EFTA01082728Set 9
2012-06-04133p26,908w
Examination of witness taken before:
21 Pearlyck Martin, FPR
Friedman, Lombardi & Olson
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23
24
25
FRIEDMAN LOMBARDI & OLSON
EFTA01082728
Page 2
1 APPEARANCES:
2
BERGER, SINGERMAN, . by
3 Charles ... Goldberg, Esq.
24 Attorney for Official Commit to of Unsecured
Creditors.
25
FRIEDMAN. LOMBARDI & OLSON
EFTA01082729
Page 3
1 FURR & COHEN, ., by
Robert Furr, Esq.
2 Attorney for Chapter ... FRIEDMAN. LOMBARDI & OLSON
EFTA01082730
Page 4
1 THE COURT: Let the record reflect this is
2 the Rule 2004 Examination of Scott Rothstein taken in
3 the case of Rothstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA01082728.pdf
EFTA00619645Set 9
2012-06-14128p27,637w
behalf of the Trustee
pursuant to a notice of taking deposition
FRIEDMAN. LOMBARDI & OLSON
EFTA00619645
2
1 APPEARANCES:
2
LAW OFFICES OF TONJA HADDAD, P.A. by
3 Tonja Haddad ... Justice.
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23
24
25
FRIEDMAN. LOMBARDI & OLSON
EFTA00619646
3
1 INDEX
2
WITNESS DIRECT CROSS REDIRECT RECROSS
3
SCOTT ROTHSTEIN ... FRIEDMAN. LOMBARDI & OLSON
EFTA00619647
4
1 Thereupon:
2 SCOTT ROTHSTEIN,
3 was called as a witness and, having been duly sworn,
4 was examined and testified as follows
https://www.justice.gov/epstein/files/DataSet%209/EFTA00619645.pdf
EFTA01117299Set 9
32p27,209w
notice of taking deposition 20
21
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FRIEDMAN LOMBARDI & OLSON
FRIEDMAN. LOMBARDI & OISON
4
1 INDEX 1 Thereupon:
2
2 SCOTT ROTHSTEIN,
WITNESS DIRECT 01039 AZDIESE? =CROSS ... right is Darryl Indyke, who is
FRIEDMAN, LOA, BARD] & OLSON
FRIEDMAN. LOMBARDI& OLSON
EFTA01117299
5 6
1 Nr. Bpstein's in-house counsel. 1 different form than it ended because ... vague for me because it started in a 25 INS WITNESS: Yes.
FRIEDMAN, LOMBARDI & OLSON FRIEDAIAN. LOMBARDI & OISON
8
1 BY NS. WOAD: 1 growth started," do you mean both
https://www.justice.gov/epstein/files/DataSet%209/EFTA01117299.pdf
EFTA01130733Set 9
2012-06-1435p27,674w
behalf of the Trustee
pursuant to a notice of taking deposition
- - -
FRIEDMAN, LOMBARDI & OLSON
305-371-6677
5ed93085-0554-4471•bcdd-ca2d81e841d1
EFTA01130735
APPEARANCES: 1 Thereupon:
2
LAW OFFICES ... Page 3 Page 5
"Mk
2 (Pages 2 to 5)
FRIEDMAN, LOMBARDI & OLSON
305-371.6677
6•0930864564-44Mbedd-ca201s9410
EFTA01130736
1 different form than it ended because it started ... with distributions.
Page 7 Page 9
3 (Pages 6 to 9)
FRIEDMAN, LOMBARDI & OLSON
305-371-6677
Sed93085.0554.447f.bcdd-ca2d8te947d1
EFTA01130737
1 Q. When you were hiring and bringing
https://www.justice.gov/epstein/files/DataSet%209/EFTA01130733.pdf
EFTA00606510Set 9
2014-01-2778p19,578w
bars a
9 malicious prosecution claim. And I have cited to
10 the case Olson vs. Johnson, 961 Sold. 356, the
11 Second DCA's opinion in 2007, after both ... doesn't rely on
20 that, on that theory.
21 Our position is that Olson vs. Johnson sets
22 forth the accurate and more persuasive
23 proposition; that is that ... does not bar a
24 malicious prosecution claim. Even though Olson
25 vs. Johnson dealt with complaints by a complaining
www.phippsreporting.com
888 811-3408
EFTA00606534
26
1 witness
https://www.justice.gov/epstein/files/DataSet%209/EFTA00606510.pdf
EFTA00607688Set 9
2014-01-2778p19,578w
bars a
9 malicious prosecution claim. And I have cited to
10 the case Olson vs. Johnson, 961 Sold. 356, the
11 Second DCA's opinion in 2007, after both ... doesn't rely on
20 that, on that theory.
