EFTA01105354.pdf

int Form The Florida Bar Inquiry/Compla . Attorney's Name: S enter Kuvin Es Your Name: Jeffrey Epstein Addres Address: 250 Australian Ave S. Suite 1404 State: a City:Eliot City: WE. s . :,:-.- State: FL lap Code: Phone: Phone: IIMIIIMIll Zip Code: 3$410 33401 ACAP Reference No. I am complaining about are: PART TWO: The specific thing or things No. I am the Def end ant in the case styled B.B. v, Epstein, Case 1. Palm Beach Fifteenth Judicial Circuit in and for 502008CA037319)000(MB AB in the taken by Florida . On Sep tem ber 2, 200 9 I attended my deposition, which was County, Spencer Kuvin, Esq. ., took my deposition, which began at 2. Spencer Kuvin, counsel for Plaintiff, B.B approximately 10:00 a.m. Kuvin asked, Ills it true, sir, that you 3. Directly after asking me my name, Mr. ript attached ped penis.' See Deposition Transc have what's been described as an egg-sha deposition in cho se to immediately set the tone of the as Exhibit "A." Accordingly, Mr. Kuv iliate and in an effort to harass, embarrass, hum in a sarcastic and demeaning manner entire deposition process. In an attempt to intimidate me, thereby disregarding the with this and intimidate me, Mr. Kuvin continued continue to embarrass, humiliate, harass me or to my document that Mr. Kuvin did not provide line of questioning by referencing a r, acc ording to the police department's probable counsel and then asked the following: "[O m[ed], when your penis as oval shaped and clai cause affidavit, one witness described thin and small - - towards the head portion, erect, it was thick towards the bottom but was EFTA01105354 and called it egg-shaped . . . ." See Exhibit A. it was obvious from Mr. Kuvin's tenor that (1) to he did not Intend to have a meaningful deposition. Instead, his goals were clear — embarrass, humiliate, intimidate and harass me; and (2) attempt to gain notoriety for himself and his firm. 4. Mr. Kuvin told one of my attorneys that he did not expect to make much money in this case, that he was a young lawyer and needed to market himself and get as much publicity as necessary for himself and his firm and that the case was another marketing method for himself and his firm. See Affidavit of Jack Goldberger, Esq. attached as Exhibit B. Nevertheless, Mr. Kuvin apparently subscribes to the old adage, °there is no such thing as bad publicity? 5. To further his goal of embarrassing and humiliating me and gaining a tactical media advantage before trial, as well as his goal to market himself and his firm, Mr. Kuvin provided the media and/or the Palm Beach Post with a copy of my video deposition, which was posted on the Palm Beach Posts website (http://www.page2live.com/2009/09/17/perv- epstein-wont-talk-about-his-penis0 and other sites on the Internet, such as http://www.voutube.com/watch7v=adCScCVZ9Rw&feature=related and htto://www.huffinatonoostecom/2009/09/17/eaq-shaoed-oenis-leffrev n 290464.htrnl, as well as numerous other sites. As the bar will see from the titles and comments in response to the article and video provided to the media by Mr. Kuvin, my rights to a fair trail have been prejudiced here in Palm Beach County. 6. Moreover, on or about September 17, 2009, Mr. Kuvin, provided the media with an interview regarding a Non-Prosecution Agreement (the %PA") I entered into with the United States Attorneys Office. interestingly, Mr. Kuvin's client Is not even listed on the 2 EFTA01105355  the opportunity to speak to the NPA. Yet, Mr. Kuvin felt compelled, once again, to harness 33 girls. He could've faced media about me. Mr. Kuvin stated: "Epstein victimized at least these charges' See Exhibit "C". at least 33 life sentences had he been convicted under it essentially brushes them its extremely unfair, extremely unfair to the 33 girls because a big deal.' Id. "There's no other aside as though nothing happened to them and it wasn't theart deal had they not been as person, no other person who would've gotten such a swee wealthy and as powerful as Jeffrey Epstein." Id. Mr. Kuvin as no basis to make such comments and his doing so is prejudicing my right to fair trial. a: 7. Mr. Kuvin has also made the following statements to the medi s, calls the decision [by a. "But Spencer Kuvin, a lawyer for one of the victim 'frustrating.' the Fourth District Court of Appeals to not release the NPA] they are for poor 'The rules shouldn't be different for rich people than people,' Kuvin said. `Had Epstein been a regular citizen, and not a time ago.'" billionaire, this document would have been made public a long as Exhibit "D". See Palm Beach Post Daily News July 2, 2009 attached 's client, Kuvin b. With respect to a settlement of a claim brought by Kuvin the resolution, told the Palm Beach