mechanical or electric recordings or representations of any kind (including, without limitation, tapes, cassettes, discs and ..) recordings), and including the file and file cover. c.i ..

The term "Document' also means any and all mputer records, data, files, directories, electronic mail, and information of whatever whether printed out or c idi stored on or retrievable from floppy diskette, compact diskette, magnetic tape, optical or magnetic-optical disk, computer memory, her S s:Nave, zip drive, jaz drive, orb drive, external memory stick, software, or a any other fixed or removable storage media, including without limitation, all back-up copies, dormant or remnant files, and any and all miscellaneous files and/or file fragments, regardless of the media on which they reside and regardless of whether the data consists in an active file, deleted file, or file fragment.

B. communications" means any oral or written statement, dialogue, colloqulafism, cussion, conversation or agreement.

Ttaintiff means L.M. (L.M. v. Jeffrey Epstein, Palm Beach County Case #502008CA028051)COCXMa), E.W. {E.W. v. Jeffrey Epstein, Palm Beach County Case #50200SCA028058XXXXPAB), Jane Doe (Jane Doe v. Jaffrey Epstein, United States District Court Case #08-civ-80893-fnarra/ ), and any other person who is or was represented by Rothstein Rosenfeldt & Adler that has not

  • e. Documents indicating that litigation with Jeffrey Epstein has been settled; Soliciting or receiving money in return for settlement funds allegedly paid or to be paid by Jeffrey Epstein; Soliciting money to help finance ongoing litigation against Jeffrey Epstein; Soliciting money to be given to, or used on behalf of, the Plaintiffs In litigation against Jeffrey Epstein; Communication between third party Investors or potential investors and the Plaintiffs or their attorneys involved in litigation against

yet filed an action against Jeffrey Epstein, and any employee, agent or attorney for any plaintiff and/or any other person acting for or on behalf of any plaintiff, or under her authority and control.

  • D. -RRA° means Rothstein Rosenfeldt & Adler, P.A.

  • E. °Money-means any tangible thing of value.

F. °Costs° include, but are not limited to, court costs, Sling fees, Sheriff's service and any other necessary service of legal papers or notices of subpoenas, court reporters' charges, long distance telephone charges, postage, courier services or kw, Federal Express or UPS, investigative costs, investigative bills, photocopies, faxes, Westlaw computerized research, travel expenses, ayCvji ess fees and expert witness fees and costs.

  • G. °Trustee" means Herbert Stettin as bankruptcy trustee for RRA.

REQUEST FOR PRODUCTION'

  1. For the time period from March 1, 2009 to present, any and all documents between, or on behalf of RRA, its employees or agents or clients, and any third party regarding a purported settlement of any litigation between Jeffrey Epstein and a RRA client or Plaintiff, or the financing of any litigation between Jeffrey Epstein and a RRA client or Plaintiff, (whether existing clients or fabricated clients), including but not limited to:

Due to the potential yogi documents involved, the parties and the Court should consider appointment of a special and/or an in camera inspection to address any objections, claims of privilege and generally manage the production of documents.

Jeffrey Epstein;

  • f. Payments made by RRA to or on behalf of any Plaintiff.
  1. Any and all fee agreements that exist or have existed between the following:
  • a. Any Plaintiff and J. has been associated;
  • b. Any Plaintiff and the law firm RRA or any entity with which he

All ails, data, correspondence, memos, or similar documents between J. , Scott W. Rothstein, William Berger andjMS Adler and/or any attorney or representative of RRA and any investor or thir c: pa (person or entity) regarding Jeffregiitriidriihich mentions Jeffrey Epstein (including Mike Fisten, Kenneth Jenne, or Rick (Rich) Fandrey).

. ails, data, correspondence, memos, or similar documents between J. , Scott W. Rothstein, and/or any attorraL9r representative of RRA regarding e e hich mentions Jeffrey Ep (including Mike %ten, Kenneth Jenne, or Rick (Rich) Far*eyk

V 5. All agreements or documents of any nature which were provided to or received from an investor or potential investor relating to any case (real or fabricated) involving Jeffrey Epstein and any of the following:

  • a. Ia. Rothstein
  • b. J. Edwards
  • c.
  • e. any entity' fohectSby RRA or J. or Scott W. Rothstein to create InvestmerRippo um es for third party investors to invest in any plaintiffs case against Jeffrey Epstein

  1. All fee sharing agreements between J. RRA, or Scott W. Rothstein and/or any other attorney or inves or re ating o any aspect of any Plaintiffs case.

