Epstein Secrets

perfield and Bill Richardson for deposition en 70-75); purported relevancy of pilot and flight logs to show interstate airplane travel in support of Jane Doe's Federal Rico claims and punitive damages (911 77-79); Epstein's interview with a New York newspaper reporter (9191 80-81); Epstein's alleged threat

Renewed Motion for Summary Judgment should be denied. Dated: February 16, 2012. Respectfully submitted, Joseph L. Ackerman, Jr. Florida Bar No. FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Easier Drive West Palm B Telephone: Facsimile: and Christopher E. Knight Florida Bar. No. FOWLER WHI

position You testified under oath (at page 12), there are only three cases in existence against Jeffrey Epstein in which You represent a plaintiff (Jane Doe, ands. 2. Admit that the testimony described in Request No. 1 is false. 3. Admit that in Your March 23, 2010 deposition you testified under oath

d West Palm Beach, FL 33409 Suite 700 Fort Lauderdale, FL 33301 Attorneys for Defendant Bradley Edwards Attorneys for Defendant Scott Rothstein FOWLER WHITE BURNETT, P.A. Attorneys for Plaintiff Jeffrey Epstein Espirito Santo Plaza 1395 Brickell Avenue, 14th Floo Miami, Florida 33131 By: '. Sanchez, Esq. d

position You testified under oath (at page 12), there are only three cases in existence against Jeffrey Epstein in which You represent a plaintiff (Jane Doe, and M.). 10. Admit that the testimony described in Request No. 16 is false. 11. Admit that in Your March 23, 2010 deposition you testified unde

s Blvd. West Palm Beach, FL 33409 FL 33301 Suite 700 383-9424F Attorneys for Defendant Bradley Edwards Attorneys for Defendant Scott Rothstein FOWLER WHITE BURNETT, P.A. Attorneys for Plaintiff, Jeffrey Epstein Espirito Santo Plaza 1395 Brickell Avenue, 14th Floor *3131 305.789.9201 fax By: Lilly A. Sanch

standing to argue against Epstein's Motion for Protective Order. The response to Epstein's Motion for Protective Order came not from the Plaintiff, Jane Doe or on behalf of the Plaintiff Jane Doe, but by her counsel, claiming he in fact was the real party in interest. Edwards, in his response, shows no b

the parties agreed to keep the records in question confidential until notice of intended use was given, an opportunity for objection to such use by FOWLER WHITE BURNETT. P.A. • EFTA00235277 Case 9:08-cv-80893-KAM Document 223 Entered on FLSD Docket 11/01/2010 Page 2 of 9 Jane Doe v. Jeffrey Epstein Case No. 08-

s specific claims against Edwards do not give Edwards carte blanche to inquire into any and all sexual conduct and related matters. Nor do the and Jane Doe cases that Edwards filed — which settled — open the door to such expansive and entirely irrelevant discovery, or give Edwards the right to ask Epst

il 2, 2012. 7 EFTA00309494 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Jeffrey Epstein's Reply to Edwards' Response FOWLER WHITE BURNETT, P.A. Attorneys for Plaintiff Jeffrey Epstein and Christopher E. Knight Florida Bar. No. 607363 FOWLER WHITE BURNETT, P.A. Attorneys for Plaint