21 Our position is that Olson vs. Johnson sets
22 forth the accurate and more persuasive
23 proposition; that is that ... does not bar a
24 malicious prosecution claim. Even though Olson
25 vs. Johnson dealt with complaints by a complaining
www.phippsreporting.com
888 811-3408
EFTA00607712
26
1 witness
https://www.justice.gov/epstein/files/DataSet%209/EFTA00607688.pdf
EFTA01166186Set 9
2014-01-2762p12,948w
bars a
9 malicious prosecution claim. And I have cited to
10 the case Olson vs. Johnson, 961 So2d. 356, the
11 Second DCA's opinion in 2007, after both ... doesn't rely on
20 that, on that theory.
21 Our position is that Olson vs. Johnson sets
22 forth the accurate and more persuasive
23 proposition; that is that ... does not bar a
24 malicious prosecution claim. Even though Olson
25 vs. Johnson dealt with complaints by a complaining
EFTA01166210
26
1 witness in a case that only resulted
https://www.justice.gov/epstein/files/DataSet%209/EFTA01166186.pdf
EFTA01166123Set 9
2014-01-2763p13,023w
bars a
9 malicious prosecution claim. And I have cited to
10 the case Olson vs. Johnson, 961 So2d. 356, the
11 Second DCA's opinion in 2007, after both ... doesn't rely on
20 that, on that theory.
21 Our position is that Olson vs. Johnson sets
22 forth the accurate and more persuasive
23 proposition; that is that ... does not bar a
24 malicious prosecution claim. Even though Olson
25 vs. Johnson dealt with complaints by a complaining
EFTA01166147
Page 26
1 witness in a case that only
https://www.justice.gov/epstein/files/DataSet%209/EFTA01166123.pdf
EFTA01106989Set 9
51p11,008w
Star Capital Acquisitions, LLC v. King,
611 F.Supp 2d 1324 (M.D. Fla. 2009) 25
Olson v. Johnson
961 So.2d 356 (Fla. 2d DCA 2007) 23, 31, 33, 35
Procacci ... that the privilege would not have
barred a malicious prosecution claim.
Finally, in Olson v. Johnson, 961 So.2d 356 (Fla. 2d DCA 2007), the Second
District also concluded that ... privilege. In that case, Johnson was in a custody battle with a man named
Olson, and she and two of her friends signed affidavits alleging that he was
stalking
https://www.justice.gov/epstein/files/DataSet%209/EFTA01106989.pdf
EFTA01199686Set 9
51p10,988w
Star Capital Acquisitions, LLC v. King,
611 F.Supp 2d 1324 (M.D. Fla. 2009) 25
Olson v. Johnson
961 So.2d 356 (Fla. 2d DCA 2007) 23, 31, 33, 35
Procacci ... that the privilege would not have
barred a malicious prosecution claim.
Finally, in Olson v. Johnson, 961 So.2d 356 (Fla. 2d DCA 2007), the Second
District also concluded that ... privilege. In that case, Johnson was in a custody battle with a man named
Olson, and she and two of her friends signed affidavits alleging that he was
stalking
https://www.justice.gov/epstein/files/DataSet%209/EFTA01199686.pdf
EFTA01104267Set 9
51p10,994w
Star Capital Acquisitions. LLC v. King,
611 F.Supp 2d 1324 (M.D. Fla. 2009) 25
Olson v. Johnson,
961 So.2d 356 (Fla. 2d DCA 2007) 23,31,33, 35
Procacci ... that the privilege would not have
barred a malicious prosecution claim.
Finally, in Olson v. Johnson, 961 So.2d 356 (Fla. 2d DCA 2007), the Second
District also concluded that ... privilege. In that case, Johnson was in a custody battle with a man named
Olson, and she and two of her friends signed affidavits alleging that he was
stalking
https://www.justice.gov/epstein/files/DataSet%209/EFTA01104267.pdf
EFTA01165659Set 9
44p8,425w
Acquisitions, LLC v. King,
611 F.Supp 2d 1324 (M. Fla. 2009) 20
iv
EFTA01165665
Olson v. Johnson,
961 So.2d 356 (Fla. 2d DCA 2007) 18, 26, 28
Procacci v. Zacco ... claims, but that the privilege would not have
barred a malicious prosecution claim.