  2. Al documents made available to any investor or potential investor by Bradley J. Edwards, RRA, Scott W. Rothstein or any of Scott W. Rothstein's entities to solicit "investors" for any case involving Jeffrey Epstein.

  3. All document reflecting the names and addresses of all individuals or entities who invested or purported to invest in any aspect of any case against Jeffrey Epstein.

  4. All documents evidencing the Costs and payment of any bill or Costs in each Plaintiffs case against Jeffrey Epstein, and the source(s) for said payments of any Costs.

  5. All documents received by you or your current firm wherein the Trustee of RRA has asserted a lien for attorney's fees or Costs arising out of work done and Costs incurred related to the Plaintiffs' cases during the time Plaintiffs' were represented by RRA.

  6. All documents and tangible things retrieved from the trash at 358 El Brillo Way, Palm Beach, Florida which is alleged to be the home of Jeffrey Epstein.

  7. All conversations recorded from any telephones which purported to be that of Jeffrey Epstein that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives or any other electronic format and any written transcriptions).

  8. All conversations recorded from any telephones which pufported to be from Jeffrey Epstein's attorneys including Roy Black, Alan Dershowitz or Jack Goldberger, that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives or any other electronic format and any written transcriptions).

  9. All intercepted phone conversations au thorady RRA including but not limited to any one of its attorneys or investigators or anyone retained by or working for RRA related to Jeffrey Epstein that are saved or stored in any media (audio tapes, CDs, DVDs, zip drives, hard drives or any othe. electronic format and any written transcriptions).

  10. All intercepted or acquired ic mail (e-mails) to or from Jeffrey Epstein authorized by RRA including but not limited to any one of its attorneys or investigators or anyone retained by or working for RRA.

  11. All intercepteror'icquired electronic mail (e-mails) to and from the attorneys for Jeffrey Epstein Including but not limited to: Roy Black, Alan Dershowitz or Jack Goldberger, authorized by RRA including but not limited to any one of its attorneys or investigators or anyone retained by or working for RRA.

  12. All documents supporting the contention that a sexual assault took place on an airplane purportedly owned by Jeffrey Epstein or a Jeffrey Epstein entity at any time between 1998 and 2005.

  13. All documents related to the amount of all Costs that were incurred by you in the representation of you and/or your law firm in representing Jane Doe, L.M. and E.W. prior to joining RRA.

  14. All documents setting forth to the amount of Costs were incurred by RRA in its representation of Jane Doe, L.M. and E.W. during the time you were employed by RRA (or that is being claimed by the Trustee).

  15. In the attached transcript dated July 31, 2009, you stated to Judge Hatele with regard to the E.W. and L.M. cases the following:

What the evidence is really going to show is that Mr. Epstein - at least dating back as far as our investigation resources have permitted, back to 1997 or '98 — has every single day of his life, made an attempt to sexually abuse children.

Were not talking about five, we're not talking about 20, we're not talking about 100, we're not talking about 400, which I believe, is the number known to law enforcement, we are talking about thousands of children, and it is through a very 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 these girls."

(A) Provide all documents to support this assertion including any documents which are the source of the informs

  1. All documents related to or mentioning potential deponents In the Jane Doe, L.M. or E.W. cases.

  2. All documents that support your claim of dam In your counterclaim in this case.

  3. The written fee agreement with the Searcy Denney firm for their representation of you in this case.

  4. All ernails exchanged between you (or anyone of your behalf) and one or more of the following individuals wherein Epstein, a Palm Beach billionaire or a similar reference was mentioned:

  • a,
  • b.
  • C. TT !Um Berger
  • d. Michael Fisten e, Kenneth Jenne fs David Bolt. ) othstein Adler c5 Deborah ,. chard (Rick) Fandrey
    • k. Christina Kitterman.

  1. A copy of your RRA business card.

  2. Any employment agreements, letter agreements or memos given to you by RRA or a representative or agent of RRA describing your compensation and benefits at RRA.

