Qtask, Inc.

What it was, in the words of a lawyer who used it	”Qtask is a project centric web-based program. So projects could be created. The project would normally be a case …”1
How Rothstein named its founders	”the two main partners there, Mr. — what’s his name Wolfgang, Von Wolfgang, Von Wolfsheild”, and “Russell Mix”2
The officer the trustee pursued	”Baron RK Von Wolfsheild (“Wolfsheild”), Qtask’s Chief Information Technology Officer”, as a trustee’s motion of 22 March 2011 describes him3
Rothstein’s stake, as the criminal information schedules it	”(BI2) Scott W. Rothstein’s equity interest in QTask”, item BI2 under the heading “Business Interests (“BI”)“4
The subpoena	”a Rule 2004 subpoena issued by the Trustee on December 8, 2009 (D.E. 95)“5
The contempt sanction	”a $5000 per day sanction to the Trustee for continued non-compliance, effective as of July 9, 2010”5
What the trustee asked for in December 2010	$25,000 a day, “the immediate incarceration of any Qtask officer who directed the contempt of court”, and the court’s own expert as its monitor6
Epstein’s route to the same data	A Special Master appointed on 13 August 2010 to review “all electronically stored information (“ESI”) and other documents in the Trustee’s possession, including Qtask data”, on a subpoena Epstein served on the trustee and at Epstein’s expense7
Reach in the released files	217 sheets across 114 documents carry the word, measured 24 October 20268

Qtask, Inc. sold a web-based workspace in which a law firm’s lawyers could gather around a case by invitation. Scott Rothstein bought into it, and told a bankruptcy examination in 2012 why: “I hoped that down the road we would be able to sell it and cash out all the Ponzi investors.”² His firm’s lawyers put their cases into it, including the lawyer acting for Jeffrey Epstein’s accusers, and when the firm collapsed the bankruptcy trustee subpoenaed what was inside. Its first productions the court’s own expert called useless. The company was held in contempt, fined $5,000 a day from July 2010, and by the end of that year the trustee was asking the court to raise the fine fivefold and to jail whichever of its officers had directed the contempt.⁵⁶ Epstein, meanwhile, was going after the same data from two directions at once: through a Special Master appointed on his own subpoena to the trustee, and privately, by e-mail, with the company’s own officer.⁷⁹¹⁰

This page is about the company, the stake in it, the instrument the firm’s cases were turned into, and the fight over what it held, which the documents read here carry from December 2009 to July 2011.

What this page covers, and what it does not

This page makes no allegation and records none. It does not name, describe or count any complainant or any survivor. The plaintiffs in the civil actions against Epstein sued under pseudonyms or initials, and neither their designations nor their case numbers are printed here, whatever any individual sheet may carry. Two of the three designations used in the deposition quoted below are covered by the producing party on the sheet cited; none of the three is reproduced.¹¹

Where the producing party has covered a name or a value on a sheet cited here, this page writes around it. It supplies nothing into a covered span, draws no inference about whom a covered span belongs to, and reproduces no telephone number, fax number, e-mail address, account number, identity number or date of birth from any document cited here. One sheet cited for a single sentence carries covered names elsewhere on it, and the rest of that message is neither quoted nor characterised.¹²

The word “victims” is used in more than one sense on the sheets cited here, and no quotation on this page contains it. Where the lawyer quoted below uses it, he is speaking of his own clients, the investors who lost money in the scheme, and this page calls them investors throughout to avoid any doubt.

Scott Rothstein has his own page, which carries his conviction and the use Epstein later made of his name; Brad Edwards has one; and the suit Epstein brought against both men has one. This page does not repeat them.

What Qtask was

The clearest description of the product in the released files is the one Bradley J. Edwards gave on oath in March 2010, in the deposition Epstein’s counsel took of him in the Palm Beach suit. Asked in what fashion he had used it at Rothstein Rosenfeldt Adler, he answered:

Qtask is a project centric web-based program. So projects could be created. The project would normally be a case, and that case discussed with lawyers the way that you may gather around a table and discuss it. And at times I was invited to projects on various cases and utilized that system.¹

The mechanism of access, as he described it later in the same deposition, was invitation. The person who started a project was its lead and could invite other lawyers to it; another lead could invite somebody else; opening the interface showed the photographs of the people invited to that project; an invitee could add material; and a person who had not been invited could not get in at all.¹³¹⁴¹⁵ Asked whether Rothstein, as the head of the firm, could have reached the system without an invitation, he answered no.¹⁵

Alongside Qtask the firm ran a document-imaging system Edwards named as Fortis, which he had not used before joining the firm.¹⁶

The stake, and what Rothstein said he bought it for

Rothstein’s interest in the company is scheduled in the federal criminal information filed against him. Under the heading “Business Interests (“BI”)”, the second item of the schedule reads “(BI2) Scott W. Rothstein’s equity interest in QTask;”, between a block of Gibraltar Private Bank & Trust stock and an interest in Broward Bank of Commerce.⁴

In a Rule 2004 examination on 4 June 2012, Rothstein was asked to be specific about Qtask and answered:

Sure. The way I was sold Qtask by the two main partners there, Mr. — what’s his name Wolfgang, Von Wolfgang, Von Wolfsheild.

