UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA Fort Lauderdale Division In re: ROTHSTEIN ROSENFELDT Case No.: 09-34791-RBR ADLER, P.A., Chapter 11 Case Debtor. Fowler White Burnett, P.A.'s Opening Statement This proceeding stems from an Agreed Order [D.E. 1194] that cancelled a hearing on a discovery issue in this bankruptcy action. The issue before the Court in 2010 was a state court subpoena issued to the Rothstein bankruptcy Trustee for the production of documents to Jeffrey Epstein. Bradley Edwards and L.M. claimed the documents were protected by the Attorney-Client Privilege among other potential privileges. As a result of these privilege claims and Edwards' complaints concerning the cost of printing the documents produced by the Trustee, a procedure was set forth in the Agreed Order that dealt with the production of these documents consisting of emails on the Rothstein firm's server sent while Bradley Edwards was employed as an attorney at that firm. Nearly eight years has elapsed from the date the Agreed Order was entered and now before the Court is an Order to Show Cause why Fowler White should not be held in contempt for violation of the November 30, 2010 Agreed Order. As will be more fully developed, Fowler White should not be held in contempt because EFTA00802384