IN THE CIRCUIT COURT OF THE

EFTA00616212 Dataset 9 5 pages Download original PDF Download as text
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, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). MOTION FOR PROTECTIVE ORDER Interested Person, CHRISTINA FITCH, by and through undersigned, moves this Honorable Court for the entry of a protective order with respect to discovery sought pursuant to the attached Notice and in support would show that the document production described in the Notice is not reasonably calculated to lead to the discovery of admissible evidence and unreasonably invades the privacy rights of third-parties. I HEREBY CERTIFY that a true and correct copy of t e foregoing has been furnished by Fax and U.S. Mail to all Counsel on the attached list, this 44" day of March, 2011. FARMER, JAFFE, WEISS1NG, EDWARDS, FISTOS & LEHRMAN, PL Attorneys for Plaintiff(s) 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Fl 33301 Bradley J. Edwards Florida Bar No. Attorney for Christina Fitch EFTA00616212 Edwards adv. Epstein Case No.: 502009CA0401300XXXXMBAG Motion for Protective Order (Stettin) COUNSEL LIST Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Marc S. Nurik Law Offices of Marc S. Nur& One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 MOM Joseph L. Ackerman, Jr., Esquire Fowler White Burnett, P.A. 901 Phillips Point West 777 S Flagler Drive 01-6170 Jack Scarola Searcy Denney Scarola Barnhart & Shipley 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 2 EFTA00616213 03/04/2011 16:02 FAX 16818811672 eJ0002/0004 JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Complex Litigation, Ha. R. Civ. Pro.1201 Case No. 50 2009CA040800)QO(XMB AG SUBPOENA FOR DEPOSITION DUCES TECUM THE STATE OF,i7LORIDA: • TO: Records Custodian, Herb Stettin, Trustee in Bankruptcy for Rothstein Rosenfeldt & Adler, P.A. c/o James C. Cunningham, Jr. Berger 8c-Singerman, P.A. 200 South Biscayne Boulevard, Suite 1000 Miami, FL 33131 YOU ARE COMMANDED to appear before a person authorized by law to take depositions at the law offices of Fowler White Burnett, P.A., Espirto Santa Plaza, 1395 thicken Avenue, 14th Floor, Miami, FL 33131 on Wednesday, March 16, 2011, at 11:00 a.m., for the taking of your deposition in this action and to have with you at that time and place the following: See Attached Schedule "A" If you failt to appear, you may be in contempt of court. EFTA00616214 03/04/2011 16:03 FAX 16618811672 a0003/0004 • Epstein v Rothstein/Bdwards Case No. 502009CA040800XXXXNEBAG Subpoena DT/Herb Stettin, Trustee RRR/RC You are subpoenaed to appear by the following attorney, and unless excused from this subpoena by this attorney or the court, you shall respond to this subpoena as directed. Dated on March 4, 2011. Joseph L. Ackeritian, Jr., Esq. Lilly Ann Sanchez, Esq. Fowler White & Burnett, P.A. Attorneys for F$'ttj ...repay Epstein Espirto Santo Plaza 1.395 Nickell Avtnue, 14th Floor 3313 IA !.. 2 For the Court By: Jr., Jo ph L. Ackeaman, Jr., q. FBN. 295354 FBN Chris o her E. Knight, Esq. EFTA00616215 03/04/2011 16:03 FAX 15618817072 Qb0004/0004 Epstein v Rothstein/Edwards Case No. 502009CA040800XXXXMBAG Subpoena DT/Herb Stettin, Trustee RRR/RC EPSTEIN v ROTHSTEIN, EDWARDS SCHEDULE "A" DUCES TECUIVI/Hcrh Stettin, Trustee RRA/RC Deposition: Any and all employment records for the following employees at Rothstein, Rosenfeldt, Adler, P.A. ("RRA"), that shows her full name, residence address, telephone, social security number, date of birth, application for employment at RRA, I-9 forms, W-4 fauns, application(s) for insurance benefits, payroll records and pay stubs, all references/emergency contacts which will include names, addresses and telephone numbers and drivers license information and a photocopy of any documents RRA took a photocopy of with picture D3 on the following: 1. Cara L. Holmes 2. Jacqui Johnson 3. MercedesiEstmda 4. ElizabethICim 5. Christina Fitch • 6. Carl Linder 7. Jonathan:Dirkman 8. Rob Busbhel wm2unsumnuosab nymcaradkowido.nduswiti Nrmoteauusonc 3 EFTA00616216

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[Image 1] The image shows a document, which appears to be a court order or a legal document. It is a scan of a paper document, and the visible text includes the names of individuals, a case number, and a date. The document is titled "MOTION FOR LEAVE TO FILE SUPPLEMENTAL PLEADINGS" and mentions a case number. The names of the individuals involved are redacted, and the document is signed by a judge or a cour [Image 2] The image shows a document that appears to be a letter or a form, possibly related to legal or official correspondence. The document is dated "2/25/99" and is addressed to "Robert E. White, Esq." from "Scott A. Sherman, Esq." The visible text includes the names of the sender and recipient, the date, and the address of the sender. The document is signed at the bottom by "Scott A. Sherman, Esq." The [Image 3] The image shows a document with text, which appears to be a letter or a report. The document is titled "REPORT OF THE SPECIAL REPRESENTATIVE OF THE SECRETARY-GENERAL FOR THE MIDDLE EAST PEACE PROCESS." It mentions names such as "Kofi Annan," "Mahmoud Abbas," "Ariel Sharon," and "Christian Berger." The document is dated "2003" and mentions "Palestine" and "Israel." The visible text includes section [Image 4] The image shows a document that appears to be a court order or a legal notice. It is a scanned document with visible text and signatures. The text includes the names of individuals, a date, and a reference to a case number. The document is addressed to a specific person and mentions a court case. The visible signatures are likely those of the court officials or the parties involved in the case. Th [Image 5] The image is a document scan, specifically a court document titled "Court Order." It lists the names of the parties involved, the date of the order, and the court location. The visible names include the plaintiff, the defendant, and the court. The document is a formal legal document with a header and footer, and it appears to be a standard court order with a structured layout.