Q. Reichart Von Wolfsheild?

A. I was pretty close. And Russell Mix. And then the way I was sold it by two people from my firm, Russell Adler and Rob Buschel, was that this was groundbreaking technology, that it would eventually be worth a fortune, and hence my decision to invest in it. I hoped that down the road we would be able to sell it and cash out all the Ponzi investors.²

The two questions that follow put the point directly, and he agreed with both: that he had wanted to buy side businesses such as Qtask “because the Ponzi had created a lot of debt” and hoped they “would help you buy your way out of the Ponzi”, and that the businesses he bought “were not for RRA’s benefit but for your benefit in terms of trying to close down, shut down the Ponzi”. To the second he answered: “That’s correct, that was their main purpose.”²

No document read for this page states what Rothstein paid for his interest. The only figure in the released files read here that attaches a sum to Qtask is one Von Wolfsheild wrote to Epstein in April 2011, listing the five proceedings he was then facing: “The adversary case - where they want to get all of Rothstein’s money back ($7.5 million)”. That is a party’s description of what the trustee was seeking to recover, not a price.¹⁷

Why the firm’s work went into it

The trustee’s own account of why Rothstein wanted the firm’s sensitive traffic on Qtask rather than on the firm’s own servers is in a motion of December 2010, which says the trustee had already put the e-mail in evidence:

The Trustee has already submitted to the Court the Scott Rothstein internal e-mail where he directed his partners to use Qtask because the RRA servers were less than secure.¹⁸

The same passage says that “In deposition, Adler makes no secret, in fact brags about being the RRA architect who brought Qtask in house to RRA”, and describes Robert Buschel as “a former RRA partner, Qtask shareholder and present Qtask lawyer” who “has been the front man in keeping the Trustee away from Qtask’s data during the last year”.¹⁸ These are an adverse party’s characterisations in a motion, not findings of the court, and this page does not treat them as more than that. The internal e-mail itself is not among the documents read for this page, and no sheet cited here quotes it.

The settlement interests sold to investors

The firm’s civil litigation against Epstein was also the raw material of a financial product. At a hearing in the bankruptcy on 4 August 2010, William R. Scherer, acting for investors who had bought into purported settlements and who sat on the creditors’ committee, described the mechanism to the court. His clients and a lawyer they had brought from a national firm went into the Rothstein conference room, investigators were summoned to bring down the Epstein file, and that lawyer went through ten boxes of it and “concluded that the Epstein case was a real case”. Rothstein then sold interests in settlements that did not exist:

So he used the real case in order to defraud my clients into investing into these phoney settlements and paid 13 and a half million dollars.¹⁹

What was sold, on that account, was an investment in settlements that did not exist, and the ten boxes of a real case were what the investors’ own lawyer was given to examine. The court asked where those boxes were. Scherer answered: “The trustee does not have the ten boxes. I presume the ten boxes are residing with the lawyers who took the case, Mr. Edwards and the successor law firm.”¹⁹

Whose claims were in the boxes is not this page’s subject and is not reproduced here. What matters to the company is what Scherer said next about where the surviving record of the arrangement would be found: “And then in addition, there’s about 6,000 e-mails that the trustee has, and I bet you when we look at Qtask, there’s going to be a boatload more.”¹⁹ The subpoena to the company was by then nearly eight months old.⁵

The Epstein files inside Qtask

Edwards joined Rothstein Rosenfeldt Adler at about the beginning of April 2009.²⁰ On oath he confirmed that he had personally put information into Qtask for a project on his cases.²¹ He said he was aware of one project in the system relating to the claims against Epstein, that he had participated in it, and that he did not remember what it was called, when it was created, or whether he created it at all. Examining counsel then proposed calling it “the Epstein project” for the rest of the questioning, and he accepted that designation; the phrase is counsel’s, not his.²⁰²²

He also testified that no project in the system had been entitled, to his recollection, by the name of any of the three Epstein cases he was asked about, and finished the answer: “And my answer is no, those titles are not, I don’t believe were ever on Qtask.”¹¹

On whether the head of the firm was in the Epstein material, his answer was short:

Q. Couple, few more questions in Qtask. Did you ever allow Mr. Rothstein, was he an invitee on the Epstein-related projects?

A. I don’t believe so.²³

He gave the same answer about Ken Jenne, whom he said he had not known and who he said had approached him about the Epstein cases on more than five and possibly more than ten occasions: asked whether Jenne had ever been “an invite person on your Qtask”, he answered “I do not believe so.”²⁴

Epstein did not accept the answer about Rothstein. In a message to his own lawyer on 8 July 2011 he wrote: “Scott was invited in by edwards on Qtask on the epstein cases. The only case scott asked to be included on.”¹² In a further message to the same lawyer on 10 December 2011 he attributed that to Edwards’s assistant: “beth williamson, brads asst said that the only case rothstein followed on Qtask ws the epstein cases..”²⁵ Both are Epstein’s own assertions in private correspondence with his attorney, the second of them his account of what he says somebody else told him. No document read for this page records any statement by Beth Williamson herself, and nothing here is a finding about her. Epstein’s messages also propose investigative steps concerning her and others; those are his proposals, they are not reproduced here, and the record read for this page contains no response to them from anybody they name.

The subpoena and the contempt

The trustee, Herbert Stettin, issued a Rule 2004 subpoena to Qtask on 8 December 2009. The company did not comply with it, nor with an order to compel of 8 March 2010. By the time of the motion that sets out this history, Qtask had been held in contempt, and the court had ordered it to pay the trustee’s fees and costs and “a $5000 per day sanction to the Trustee for continued non-compliance, effective as of July 9, 2010”. To measure how far the company was out of compliance, the court appointed Robert Moody as its own expert.⁵

Moody submitted his report on 13 December 2010, and it was docketed on 17 December.²⁶ The trustee’s motion of 29 December 2010 then reproduces what it calls “Verbatim highlights” of the report under its own headings. On the productions:

“Initial productions were useless.

The initial productions by Qtask were CD/DVDs containing what essentially exists as the computer data version of a run on sentence. The initial production consisted of a lot of computer code and data but no format or structure for the Trustee to use.

