EFTA01074140.pdf

pot Phillips Point West Fowler White Burnett N> ATTORNEYS AT LAW.% 777 South Ftagler Drive West Palm Beach, Florida 33401 www.fowler-white.com Joseph L. Ackerman, Jr. direct March 24, 2011 fax jackerman@ ow vlute.corn VIA EMAIL AND FIRST CLASS MAIL Charles Lichtman, Esq. Berger Singerman 350 East Las Olas Boulevard, Suite 1000 Ft. Lauderdale, FL 33301-4215 Re: Jeffrey Epstein v. Scott Rothstein, individually, Bradley J. Edwards, individually, and L.M., individually PBC Circuit Case No. 502009CA040800)OOOCMBAG Our File No. 80743 Dear Chuck: Enclosed please find a proposed Agreed Order that I have sent to counsel in the Epstein v. Rothstein, Edwards, et aL matter which limits the scope of the subpoena that we previously served upon Mr. Stettin. A copy of that Subpoena Duces Tecum is enclosed for your easy reference. This order is based on what we understood that you were willing to produce. Would you kindly confirm my understanding. If acceptable to you, I believe then that your Motion for Protective Order scheduled for March 28, 2011 before Judge Crow is not necessary and may be canceled. Please advise. Thank you for your courtesies. Sincerely yours, oseph L. Ackerman, Jr. Enclosures WAS074METTR861-Letter Grades La:Mina& Esquire • proposed agreed ordera.A.docx Miami • Fort Lauderdale • West Palm Beach EFTA01074140  IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA0408003OOOCMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. AGREED ORDER THIS MATTER came before this court on Motions for Protective Order filed on behalf of Bradley J. Edwards, Elizabeth Kim and Christina Finch. This Court having reviewed the motion, having been advised that there is no objection to the entry of this Order, it is hereby ORDERED AND ADJUDGED that the motion is granted in part and denied in part as follows: 1. The motion is denied to the extent that the trustee may provide last known home address, home telephone number, and cellular telephone number for the following individual(s): Cara L. Holmes, Jacqui Johnson, Mercedes Finch, Carl Linder, Jonathan Birkman, Rob Buschel. 2. The motion is granted to the extent it requests records containing any other information other than that set forth above in paragraph 1. EFTA01074141  Epstein v Rothstein, Edwards, etc. CASE NO. 502009CA040800XXXXMBAG Agreed Order on Edwards, Kim and Finch re MPO 3. This Order is without prejudice to the Plaintiff to seek further relief should the information provided by the trustee is not sufficient to allow the Plaintiff to locate the above- named individual(s) for the purpose of serving a subpoena for deposition. DONE AND ORDERED this day of in chambers at West Palm Beach, Palm Beach County, Florida. Judge David F. Crow, Circuit Judge Copies Furnished to: See attached Service List -2- EFTA01074142  Epstein v Rothstein, Edwards, etc. CASE NO. 502009CA040800XXXXMBAG Agreed Order on Edwards, Kim and Finch re MPO SERVICE LIST Epstein v Rothstein - 502009CA040800)CCOCAIBAG Joseph L. Ackerman, Esq. Fowler White Burnett P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, Florida 33409 Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Fort Lauderdale, Florida 33301 Bradley J. Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Charles H. Lichtman Berger Singermann 350 Las Olas Blvd, 10th Floor Ft. Lauderdale, FL 33301 Counselfor Trustee, Herbert Stettin -3 EFTA01074143  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, BRADLEY L EDWARDS, individually, and L.M., individually, Defendants. SUBPOENA FOR DEPOSITION DUCES TECUM THE STATE OF FLORIDA: TO: Records Custodian, Herb Stettin, Trustee in Bankruptcy for Rothstein Rosenfeldt & Adler, P.A. do James C. Cunningham, Jr. Berger & Singennan, 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 Brickell 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 lime and place the following: See Attached Schedule "A" If you fail to appear, you may be in contempt of court. EFTA01074144 Epstein v Rothstein/Edwards Case No. 502009CA040800XXXXMBAG 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. For the Court By: \Arnen-vt-P4-" Joseph L. Ackerman, Jr., sq. FBN. 295354 Christopher E. Knight, Esq. FBN. 607363 Joseph L. Ackerman, Jr., Esq. Lilly Ann Sanchez, Esq. Fowler White & Burnett, P.A. Attorneysfor Plaintiff, Jeffrey Epstein Espirto Santo Plaza 1395 Brickell Avenue, 14th Floor Miami, FL 33131 Telephone: Facsimile: 2 EFTA01074145  Epstein v Rothstein/Edwards Case No. 502009CA040800XXXXMBAG Subpoena DT/Herb Stettin, Trustee RRR/RC EPSTEIN v ROTHSTEIN, EDWARDS SCHEDULE "A" DUCES TECUNUllerb 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 forms, 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 ID on the following: 1. Cara L. Holmes 2. Jacqui Johnson 3. Mercedes Estrada 4. Elizabeth Kim 5. Christina Fitch 6. Carl Linder 7. Jonathan Birkman 8. Rob Buschel WAS2235‘SHBDT866-Subpoena UT for Deposition- Herb Stettin, Trustee 4I.A.6scx 3 EFTA01074146