URGENT
Aj call mike - guys with money are trying to manage all the logistics but need wire instructions and need to go through a process that takes a few steps
This is not a chart. It is an excerpt from an email.
Key information:
- Sender: Scott Rothstein
- Recipient(s): Multiple, redacted.
- Cc: Ritchie, Thane
- Date: Thursday, October 22, 2009
- Subject: Help
- Context: The email indicates a need for wire instructions and a multi-step process for managing logistics with individuals who have money.
Cc: Ritchie, Thane
Sent: Thu Oct 22 12:09:33 2009
Subject: Help
The shit just hit the fan. Client just threatened to fire me. Thinks I am lying about her funding. And I can't blame her. But I can not be made to look like this. Need to know what is really going on. Please. This is not fair to me or to my firm. I can end up losing all these clients that I have in this matter.....it will literally destroy me and my reputation. This is the reality. Love ya Scott
Legamaru EXHIBIT 6
FOR 3-11-11 LLP
EFTA00804853
Just give me any cause of action that we can work into the factual scheme of this case that is not a tort. That is all I need. Please This is urgent. Love ya me
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I just spoke to Brad about coming up with a contract claim (based on promises Epstein made to help their modelling careers etc) and he is calling some clients to verify that any such representation was made to any of them- he will get back with you very shortly on this.
Thanks,
ME (still Insuspense)
He made those promises to many girls (modeling with Victoria Secret was one of his favorite lines); however, he did not entice our clients that way. It was strictly payment for services, and it's hard to allege a breach where both parties performed.
Bradley J. Edwards
Partner
Rothstein Rosenfeldt Adler| Attorneys at Law
Las Olas City Centre
401 East Las Olas Boulevard, Suite 1650
Fort Lauderdale, FL 33301
Scott:
Hero's where we are.
The Structured Settlement statute (FS 628.99296) refers to 'torts." Based on the language of the statute and its history a 'tort" would be a 'personalinjury claim under Florida common law.
Currently, we have two claims in Epstein which don't squarely fit that definition: Civil RICO and 18 USC 2255. Civil Rico predicates we've alleged include violations of laws which are not based on "personal Injury." Hence, as to those claims, thoy wouldn't fell under the definition of torts as stated in FS 626.99296. Brad was in contact with a Utah law professor (who knows the case) who opines that 18 USC 2255 is a federal statute, thus is doesn't fall within the ambit of FS 626.99296 because of the Supremacy Clause. I think this makes sense, and would take our 18 USC 2255 claim out of the FS 626.99296.
That's the collective wisdom.
Mark S. Fistos
Partner
Rothstein Rosenfeidt Adler I Attorneys at Law
200 W. College Avenue, Suite 226
Tallahassee, FL 33301
mistos@rra-law.com | www.a-law.com
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