The second production, as reported by Qtask, did provide structure through specialized programming but, as reported by the Trustee, did not have the functionality or ease of use that the Trustee needed to work with the data set.”²⁶

On access: “Access to the “shadowbox” has been blocked. The Trustee still does not have the passwords associated with the individual user accounts.”²⁶ The report and the motion use the word “shadowbox” without defining it, and this page does not supply a definition for it.

On what the company could see of the trustee’s work, the report states a finding and then immediately qualifies it, and the qualification belongs with it:

“Qtask is monitoring the Trustee’s investigation.

Through interviews, Qtask has acknowledged that it knows what and when the Trustee has accessed on Qtask because they are part of the same projects as the Trustee and they maintain administrative and technical control over the workspace the Trustee is conducting its investigation in.

A review of the Qtask environment shows that this is an inherent feature of Qtask and not something that was created to monitor the Trustee. Regardless of how it came into existence, the fact is this feature does exist. Furthermore, the “shadow box” being hosted on the Qtask network does offers a significant security risk to the Trustee’s investigation.”²⁷

The company’s stated reason for not producing was that the material was not its own:

“Qtask has repeatedly claimed that the information contained within their system does not belong to them, it belongs to their client. They have stated that they are the gatekeepers and that they are not able to provide access because they do not own the information. …”²⁸

The report answers that the classification is right and the role is wrong, comparing the company to other service bureaus which have procedures for producing information when properly asked, and saying it “should not be taking the position of questioning the Trustee as to why the information is needed”.²⁸ The report also records that the company had stopped trying: the trustee and Qtask “have both acknowledged that Qtask has stopped complying with these subsequent requests because Qtask feels that they are too burdensome and it should not be made to “run back to the warehouse numerous times” to meet the Trustee’s demands.”²⁹

The motion then asks the court to expedite seven heads of relief. They include liquidating the accrued fees and the daily fine to a final judgment; “Increasing the $5000 per day fine to $25,000 per day for continued non-compliance”; “Ordering the immediate incarceration of any Qtask officer who directed the contempt of court until full compliance by Qtask occurs”; “appointing Moody as this Court’s monitor with obligations to regularly report back to the Court on an extremely expedited basis”; and leave to bring a further motion “to determine the culpability of Buschel in these proceedings, so as to potentially assess on a joint and several basis the total attorneys fee award and fine against Buschel and Qtask”.⁶ An earlier sheet of the same motion puts the estate’s spend at “over $100,000 in attorneys fees for rehashing and revisiting the same meritless arguments with Qtask for a one year period”.³⁰ Nothing read for this page records what the court did with any of the seven.

The officer who accepted responsibility

On 7 March 2011 the court entered a final judgment for sanctions against the company. Fifteen days later the trustee moved to put those sanctions on an individual as well. The motion’s whole argument is one sentence of an affidavit the officer had filed on 7 June 2010, which it quotes:

I accept full and all responsibility for the decisions made on behalf of Qtask, Inc., regarding the disclosure of data stored on the Qtask service in response to the subpoena by the Trustee and litigation of the above entitled matter as it pertains to Qtask, Inc.³

From that the trustee argued that “Wolfsheild has individually claimed responsibility for the actions of Qtask” that led to the order to compel and the order of contempt, and that “the Court should recognize his admission, for what it is, on its face”.³ The motion adds that his assumption of liability “has nothing to do with the independent potential liability of Qtask’s lawyer, Robert Buschel”.³ The affidavit itself is not among the documents read for this page; the words above are the motion’s quotation of it.

Five weeks later he described the position to Epstein himself in plainer terms, counting five proceedings including “The “final judgement amendment #2 - where they want me personally to pay all the fees …”.¹⁷

Epstein’s pursuit of the Qtask data

Epstein approached the same body of data twice over, in public through the court and in private by e-mail, and the two tracks ran at the same time.

Through the court. Epstein served a subpoena on the trustee, and after a hearing on 4 August 2010 the bankruptcy court appointed a Special Master over the material. The order, filed on 13 August 2010, names Qtask expressly:

The Court appoints former Broward County Circuit Judge Robert Carney as Special Master who shall work with counsel for the Trustee to obtain documents responsive to the subpoena served upon the Trustee by Jeffrey Epstein to: (i) review all electronically stored information (“ESI”) and other documents in the Trustee’s possession, including Qtask data for purposes of determining the applicability of the attorney/client and work product privileges …⁷

Nothing was to be released to anyone until the Special Master had reported, and the order closes: “All legal fees and costs incurred by the Special Master shall be paid by Epstein, who has agreed to pay directly all such fees and costs.”⁷ No document read for this page records what the privilege log contained, or whether anything was produced to Epstein under this order.

By e-mail. On 15 January 2011, by the thread’s own quoted header, under a subject line reading “Re: when are you free to speak”, Epstein wrote to a correspondent the sheet identifies only as Reichart: “how do i try qtask , is there a tutorial?”⁹ Two days later the correspondent answered that trying it alone was no use and that it would be better to invite a couple of people, suggesting someone whose name the producing party covers on that sheet and which is not supplied here, and offering a screen-shared tour.³¹

Four months later the same correspondent reported that the trustee’s lawyers had come looking for Epstein’s own material. On 18 May 2011, after describing an attempt to fine him personally, he wrote:

It is interesting, your name finally came up. Berger Singerman want the projects in Qtask regarding YOU.¹⁰

Epstein answered the same day, in a single line: “I have guest apts in new york that you are welcome to use”.³² The documents establish only the sequence and the date. Neither message gives a reason for the offer, and this page draws no connection between them. The two messages carry clock stamps which this page does not convert or difference: see the note on the clocks below.³³

On 6 July 2011 Epstein asked for the material directly: “i need my q task stuff from rothsteinn, profile,, beth williamson.”³⁴ The reply, a week later, was that there was nothing to get:

I can tell you now that there is nothing I have access to of Beth’s. And Scott barely used Qtask in the first place (he knew it tracked everything) If I were to assume, Beth would not have stored anything back then in Qtask because it was something new to them back then.³⁴

In the same thread Epstein pressed: “i know that scott was invited into all my cases . and he asked that he be kept up on them,, what can i do to get hold of the info”. The answer, on 13 July 2011 by the sheet’s own header, sent him back to the trustee’s lawyers: “That is possible. I don’t see those. I was under the impression that BS now has this info though. Please, ATTACK THEM. They are a-holes.”³⁵

The man writing these messages is given on the sheets only as Reichart, with no surname in any sender field. This page takes him to be Reichart Von Wolfsheild, the Qtask co-founder Rothstein named in his examination and the officer the trustee moved against, on four bases from the face of the documents. A Google+ notification sent to Epstein’s own address on 20 October 2011 is headed “Reichart Von Wolfsheild added you on Google+”.³⁶ The April 2011 message lists exactly the five proceedings the trustee’s filings show running against the company, its lawyer and its officer, and says the writer is about to co-host a series for the History Channel.¹⁷ The May 2011 message names the trustee’s law firm, reports a demand for Epstein’s Qtask projects, and says the same thing about the series.¹⁰ And Rothstein’s examination names Reichart Von Wolfsheild and Russell Mix as the company’s two main partners.² No sheet cited here gives the surname in the sender field of any of these messages, and nothing is recovered from any other copy.

What the released files do not settle

This page does not say what the trustee finally received. No document read for it records the outcome of the contempt proceedings, whether the daily fine was ever raised, whether any officer was jailed, what the Special Master’s privilege log contained, or what was in the Epstein project. The latest statement read here about where the material had got to is the officer’s own guess of 13 July 2011 that the trustee’s lawyers already had it, which he gives as an impression and not as knowledge.³⁵

A search of the released files for the single word returns 217 sheets across 114 documents. That is a small number in this release, where the single word “Epstein” reaches 578,565 documents, and a count of sheets is not a count of events: a document copied many times in a production is counted once per copy, and several of the 114 are copies of one another.⁸ No figure in this paragraph is a finding.

How the documents on this page were read

Twenty-four sheets were read at the page image. Eight of them, in the Rothstein forfeiture schedule and the trustee’s motion, were rendered from this project’s local copy of the served file; the other sixteen were fetched from this project’s own per-document path, read-only, with a negative control on an identifier that exists nowhere, which failed as it must. Page counts were reconciled against the released text for both local files, at 17 sheets and 755 sheets. The native resolution of the local scans is 96 pixels per inch, measured on the sheets themselves, so no higher figure is claimed for any reading here.

Every quotation on this page is from a sheet read at the image, with two exceptions, each marked in its footnote: the three words counsel proposed as a name for the project, and the two short fragments of the answer about Ken Jenne, both in the Edwards deposition, which were read in the released text. The deposition sheets that are described rather than quoted, on the invitation mechanism, the Fortis answer and the witness’s account of the project, were also read in the released text, and their footnotes say so.

The released text was wrong on this page’s own material in several places the images corrected. It gave the trustee’s expert as reporting that initial productions were “uselesa” and the sentence about structure as “no format o tructLre”; it rendered “claimed that the” as “claim that-the”; it printed the speaker of one quoted passage as “MR. SOBERER” where the sheet reads “MR. SCHERER”; and it shows no trace at all of the words “NOT A CERTIFIED COPY”, which are set diagonally across every sheet of the trustee’s motion as this release serves it. An extraction that improves a document is as dangerous as one that damages it, and the quotations here follow the sheets, including their own spellings, their doubled commas and their missing full stops.

Several of these sheets set two spaces after a full stop, and some of the e-mails carry doubled spaces inside a sentence; the quotations here keep the doubled spaces inside a sentence, render a doubled space after a full stop as one, and change nothing else. Where a quotation crosses a line break in the source it is rendered as a single space. Where a quotation is cut, the cut is marked. A span the producing party has covered is marked ▮ and nothing is written into it.

Limits of this page

It does not say who built the software, when the company was incorporated, where it was based, how many customers it had, or what became of it, because no document read for this page states any of those things. It gives no founding date and no headquarters. It does not say what Rothstein paid. It does not say what was in any project, and it says nothing about the contents of the Epstein project beyond the witness’s own answers about its name and his participation. It does not resolve whether Rothstein was invited into that project: it reports a sworn “I don’t believe so” and an adverse party’s private assertion to the contrary, and leaves them side by side.

It takes no position on whether the company’s conduct in the discovery was obstruction. It reports a contempt order, a sanction, an expert’s findings as a motion quotes them, and the company’s own stated reason for withholding, and it notes that the expert said in terms that the monitoring capability was an inherent feature of the product and not built to watch the trustee.

It names no complainant, describes none, and takes nothing from any document for anything that document records about one.