  3. All documents and communications from Herbert Stettin, as bankruptcy Trustee for RRA, asserting liens against recoveries in:

  • a. L.M. v. Epstein, Case No. 502008CA028051XXXXMB
  • b. E.W. v. Epstein, Case No. 502008CA028058XXXXMB
  • c. Jane Doe v. Epstein, Case No. 08-CV-80119-MARRA/ [REDACTED]

Certificate of Service

I HEREBY CERTIFY that a true copy of the foregoing was sent by fax and U.S. Mail to the following addressees on this 12th day of April, 2010:

Gary M. [REDACTED] Jr., Esq.
[REDACTED] Jaffe, Weissing, [REDACTED] Fistos
& Lehman, PL
425 N. Andrews Avenue, Suite 2
Fort Lauderdale, FL 33301
954-524-2820
954-524-2822 - fax
Attorneys for Defendant, L.M.

Jack Alan Goldberger, Esq.
Atterbury Goldberger & Weiss, P.A.
250 Australian Avenue South
Suite 1400
West Palm Beach, FL 33401-5012
Fax: 561-835-8691
Co-Counsel for Defendant Jeffrey Epstein

Jack Scarola, Esq.
Searcy Denney Scarola Bamhart &
Shipley, P.A
2139 Palm Beach Lakes Blvd.
West Palm Beach, FL 33409
686-6300
383-9424 F
Attorneys for Defendant Bradley Edwards

MARC S. NURIK, ESQ.
Law Offices of Marc S. Nurik
One East Broward Boulevard
Suite 700
Fort Lauderdale, FL 33301
954-745-5849
954-745-3556 Fax
Attorneys for Defendant Scott Rothstein

BURMAN, CRITTON, LUTTIER & COLEMAN, LLP
303 Banyan Boulevard
Suite 400
West Palm Beach, FL 33401
(561) 842-2820
(561) 253-0164 Fax

By:

(Counsel for Defendant Jeffrey Epstein)

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

CASE NO.: 502009CA040800XJOO(MBAG

JEFFREY EPSTEIN,

Plaintiff,

vs.

T I in ividually, J. , individually, and . indiv ua,

/

Defendant.

DEFENDANT J. EDWARDS RESPONSE TO PLAINTIFF'S REQUEST IM PIRODUCTION DATED APRIL 12, 2010

Defendant, J. EDWARDS, hereby files his Response to Request for

Production propounded by Plaintiff on April 12, 2010 as follows:

    1. None.
    1. a. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence.
    • b. None.
    1. Objection as to communications to or from investigators as that is protected by the work-product and /or attorney-client privilege.
    1. Objection; any such communications are protected by the work-product and /or attorney-client privilege.
    1. None.
    1. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence; vague; overbroad, without waiving objection, there are no fee agreements with any Investor.
    1. None.
    1. None. < < S42 )
    1. None.
    1. None.
    1. None. ( S \
    1. None.
    1. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence; vague; overbroad, ambiguous.
    1. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence.
    1. None.
    1. None.
    1. Objection, relevance, not reasonably calculated to the discovery of admissible evidence.
    1. Objection, relevance, not reasonably calcine OM to the ) discovery of admissible evidence. C
    1. Objection, relevance, not reasonably calculated to lead to the discovery of admissible evidence and protected by the work-product privilege.
    1. Objection, vague overbroad and any and all such documents are protected by the work-product privilege.
    1. Objection, vague overbroad and any and all such documents are protected by the work-product and attorney-client privilege.
    1. Not yet determined.

No.: 502000CACL40800XXYJGABAG Response to Request for Production dated 4/12/10

    1. Objection.
    1. Objection; attorney-client privilege and/or work-product privilege.
    1. None in Defendant's possession.
    1. None.
    1. None in Defendant's possession.

CO g

Case No.: 502009CA040800XXXXMBAG
[REDACTED] Response to Request for Production dated 4/12/10

CERTIFICATE OF SERVICE

I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished via 1FAX AUD U.S. Mail to all counsel on the attached list on April 11th, 2010.

Jack Scarola
Searcy Denney Scarola Bamhart & Shipley, P.A.
Attorneys for Defendant, Bradley Edwards
2139 Palm Beach Lakes Boulevard
West Palm Beach, Florida 33409
Phone: (561) 686-6300
Fax: (561) 383-9461

Jack Scarola
Florida Bar No.: 169440

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