# Profoundd archive — Epstein Files
# Bates number: EFTA00728315
# Title:        IN THE CIRCUIT COURT OF THE
# Dataset:      9
# Pages:        8
# Images:       8 detected
# Tags:         epstein, doj, dataset-9, image-described
# Source PDF:   https://profoundd.com/epstein-docs/EFTA00728315/download
# Doc viewer:   https://profoundd.com/epstein-docs/EFTA00728315
#
# Text below is what Profoundd has extracted from the source PDF.
# 'ocr-enriched' tag means OCR was applied to scan-only pages.
# Image descriptions are AI-generated factual captions (llava:13b).
#----------------------------------------------------------------------

=== SUMMARY ===
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, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant. NOTICE OF HEARING (MOTION CALENDAR) To: All Counsel of Record YOU ARE HEREBY NOTIFIED that the undersigned has called up for hearing the following: MOTION FOR PROTECTIVE ORDER DATE: Monday, April 19, 2010 TIME: 8:45 A.M. JUDGE: The Honorable


=== EXTRACTED TEXT ===
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, 
BRADLEY J. EDWARDS, individually, 
and L.M., individually, 
Defendant. 
NOTICE OF HEARING 
(MOTION CALENDAR) 
To: All Counsel of Record 
YOU ARE HEREBY NOTIFIED that the undersigned has called up for hearing the 
following: MOTION FOR PROTECTIVE ORDER 
DATE: Monday, April 19, 2010 
TIME: 8:45 A.M. 
JUDGE: The Honorable David F. Crow 
PLACE: Palm Beach County Courthouse, Room 9C 
EFTA00728315
Notice of Hearing 
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 April ill  , 2010. 
Gary M. Farmer, Jr. 
Fanner, Jaffe, Weissing, 
Edwards, Fistos & Lehrman, PL 
425 N. Andrews Ave., Suite 2 
Fort Lauderdale, 301 
Attorney nt L.M. 
By: 
Gary Farmer, Jr. 
Florida Bar No.: 914444 
EFTA00728316
Notice of Hearing 
COUNSEL LIST 
Robert D. Critton, Jr., Esquire 
Michael J. Pike, Esquire 
Burman, Critton, Luttier & Coleman LLP 
303 Banyan Boulevard, Suite 400 
West Palm FL 33401 
Phone: 
Fax: 
Attorneys for Jeffrey Epstein 
Jack Goldberger 
Atterbury, Goldberger & Weiss, P.A. 
250 Australian Avenue South 
Suite 1400 
West Palm Beach. FL 33401 
Phone: 
Fax: 
Attorneys for Jeffrey Epstein 
Jack Scarola 
Searcy Denney Scarola Barnhart & Shipley, P.A. 
2139 Palm Beach Lakes Boulevard 
West Palm Beach, Florida 33409 
Phone: 
Fax: 
Attorneys or e endant, Bradley Edwards 
Marc Nurik 
Law Offices of Marc S. Nurik 
One East Broward Boulevard, Suite 700 
Fort Lauderdale, FL 33301 
Phone: 
Fax: 
Counsel for Scott -Rothstein 
Copies Furnished to: 
Judicial Assistant to Judge Crow with motion(s) 
EFTA00728317
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, 
BRADLEY J. EDWARDS, individually, 
and L.M., individually, 
Defendant. 
MOTION FOR PROTECTIVE ORDER 
L.M., pursuant to Florida Rule of Civil Procedure 1.280(c), hereby files this 
Motion for Protective Order to prevent the depositions of any private investigators who 
are working on or have worked on the case of L.M. v. Epstein and as grounds therefore 
would state: 
1. In June of 2008, Jeffrey Epstein plead guilty to two felony cases related to his 
sexual abuse of minors, and he was incarcerated and forever labeled a sex 
offender; he remains on community control for these offenses as of the date of 
this motion. 
2. L.M. was one of his many (thought to be in the hundreds) of underage victims. 
EFTA00728318
Case No.: 502009CA040800>00C<MBAG 
Motion for Protective Order 
3. On September 11, 2008, L.M. filed a civil complaint against Jeffrey Epstein for 
Mr. Epstein having molested L.M. on many occasions when she was a minor 
child. 
4. The case was originally filed by Brad Edwards while at the law firm of Brad 
Edwards and associates. 
5. In or about April of 2009, Brad Edwards went to work for Rothstein Rosenfeldt 
Adler (RRA), and his cases, including the case of L.M. v. Jeffrey Epstein, 
became cases of the RRA law firm. 
6. The case of L.M. versus Jeffrey Epstein was litigated through RRA from April 
2009 until the firm's dissolution in October of 2009. 
7. The law firm of RRA, like most if not all law firms, hired private investigators to 
perform investigative work in anticipation and furtherance of litigation. 
8. Several private investigators, including Michael Fisten and Richard Fandry, 
were hired by RRA to perform investigative work on the L.M. case, in 
anticipation and furtherance of litigation. 
9. As has been well publicized, RRA suddenly disbanded in October/November 
2009 when it was discovered that the firm's President, Scott Rothstein, stole 
firm money, which forced the firm into bankruptcy and it was ultimately 
uncovered that Mr. Rothstein ran a ponzi scheme our of the RRA law firm and 
consequently pled guilty to various federal crimes. 
2 
EFTA00728319
Case No.: 502009CA040800XXXXMBAG 
Motion for Protective Order 
10. L.M. is one of many females that was molested by Mr. Epstein as a minor, and 
as such the 20-plus lawsuits related to Mr. Epstein being a serial child 
molester have also received extensive publicity. 
11. It should be noted that Mr. Epstein has not denied any of the claims alleged by 
these children against him, including those by L.M., and has instead relied on 
his Invocation of the Sth amendment as his sole defense in all of the filed civil 
cases. 
12. On December 7, 2009, Jeffrey Epstein, in an attempt to exploit the demise of 
RRA, filed this frivolous lawsuit against Scott Rothstein, Brad Edwards, and 
L.M., alleging basically that the three defendants conspired to sell settlements 
of cases against Jeffrey Epstein to third party investors. 
13. Jeffrey Epstein filed this lawsuit, despite knowing that he could not 
substantiate the claims and in fact taking the 5th in his deposition in this case 
where he is a Plaintiff on all issues relevant to his claims. 
14. The claims are completely unfounded, and there is an outstanding 57.105 
letter to Mr. Epstein's attorney that was sent on behalf of Brad Edwards and 
L.M.; those Motions will be before this court after the expiration of the 21 day 
notice period. 
15. On March 23, 2010, Mr. Epstein took a day long deposition of attorney Brad 
Edwards (who is himself represented by Jack Scarola of Searcy Denney 
Scarola Barnhart and Shipley), and the questions were meant to invade 
3 
EFTA00728320
Case No.: 502009CA040800)O0O(MBAG 
Motion for Protective Order 
attorney-client and work-product privilege relation to the investigation of the 
cases against Jeffrey Epstein. 
16. Jeffrey Epstein has now noticed the depositions of Michael Fisten and Richard 
Fandry, both private investigators that were hired to perform investigative work 
on behalf of L.M. in pursuit of her cases against Jeffrey Epstein. Both 
depositions have been noticed unilaterally by Epstein for April 19, 2010. 
17. Neither of these investigators are witnesses on any witness list nor is there 
any intent by L.M. to call either investigator as a witness. 
18. This Motion has been filed at the undersigned's first opportunity and noticed 
for hearing in accordance with the Court's local rules. 
Memorandum in Support of Motion 
Information relating to a matter which is the subject of litigation, which is 
received by a party's attorneys from investigators and adjusters in anticipation of or 
connected with litigation, is protected by the work product privilege. 501 Nevin v. Palm 
Beach County School Board, 958 So.2d 1003 (Fla. lit DCA 2007), citing Seaboard Air 
Line R. Co. v. Timmons,  61 So.2d 426 (Fla. 1952); Federal Express Corp. v. Cantawav, 
778 So.2d 1052 (Fla. 4th DCA 2001). Florida cases are clear that it is improper and 
impermissible to allow the taking of the deposition of an opposing party's investigator, 
so long as the investigator has not been listed as witnesses, as such a deposition would 
necessarily invade the work-product privilege and irreparably prejudice the case. See 
4 
EFTA00728321
Case No.: 502009CA040800XXXXMBAG 
Motion for Protective Order 
Huet v. Tromp, 912 So.2d 336 (Fla. 5th DCA 2005): see also 5500 North Corporation v. 
Willis, 729 So. 2d 508 (Fla. 5th DCA 1999). 
In this case, any questions by Jeffrey Epstein would only seek information 
related to the investigations of the civil actions against Mr. Epstein, and would thus 
clearly invade the work-product privilege. As such, this court must grant this Protective 
Order to prevent the depositions of these investigators from being taken. 
WHEREFORE, L.M. requests this Court to enter a protective order as set forth 
above. 
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 April 
Gary M. Farmer, Jr. 
Farmer, Jaffe, WeissIn°, 
Edwards, Flstos & Lehrman, PL 
425 N. Andrews Ave., Suite 2 
Fort Lauderd 33301 
Attorn-ys 9klant L.M. 
cins44_ arr. Gary M. Farmer, Jr. 
Florida Bar No.: 914444 , 2010. 
By: 
5 
EFTA00728322