Documents cited

identifier	what it is
EFTA00193199	A 755-sheet mixed production whose first sheet is a 2008 e-mail between prosecutors. Only served p. 679 is used here, which is page 27 of 36 of Document 1 in Case 0:09-cr-60331-JIC, the federal criminal information against Rothstein entered on the docket on 1 December 2009
EFTA02769191	17 sheets. Served pp. 1 and 2 are Epstein’s notice, filed in the Palm Beach circuit court in December 2010, of his intention to rely on an attached exhibit. Served pp. 3 to 17 are that exhibit: bankruptcy Doc 1270, the trustee’s motion to fix and compel payment by Qtask, filed 29 December 2010, 15 pages, of which pp. 8 to 15 are the certificate of service and the service list
EFTA00621390	Bankruptcy Doc 1558, the trustee’s motion to hold Von Wolfsheild jointly and severally liable, filed 22 March 2011, 9 sheets, of which pp. 3 to 9 are the master service list
EFTA01082728	Transcript of the Rule 2004 examination of Scott Rothstein, 4 June 2012, 133 sheets. Only served p. 29 is used here
EFTA00599662	Videotaped deposition of Bradley J. Edwards, Volume I of II, 23 March 2010, in Epstein’s Palm Beach suit, 147 sheets. Only the sheets named in the footnotes are used here
EFTA00213917	A 10-sheet condensed transcript, four transcript pages to the sheet, filed as Document 214-3 in Case 9:08-cv-80893-KAM and entered on that docket on 2 September 2010. The transcript itself is of a bankruptcy hearing of 4 August 2010. Only served p. 5 is used here
EFTA00206606	Bankruptcy Doc 888, the order appointing a Special Master, filed 13 August 2010, reproduced as Document 214-4 in the same civil case and entered on that docket on 2 September 2010, 3 sheets
EFTA01835022	E-mail of January 2011 under the subject “Re: when are you free to speak”, one sheet
EFTA01793279	E-mail thread of 17 January 2011 in the same subject, two sheets
EFTA00707937	E-mail of 28 April 2011 listing five proceedings, two sheets
EFTA01863165	E-mail of 18 May 2011, one sheet
EFTA01863573	Epstein’s reply of 18 May 2011, carrying the earlier message, one sheet
EFTA01776463	E-mail of 13 July 2011 carrying Epstein’s message of 6 July, two sheets, the second a property list rather than text
EFTA01862117	E-mail of 13 July 2011 carrying Epstein’s message of 12 July and the thread beneath it, two sheets
EFTA01858073	Epstein to his attorney, 8 July 2011, one sheet
EFTA00925741	Epstein to his attorney, 10 December 2011, one sheet
EFTA00687427	Google+ notification to Epstein’s address, 20 October 2011, one sheet, born digital

Footnotes

Footnotes

1. Videotaped deposition of Bradley J. Edwards, Esquire, Volume I of II, Tuesday 23 March 2010, 10:00 to 5:07 p.m., in Jeffrey Epstein v. Scott Rothstein, individually, Bradley J. Edwards, individually, Case No. 50 2009CA040800XXXXMB AG, Fifteenth Judicial Circuit in and for Palm Beach County, reported by Cynthia Hopkins, RPR, FPR, for Prose Court Reporting Agency. Examining counsel is Mr. Critton; Mr. Scarola appears for the witness. Served p. 36 carries the transcript’s own page 36, and the two numberings agree throughout this production. Read at the page image; the sheet carries the printed stamp EFTA00599697. The reporting agency’s footer carries covered values on either side of its name. https://epstein-data.com/EFTA00599662 p.36. ↩ ↩²

2. Rule 2004 examination of Scott Rothstein, Fort Lauderdale, Monday 4 June 2012, 9:07 a.m. to 12:37 p.m., in Case No. 09-34791-RBR, taken before Pearlyck Martin, FPR, for Friedman, Lombardi & Olson. Read at the page image; the sheet carries the printed stamp EFTA01082756 and the transcript’s own “Page 29”. The examiner is not named on this sheet and is not identified here. The transcript sets two spaces after a full stop and the quotations render them as one. The reporter’s footer carries a covered value beneath the firm name. https://epstein-data.com/EFTA01082728 p.29. ↩ ↩² ↩³ ↩⁴ ↩⁵

3. Trustee’s motion to hold Baron RK Von Wolfsheild jointly and severally liable for sanctions against Qtask, Inc., same court and case, Doc 1558, filed 03/22/11, page 1 of 9. Read at the page image; the sheet carries the printed stamp EFTA00621390. The affidavit is identified on the sheet as filed on 7 June 2010 at docket entry 741 and the quoted sentence is set in italics as a block quotation in the motion; the abbreviation before each docket number, and two letters after the debtor’s name, are covered by bars on this sheet and nothing is written into them. The sheet reads “to Qtask, Inc.” with a comma where the released text gives none. The motion is signed for Berger Singerman and dated 22 March 2011. Served pp. 3 to 9 are the master service list and nothing from them is used here. https://epstein-data.com/EFTA00621390 pp.1-2. ↩ ↩² ↩³ ↩⁴

4. Federal criminal information, United States v. Scott W. Rothstein, Case 0:09-cr-60331-JIC, Document 1, entered on the docket of the Southern District of Florida on 1 December 2009, 36 pages. The sheet is the information’s own page 27, which prints “27” at its foot. Read at the page image; the served sheet carries the printed stamp EFTA00193877. The schedule’s item labels stand in a separate column from their text at the left of the sheet, so the pairing of “(BI2)” with the QTask line was read at the image and not inferred from the released text, in which the labels extract as one vertical run. The surrounding items are other business interests and nothing is inferred from their adjacency. This identifier holds a 755-sheet mixed production, so it is cited by page and never bare. https://epstein-data.com/EFTA00193199 p.679. ↩ ↩²

5. Trustee’s motion to fix and compel payment by Qtask of attorneys fees and sanctions for its contempt of court, United States Bankruptcy Court for the Southern District of Florida, In re Rothstein Rosenfeldt Adler, P.A., Case No. 09-34791-RBR, Doc 1270, filed 12/29/10, page 1 of 15. Read at the page image; the served sheet carries the printed stamp EFTA02769193. The words “NOT A CERTIFIED COPY” are set diagonally across the sheet and the released text shows no sign of them. The sheet reads “the Trustee’s attorneys fees and costs calculated from February 9, 2009 and continuing thereafter”; that is the motion’s own text and this page neither corrects nor explains it. The run is mixed and is cited by page: served pp. 1 and 2 are a state-court notice of filing, and the motion is the exhibit behind it. https://epstein-data.com/EFTA02769191 p.3. ↩ ↩² ↩³ ↩⁴ ↩⁵