Daily News, "She was not happy with trying to but she wanted it over. He's got investigators in the civil cases Is that he dig up dirt on every one of his accusers. The disgusting thing now he pleads the fifth on everything that's been asked of him and got demands these girls' lives become an open book. ... He absolutely News special treatment because he's wealthy? See Palm Beach Daily July 23-25, 2009 attached as Exhibit "E." 3 EFTA01105356  8. Moreover, some of the articles involving Jeffrey Epstein are directly 'linked' to the Leopold-Kuvin website found at www,le000ldkuvin.coM. 9. Mr. Kuvin's conduct is improper and violates Florida Rule of Professional Conduct 4-3.6 — Trial Publicity. Mr. Kuvin has obstructed my right to obtain a fair trial by virtue of his interviews and meeting with the media, which were done for the sole purpose of gaining media attention for Mr. Kuvin. In fact, Mr. Kuvin's actions may be in direct conflict with his client's directive and wish in connection with her requests to remain confidential and travel under the pseudonym, B.B., in this above referenced matter. PART THREE: The witnesses in support of my allegations are: 1. Jack Goldberger, Esq., Atterbury, Goldberger & Weiss, P.A., 250 Australian Ave South, Suite 1400, West Palm Beach, FL 33401. 2. Robert D. Critton, Jr. and Michael J. Pike of Burman, Critton, Luttier and Coleman, 303 Banyan Boulevard, West Palm Beach, Florida 33401. Suite 400. PART FOUR: Under penalty of perjury, I declare the foregoing facts are true, correct and complete 4 EFTA01105357  The Florida Bar Inquiry/Complaint Form Your Name: Jeffrey Epstein Attorney's Name: J3radley Edwards, ESQ., William Berger, Esq. and Scott W. Rothstein Address: 250 Australian Ave S., Address: Rothstein Rosenfeldt Adler, Suite 1404 P.A., 401 East Las Olas Boulevard, Suite 1650 City: West Palm Beach State: a City: Fort Lauderdale State: EL Zip Code: Phone: Zip Code: Phone: 33401 33aQ,1 ACAP Reference No. g about are: PART TWO: The specific thing or things I am complainin Epstein Case No. 1. I am the Defendant in cases styled E.W. v. 50200 8CA028058)OOO(MB AB 502008CA028051XXXXMB AB, L.M. v. Epstein Case No. ty, Florida and Jane Doe v. in the Fifteenth Judicial Circuit in and for Palm Beach Coun s Distri ct Court, Southern Epstein, Case No. 08-CIV-80893 Marra/Johnson, United State District Court of Florida. their firm, Rothstein, 2. Mr. Edwards, Mr. Berger and Scott Rothstein, through ntly represent the three Plaintiffs Rosenfeldt and Adler, P.A., CRRA") represented and curre Individuals. listed above, L.M., E.W. and Jane Doe; and, possibly other running a covert 3. Based upon the news media reports of Mr. Rothstein belief that the above-referenced investment scheme built on legal settlements, It Is my by promising those investors a lawyers obtained investors in the various cases against me in these cases. piece/share of the fees, settlements or verdicts reached EFTA01105358  4. Mr. Edwards has represented to my attorneys on multiple occasions that he taken believes these cases are worth tens of millions of dollars. Extensive discovery has place by Mr. Edwards with what appears an unlimited budget to litigate these cases. 5. I believe that the above lawyers and RRA improperly, unethically and potentially illegally solicited investors in these personal injury contingent cases to front money for payment of bills and costs with the understanding in writing or orally that the investors would receive a share of the attorneys fee or prospective settlement or judgment if and when any return was realized. 6. As of the current date, I have settled no cases with Mr. Edwards, Mr. Berger, Mr. Rothstein or RRA. 7. I believe various Florida Rules have been broken by the above-referenced attorneys with this investment scheme. I believe the following Bar Rules, but not limited to these Rules have been violated: Rule 4-1.2(d), 4-1.4; 4-1.5(a)(dXf)(g); 4-1.8(aXeXf)(i); 4- 8.3 and 4-8.4. PART THREE: The witnesses in support of my allegations are: 1. Bradley Edwards, Esq., William Berger, Esq., Scott Rothstein, Esq., Judge Herbert Stettin, the receiver, Stuart Rosenfeldt, Esq.; partners of Rothstein Rosenfeldt Adler, P.A., 401 East Las Olas Boulevard, Suite 1650, Fort Lauderdale, FL 33301; investors (unknown to me at this time). 2. My attorneys as to what has been said to them re: alleged value of the cases, Robert D. Critton, Jr., Esq. and Michael J. Pike, Esq. of Burman, 2 EFTA01105359  Critton, Luttier and Coleman, 303 Banyan Boulevard, Suite 400, West Palm Beach, Florida 33401 3. The Plaintiffs, L.M., E.W. and Jane Doe (S.R.). PART FOUR: Under penalty of perjury, I declare the foregoing facts are true, correct and mplete Si Date 3 EFTA01105360