UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION www.flsb.uscourts.gov IN RE: CASE NO.: 09-34791-RBR ROTHSTEIN ROSENFELDT ADLER, P.A., CHAPTER 11 Debtor. MOTION FOR EMERGENCY HEARING AND FOR A STAY OF COURT ORDER DIRECTING PREPARATION OF PRIVILEGE LOG Movant, LM, through counsel, pursuant to L.R. 9075-I hereby requests an emergency hearing before December 28, 2010 and moves to briefly stay enforcement of its Order [DE 1068] compelling LM and her counsel Fanner, Jaffe, Weissing, Edwards, Fistos, & Lehrman, P.L. ("FJW") to produce a privilege log in order to permit the state court: (1) to first rule on the pending motions for summary judgment and for protective order which make the privilege log and production irrelevant; and/or (2) to permit FJW sufficient time to prepare an appropriate privilege log relating to documents which now exceed 24,000 email-related pages. In support, FJW on behalf of LM states as follows: I. BACKGROUND A. The Pending Summary Judgment and Protective Order Motions As this Court is well aware, Jeffrey Epstein (a convicted sex offender) has sued one of his alleged victims, ■ as well as attorney, Bradley J. Edwards, Esq.', in Florida state court for conduct that allegedly occurred in the course of Edwards' representation of multiple young female victims of Epstein's sexual abuse. While an employee of the now defunct Rothstein, Rosenfeldt, Adler firm and with his current firm, Edwards filed and pursued civil lawsuits Mr. Edwards, an attorney with the FJW firm, is represented by Jack Scarola of the firm Searcy, Denny, Scarola, Barnhart, and Shipley.. EFTA00595514