6. Same motion, Doc 1270 page 7 of 15, the numbered relief and the signature block. Read at the page image; the served sheet carries the printed stamp EFTA02769199. The sheet is dated 29 December 2010 and signed “/s/ Charles H. Lichtman” for Berger Singerman, P.A., attorneys for the Chapter 11 trustee; it bears a conformed electronic signature and no ink. The released text drops “this” from “appointing Moody as this Court’s monitor” and drops “potentially” and “Buschel and” from the seventh head of relief; the readings above are the image’s. Counsel’s telephone, facsimile and e-mail lines are not reproduced here. https://epstein-data.com/EFTA02769191 p.9. ↩ ↩² ↩³

7. Order respecting production of documents, same bankruptcy court and case, Doc 888, filed 08/13/10, page 2 of 3, ordered by Judge Raymond B. Ray. The copy in the release is Document 214-4 in Case 9:08-cv-80893-KAM, entered on that docket on 2 September 2010, and the wrapper is the civil filing, not the order. Read at the page image; the sheet carries the printed stamp EFTA00206607. The quotation is cut after “privileges” and the cut is marked; what follows names clients of a law firm, including one identified by initials, and is not reproduced here. The order’s first sheet recites the motions it disposes of and the hearing of 4 August 2010. https://epstein-data.com/EFTA00206606 p.2. ↩ ↩² ↩³ ↩⁴

8. Counts taken from the released files on 24 October 2026 by exact-token search, column-scoped. The single token reaches 217 sheets across 114 documents; the search treats upper and lower case alike, so “Qtask” and “QTask” are one query and not two corroborating forms. The denominators, 1,425,556 documents and 2,925,025 sheets, and the comparison figure of 578,565 documents for the single word “Epstein”, were measured over this project’s whole store. An invented phrase run in the same session returned 0 sheets and 0 documents, so a zero from this instrument would have been a real zero. These are counts of sheets on which a token is printed, not counts of events, and the 114 include copies of one another, because several of the filings quoted here recur across productions. ↩ ↩²

9. E-mail from Jeffrey Epstein to a correspondent the sheet names only as Reichart, under the subject “Re: when are you free to speak”. Read at the page image; the sheet carries the printed stamps EFTA_R1_00214447 and EFTA01835022. The sheet gives two clock stamps for the correspondent’s earlier message and neither carries a time zone: the export header above reads “Sun 1/16/2011 1:29:26 AM” for Epstein’s own message, and the quoted inline header reads “On Sat, Jan 15, 2011 at 2:32 PM”. This page converts neither and asserts no interval between them, and dates Epstein’s question to 15 January 2011 on the thread’s own quoted header, which is the date the next sheet in the thread also gives. The addressee’s e-mail address is covered by the producing party on this sheet and is not supplied here. https://epstein-data.com/EFTA01835022 p.1. ↩ ↩²

10. E-mail to Jeffrey Epstein, export header “Sent: Wed 5/18/2011 6:12:41 AM”, no time zone stated. Read at the page image; the sheet carries the printed stamps EFTA_R1_00264734 and EFTA01863165. The From field reads “Reichart” with no surname and no bar. The quoted sentence crosses a line break after “projects”, rendered here as a single space. The writer also reports flying back from Maui and starting to shoot a History Channel series. https://epstein-data.com/EFTA01863165 p.1. ↩ ↩² ↩³

11. Same deposition, served p. 52, transcript page 52. Read at the page image; the sheet carries the printed stamp EFTA00599713. The witness’s answer names three cases; two of the three designations are covered by solid bars applied by the producing party and the third is a pseudonym, and none of the three is reproduced here. The fragment quoted in the body is the whole of the witness’s second answer on that sheet. https://epstein-data.com/EFTA00599662 p.52. ↩ ↩²

12. E-mail from Jeffrey Epstein to “William R. Scherer”, export header “Sent Fri 7/8/2011 3:40:47 AM”, no time zone stated, one sheet. Read at the page image; the sheet carries the printed stamps EFTA_R1_00256385 and EFTA01858073. The two sentences quoted in the body are consecutive on the sheet. The rest of the message is Epstein’s own account of other events and his proposals for an investigation, it carries four spans covered by the producing party, and it is neither quoted nor characterised here; one case designation printed on it is not reproduced. The addressee’s e-mail address is covered on this sheet. https://epstein-data.com/EFTA01858073 p.1. ↩ ↩²

13. Same deposition, served p. 42, transcript page 42. Read in the released text; this page holds no image reading of this sheet. The lead of a project could invite other attorneys; another lead could invite somebody else; the interface shows photographs of those invited. https://epstein-data.com/EFTA00599662 p.42. ↩

14. Same deposition, served p. 43, transcript page 43. Read in the released text; this page holds no image reading of this sheet. Asked whether an invitee was allowed to add to Qtask, the witness answers “Correct”; asked whether an invitee could also delete, he answers “I don’t know that.” https://epstein-data.com/EFTA00599662 p.43. ↩

15. Same deposition, served p. 46, transcript page 46. Read in the released text; this page holds no image reading of this sheet. Invitees receive a notification so that they can accept; a person not invited cannot access the system, “That’s just not how the system works”; and asked whether Rothstein could have accessed it as head of the firm whether invited or not, the witness answers “No”. https://epstein-data.com/EFTA00599662 p.46. ↩ ↩²

16. Same deposition, served p. 38, transcript page 38. Read in the released text; this page holds no image reading of this sheet. Edwards names the firm’s electronic case management software as “Fortis” and says he had not used it before joining the firm. https://epstein-data.com/EFTA00599662 p.38. ↩