=== IMAGE DESCRIPTIONS ===
[Image 1] The image appears to be a scanned document, possibly a court order or legal document. It contains text and numbered paragraphs, which are typical of legal documents. The text is too small to read in detail, but it seems to be related to a legal case or investigation. There are no visible names, dates, places, or logos that can be discerned from this image. The document is structured with headings 

[Image 2] The image shows a document with text, which appears to be a legal or official document. The text is in English and includes numbered paragraphs, each with a heading. The document mentions a case number and includes references to legal proceedings, such as "Plaintiff" and "Defendant." There are also references to specific individuals, including "Mr. Epstein," "Jeffrey Epstein," and "Scott Rothstein

[Image 3] The image is a document scan, specifically a page from a legal case file. The document is titled "Case No. 1:09-cv-00001-LJM-BMK," indicating it is a civil case filed in the United States District Court for the District of Columbia. The document appears to be a motion or a brief, as indicated by the numbered points and the formal legal language. The text discusses legal matters such as jurisdictio

[Image 4] The image is a document scan, specifically a court order or a legal document. It contains text and signatures, indicating it is an official document. The visible text includes the names of individuals, a date, and a reference to a case number. The document is signed by a judge or a court official, and there are signatures at the bottom, which are likely those of the parties involved in the case or

[Image 5] The image shows a document, which appears to be a court order or a legal notice. It is a formal document with a header that includes the name of the court, the case number, and the names of the parties involved. The body of the document contains a statement of the case and the details of the order or notice. The visible text includes the names of the parties, the date of the order or notice, and t

[Image 6] The image is a photograph of a document, specifically a page from a court case. The document is titled "Counsel List" and lists the names of attorneys and their respective law firms. The text is black on a white background, and the document appears to be a formal legal document. The names, law firms, and contact information are visible, but the specific details of the case are not provided in the