UNITED STATES BANKRUPTCY COURT SOUTHERN DISTRICT OF FLORIDA FORT LAUDERDALE DIVISION www.flsb.uscourts.gov IN RE: ROTHSTEIN ROSENFELDT ADLER, P.A., Debtor. CASE NO. 09-34791-RBR CHAPTER II JEFFREY EPSTEIN'S WRITTEN OPENING STATEMENT Jeffrey Epstein ("Epstein"), pursuant to the Court's Order to Show Cause Why Fowler White and Jeffrey Epstein Should Not Be Held in Contempt and Scheduling Evidentiary Show Cause Hearing [D.E. 6366], submits this Written Opening Statement, and states: INTRODUCTION A. Background: Link & Rockenbach's Appearance in the State Court Proceeding, and the Circumstances of the CD's Discovery. On November 1, 2017, Epstein's counsel, Link & Rockenbach, PA, made its first appearance in Epstein v. Rothstein, Edwards, and L.M., No. 50-2009CA040800XXXXMBAG (Fla. 15th Cir. Ct.), pending in state court in Palm Beach County, Florida (the "state court proceeding"). At that time, Link & Rockenbach had not yet received Epstein's files possessed by one of his former counsel—Fowler White Burnett, P.A. ("Fowler White"), whose representation of Epstein terminated over six years ago in May 2012.1 Epstein, as is his right, requested Fowler White to turn over his files to Link & Rockenbach. 1 From the production it had received by that time, Link & Rockenbach did know that there had been a subset of documents produced in the litigation on May 7, 2012, which contained eighty- four documents that had been listed on Farmer, Jaffe, Weissing, Edwards Fistos & Lehrman, P.L.'s privilege log, that had nonetheless been filed with the state court, including as summary judgment evidence. Further, Link & Rockenbach knew that Edwards had testified to having reviewed 26,000 pages of e-mails and producing them to Epstein. EFTA00806956