17. E-mail to Jeffrey Epstein, “Date: Thu, 28 Apr 2011 09:32:07 +0000”, which is the only stamp on the sheet and carries a zone. Read at the page image; the sheet carries the printed stamp EFTA00707937. The From field reads “Reichart” above an address covered by the producing party, which is not supplied here. The five items are quoted from the list as printed, including its own spelling “judgement”. https://epstein-data.com/EFTA00707937 p.1. ↩ ↩² ↩³

18. Same motion, Doc 1270 pages 5 and 6 of 15. Both served sheets read at the page image; they carry the printed stamps EFTA02769197 and EFTA02769198. The sentence about the internal e-mail begins at the foot of the first and ends at the head of the second, and is quoted whole across the break. The passages about Adler and Buschel stand on the second of the two sheets. A word is covered by a bar in the firm name “Berger ▮man” in the Buschel passage and nothing is written into it; the quotations given here do not cross that span. https://epstein-data.com/EFTA02769191 pp.7-8. ↩ ↩²

19. Excerpt of proceedings before the United States Bankruptcy Court for the Southern District of Florida, In re Rothstein Rosenfeldt Adler, P.A., Case No. 09-34791-BKC-RBR, 4 August 2010, on a motion to compel production of documents from the trustee and a motion for a protective order, reported by Ouellette & Mauldin Court Reporters, Inc. The copy in the release is Document 214-3 in Case 9:08-cv-80893-KAM, entered on that docket on 2 September 2010. Read at the page image; the sheet carries the printed stamp EFTA00213921. The sheet is a condensed transcript carrying four transcript pages in a two-by-two block, and the released text returns them out of order, so every quotation here was read at the image and no two columns are joined. The three quotations are from transcript page 18 lines 17 to 20, transcript page 20 lines 17 to 20, and transcript page 20 lines 21 to 24. The released text prints the speaker of the last as “MR. SOBERER”; the sheet reads “MR. SCHERER”. The surrounding passages describe the claims of complainants and are neither quoted nor characterised here, and the designation by which one of them is identified on the sheet is not reproduced. The reporter’s telephone line is not reproduced here. https://epstein-data.com/EFTA00213917 p.5. ↩ ↩² ↩³

20. Same deposition, served p. 57, transcript page 57. Read in the released text; this page holds no image reading of this sheet. The witness says he does not know who created the project and is aware only of the project he participated in relating to Mr. Epstein; he does not remember what it was called, when it was created, or whether he created it. The remainder of that answer characterises the conduct alleged against Epstein and is not reproduced here. https://epstein-data.com/EFTA00599662 p.57. ↩ ↩²

21. Same deposition, served p. 39, transcript page 39. Read in the released text; this page holds no image reading of this sheet. Asked whether he had ever personally put any information into the Qtask system for a project on his cases, he answers “Yes” twice, to the question and to its completion. https://epstein-data.com/EFTA00599662 p.39. ↩

22. Same deposition, served p. 58, transcript page 58. Read in the released text; this page holds no image reading of this sheet. Examining counsel asks “let me just call it the Epstein project, are you okay with that designation?” and the witness answers “Yes”. The phrase is counsel’s own, proposed for convenience, and this page does not present it as the project’s name. https://epstein-data.com/EFTA00599662 p.58. ↩

23. Same deposition, served p. 63, transcript page 63. Read at the page image; the sheet carries the printed stamp EFTA00599724. The quoted exchange follows a recess timed on the sheet at 11:21 and 11:28 a.m. https://epstein-data.com/EFTA00599662 p.63. ↩

24. Same deposition, served pp. 130 to 132, transcript pages 130 to 132. Read in the released text; this page holds no image reading of these sheets. Ken Jenne is named in the questions on transcript page 130 and the questioning about him runs on without a further name, so the pronouns on pages 131 and 132 were resolved by reading back to that page and not assumed. The witness answers “He would have approached me. I didn’t know him.”, and says Jenne approached him to talk about the Epstein cases more than once, more than twice, more than five times and possibly more than ten; asked whether Jenne was ever “an invite person on your Qtask” he answers “I do not believe so”; and asked whether he ever asked Jenne why he was interested, “No”. Transcript page 131 carries material about the complainants in those cases and nothing from it is reproduced or characterised here. https://epstein-data.com/EFTA00599662 pp.130-132. ↩

25. E-mail from Jeffrey Epstein to “William R. Scherer”, “Date: Sat, 10 Dec 2011 20:12:34 +0000”, which carries a zone, one sheet. Read at the page image; the sheet carries the printed stamp EFTA00925741. The clause is quoted exactly as the sheet prints it, with two spaces after the first comma, the spelling “ws”, and the two full stops at its end. The remainder of the message is a run of investigative questions about other named people and is not reproduced here. The addressee’s e-mail address is covered on this sheet. https://epstein-data.com/EFTA00925741 p.1. ↩

26. Same motion, Doc 1270 page 2 of 15. Read at the page image; the served sheet carries the printed stamp EFTA02769194. The quoted block is one quotation in the motion: its opening mark stands before “Initial productions were useless.” and its closing mark after “work with the data set.”; its three paragraphs are reproduced here as three. The sheet reads “run on sentence” with no hyphen. The released text of this sheet gives “uselesa”, “ru on seltanCe” and “format o tructLre”; the readings above are the image’s. The shadowbox sentence is the opening of a separate quotation under its own heading, and the sheet sets the word in straight double quotes. https://epstein-data.com/EFTA02769191 p.4. ↩ ↩² ↩³