In Olson v. Johnson, 961 So.2d 356 (Fla. 2d DCA 2007), the Second District
also concluded that ... privilege. In that case, Johnson was in a custody battle with a man named Olson,
and she and two of her friends signed affidavits alleging that he was stalking
https://www.justice.gov/epstein/files/DataSet%209/EFTA01165659.pdf
EFTA01138929Set 9
2007-01-0633p8,537w
protection of the privilege.
Wolfe, 128 So. 3d at 71. The Third District cited Olson v. Johnson, 961 So. 2d 356
(Fla. 2d DCA 2007) and Am. Nat'l Title ... claim for
malicious prosecution where the elements of that tort are satisfied.
3 In Olson, the act complained of in the malicious prosecution action was a
police report falsely accusing ... Olson of stalking. In Am. Nat'l Title & Escrow, a
claim of absolute privilege was rejected upon a finding that the defendants would
enjoy at most a qualified privilege
https://www.justice.gov/epstein/files/DataSet%209/EFTA01138929.pdf
EFTA01154575Set 9
2014-09-304p2,391w
restoring public confidence in the agency and boosting employee morale.
National Taxpayer Advocate
Nina Olson has been the National Taxpayer Advocate since 2001. She heads up the Taxpayer Advocate
Service ... which was created in 2000, and is an independent organization within the IRS. Ms. Olson
and the TAS are the taxpayers "voice at the IRS." The TAS is designed ... navigate issues
with the IRS when the usual channels have failed; in addition, Ms. Olson regularly focuses on larger issues
within the IRS and the tax system itself, and recommends
https://www.justice.gov/epstein/files/DataSet%209/EFTA01154575.pdf
EFTA00157004Set 9
2020-01-1022p8,934w
theoretically complex and thus difficult to
apply in real-world settings (e.g., Elliott, 2017; Olson et al., 2007). Winters and
Jeglic (2017) model of grooming behavior proposes five overarching stages ... targeted child and isolate him/her from others. Indeed, Lanning (2010),
Craven et al. (2006), Olson et al. (2007), and Leclerc et al. (2009) all proposed
models that include a stage ... trust and cooperation
with the child (Craven et aL, 2006; Leclerc et at, 2009; Olson et al., 2007). While
some models incorporate a broad stage that refers to the overarching
https://www.justice.gov/epstein/files/DataSet%209/EFTA00157004.pdf
EFTA00156832Set 9
2016-02-0111p6,024w
perceived vulnerabilities of the child (Lanning 2010;
McAlinden 2006; Mooney and Ost 2013; Olson, Ellevold, and Rogers 2007). Elliott, Browne,
and Kilcoyne (1995) found that when selecting a victim, offenders ... childcare responsibilities (Conte et al. 1989; Elliott et al. 1995; Lang and Frenzel 1988; Olson
et al. 2007). Further, children who have families with alcohol or drug addictions, emotional ... risk for sexual abuse as these situations may also lead to less parental supervision (Olson et al.
2007). The offender may also seek children with perceived psychological vulnerabilities that
would
https://www.justice.gov/epstein/files/DataSet%209/EFTA00156832.pdf
EFTA00156941Set 9
11p10,434w
authority for the perpetrator—a sense of fear in the victim to sexual contact (Olson et al., 2007) and using previous sexual
and an "invisible cage"—to perpetuate the victim ... between coercive control in 1PV and
found in research on sexual predation of youth (Olson et al.. 2007)
other contexts of power and control. Coercive control ... paid by the victim (Langenderfer & Shimp.
perpetrator. victim, and sometimes the victim's family (Olson. 2001). In these instances the perpetrator skillfully focuses the
Daggs, Ellevold. & Rogers. 2007). Trust
https://www.justice.gov/epstein/files/DataSet%209/EFTA00156941.pdf
EFTA00589617Set 9
2015-02-1830p6,231w
Medical Center, Inc.,
935 So. 2d 1266 (Fla. 4th DCA 2006) 13
ii
EFTA00589619
Olson v. Johnson,
961 So. 2d 356 (Fla. 2d DCA 2007) 17, 22
Pardo v. State ... still be
viable. See Fridovich v. Fridovich, 598 So. 2d 65 (Fla. 1992); Olson v. Johnson,
961 So. 2d 356 (Fla. 2d DCA 2007).
Moreover, the Florida Supreme Court judiciously ... institution of criminal charges." 598 So. 2d at 69 (emphasis added). See also
Olson v. Johnson, 961 So. 2d 356 (Fla. 2d DCA 2007) (litigation privilege is
inapplicable because basis
https://www.justice.gov/epstein/files/DataSet%209/EFTA00589617.pdf