Epstein Secrets

EFENDANT/COUNTER-PLAINTIFF, BRADLEY J. EDWARDS PlaintifOCounter-Defendant, Jeffrey Epstein, by and through his undersigned counsel, and pursuant to the Florida Rules of Civil Procedure, files this his Notice of Propounding First Set of Expert Witness Interrogatories and Request to Produce Expert Reports directed to Defendant/Count

Blvd., Suite 700 Ft. Lauderdale, FL 33301 Joy L. Acke Jr. 14 3 6± Fla. Bar No. 235954 FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: (561) 802-9044 Facsimile: (561) 802-9976 Attorneys for Jeffrey Epstein, Plaintiff/ Counter-defendant

ON TO COMPEL DISCOVERY RESPONSES AND FOR SANCTIONS Plaintiff Jeffrey Epstein, by and through his undersigned counsel and pursuant to Rule 1.380 of the Florida Rules of Civil Procedure, hereby moves this Court to enter an order compelling the Defendant Bradley Edwards, yet again, to provide responses to Plaintiff's Request for Pro

BLE DAVID F. CR( )w %it CIRCUIT JUDGE Copies furnished to: Joseph L. Ackerman, Jr., Esq. Fowler White Burnett, P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, FL 33401 Lilly Ann Sanchez, Esq. The L•S Law Firm Four Seasons Tower, 15th Floor 1441 Brickell Avenue Miami, FL 33131 Jack Sc

LEGAL AUTHORITIES Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("EPSTEIN"), by and through his undersigned counsel and pursuant to Rule 1.280(c) of the Florida Rules of Civil Procedure, files this Motion for Protective Order to Preclude Opposing Counsel and Defendant/Counter-Plaintiff From Making Extra-Judicial Statements and Comm

01. J eph Ackerman, Jr. Fla. Bar No. 235954 Christopher E. Knight Fla. Bar. No. 607363 FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: (561) 802-9044 Facsimile: (561) 802-9976 W:V30743NOTIIRG30-Epstein's MPO co Ewa-Judicial Slatnals-CEK.

' REQUEST TO PRODUCE Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, hereby files his Responses and Objections to Defendants/Counter-Plaintiffs' Request to Produce to Jeffrey Epstein dated October 28, 2011 and in su

: December 12, 2011. Respectfully submitted, seph . Ackerman, Jr. •lorida Bar No. 235954 FOWLER WHITE BURNETT, P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: (561) 802-9044 Facsimile: (561) 802-9976 Attorneys for Plaintiff Jeffrey Epstein - 3 - EFTA00286380

e 3 of 6 Bruhnel's testimony abroad pursuant to Florida, Federal and International law. Indeed, undersigned counsel directed plaintiff's counsel to the Florida Rules of Civil Procedure and the Hague Convention, each of which provide specific mechanisms for the securing of testimony abroad. Plaintiff's counsel has never served Mr.

rt deems appropriate. Dated: March 12, 2010 Respectfully submitted, TAMA BETH KUDM AN, P.A. Attorney for Non-Party Witness, Jean Luc Bruhnel 777 South Flagler Drive Suite 800 - West Tower -5- EFTA01660081 Case 9:09-cv-87.092-KAM Document 14 Entered on FLSD Docket 03/12/2010 Page 6 of 6 West Palm Beach, FL 33

LEGAL AUTHORITIES Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.280(c) of the Florida Rules of Civil Procedure, files this Amended Motion for a Protective Order to Preclude Opposing Counsel and Defendant/Counter-Plaintiff From Making Extrajudicial Statements

ary and proper. Respectfully submitted, By: Joseph L. Ackerman, Esq. Fla. Bar No. 235954 FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 - 9 - FOWLER WHITE BURNETT P.A. • ESPIRITO SANTO PLAZA, 1395 BRICKELL AVENUE, 14" FLOOR. MIAMI, FLORIDA 33131 • (30

LEGAL AUTHORITIES Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.280(c) of the Florida Rules of Civil Procedure, files this Amended Motion for a Protective Order to Preclude Opposing Counsel and Defendant/Counter-Plaintiff From Making Extrajudicial Statements

ary and proper. Respectfully submitted, By: Joseph L. Ackerman, Esq. Fla. Bar No. 235954 FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 and Christopher E. Knight Fla. Bar. No. 607363 FOWLER WHITE BURNETT P.A. Espirito Santo Plaza, 14th Floor 1395