27. Same motion, Doc 1270 pages 3 and 4 of 15. Both served sheets read at the page image; they carry the printed stamps EFTA02769195 and EFTA02769196. The quotation begins on the first of the two, under the heading “Qtask Can Monitor the Trustee’s Investigation through the Shadowbox:”, and runs across the page break; the words “administrative and technical control” open the second sheet. The sheet reads “does offers” and the quotation follows it. https://epstein-data.com/EFTA02769191 pp.5-6. ↩

28. Same motion, Doc 1270 page 4 of 15. Read at the page image; the served sheet carries the printed stamp EFTA02769196. The released text of this sheet gives “claim that-the”; the sheet reads “claimed that the”. The opening quotation mark is on the sheet and the quotation continues past the extract on the same sheet, which is why no closing mark is given here. The comparison to other service bureaus and the sentence about questioning the trustee stand in the same quotation, lower on the sheet. https://epstein-data.com/EFTA02769191 p.6. ↩ ↩²

29. Same motion, Doc 1270 page 4 of 15, under the heading “Qtask Has Stopped Even Attempting to Comply With the Trustee’s Requests for Information from Qtask:”. Read at the page image; the served sheet carries the printed stamp EFTA02769196. The released text gives “it*ould not be”; the sheet reads “and it should not be made to”. The inner quotation marks round “run back to the warehouse numerous times” are the report’s own. https://epstein-data.com/EFTA02769191 p.6. ↩

30. Same motion, Doc 1270 page 5 of 15. Read at the page image; the served sheet carries the printed stamp EFTA02769197. The sentence quoted runs “In economic terms, the Estate has already spent over $100,000 in attorneys fees for rehashing and revisiting the same meritless arguments with Qtask for a one year period”, and the quotation above begins at “over”. The same sheet says that “The Trustee will shortly provide the Court with an updated attorneys fee and cost affidavit to liquidate these sums”, so the figure is the motion’s own running total and not an award. A word is covered by a bar between “the Qtask” and “Adler” lower on the sheet and nothing is written into it. https://epstein-data.com/EFTA02769191 p.7. ↩

31. E-mail thread of Monday 17 January 2011, 3:43 p.m. by the sheet’s own header, carrying the exchange beneath it. Read in the released text; this page holds no image reading of this sheet. A personal name is covered by the producing party in the sentence suggesting whom to invite, and nothing is supplied into it; the person is not characterised here and no inference is drawn about who they are. The sheet carries quoted-printable damage, printing “s=ell” for “spell” and “wr=te” for “wrote”, and this page quotes nothing from it. https://epstein-data.com/EFTA01793279 p.1. ↩

32. E-mail from Jeffrey Epstein, export header “Sent Wed 5/18/2011 10:08:25 AM”, no time zone stated, carrying the earlier message beneath a quoted inline header reading “On Wed, May 18, 2011 at 8:12 AM”. Read at the page image; the sheet carries the printed stamps EFTA_R1_00265367 and EFTA01863573. The line is the whole of Epstein’s own text and carries no terminal full stop. No e-mail address on this sheet is reproduced here. https://epstein-data.com/EFTA01863573 p.1. ↩

33. Two clocks, and this page converts neither. The 18 May messages carry an export header of 6:12:41 a.m. for the incoming message and 10:08:25 a.m. for the reply, while the reply’s own quoted inline header times the incoming message at 8:12 a.m. None of the three carries a time zone, so no interval between the two messages is stated here. The same shape runs through the July thread, where one sheet’s quoted inline headers put Epstein’s message at 10:21 p.m. on 12 July above a reply it quotes at 12:46 a.m. on 13 July, which cannot both be read on one clock; this page therefore states the order the thread presents and no interval. The only sheets cited on this page whose headers do carry a zone are the April 2011 list of proceedings, the Google+ notification and the message of 10 December 2011, each “+0000”.¹⁷³⁶²⁵ ↩

34. E-mail to Jeffrey Epstein, “Sent: Wednesday, July 13, 2011 4:46 AM”, carrying Epstein’s message beneath a quoted inline header reading “On Wed, Jul 6, 2011 at 8:49 AM”. Read at the page image; the sheet carries the printed stamps EFTA_R1_00091134 and EFTA01776463. The From field reads “Reichart” above an address covered by the producing party. Epstein’s line is quoted exactly as the sheet prints it, with two spaces after the first comma and two commas after “profile”. The reply is quoted with the line breaks the sheet gives it, and the sheet carries no full stop after “everything)”. The sheet also carries the writer’s complaint about the trustee’s law firm, which is not reproduced here. Served p. 2 of this document is a property list rather than text and nothing from it is reproduced, including the integers in it. https://epstein-data.com/EFTA01776463 p.1. ↩ ↩²

35. E-mail to Jeffrey Epstein, export header “Sent: Wed 7/13/2011 5:50:39 AM”, carrying Epstein’s message beneath a quoted inline header reading “On Tue, Jul 12, 2011 at 10:21 PM”. Read at the page image; the sheet carries the printed stamps EFTA_R1_00263009 and EFTA01862117. Epstein’s line is quoted exactly as the sheet prints it, with a space before the full stop after “cases” and two commas after “them”. Several names are covered by bars in the deepest quoted layer of the thread on this sheet and nothing is written into them; the sentences quoted here cross no covered span. “BS” is the writer’s own abbreviation and this page does not expand it. https://epstein-data.com/EFTA01862117 p.1. ↩ ↩²

36. Google+ notification to Jeffrey Epstein’s address, “Date: Thu, 20 Oct 2011 00:27:09 +0000”, subject “Reichart Von Wolfsheild added you on Google+”, one sheet. Read at the page image; the sheet carries the printed stamp EFTA00687427. The sheet is born digital rather than a scan, so its type is the document. It carries no employer or affiliation for the person it names, and none is taken from it. The sender address is a no-reply address of the service and is not reproduced. https://epstein-data.com/EFTA00687427 p.1. ↩ ↩²