Epstein Secrets

ack Scarola, Esq., Searcy Denney Scarola et al., 2139 Palm Beach Lakes Boulevard, West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401-5012; and Marc S. Nurik, Esq., Law Offices of Marc S. Nurik, One East Bro

very issues. EFTA00613622 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Division AG 3. At the hearing on September 28, 2011 on Edwards' Motion to Dismiss the Second Amended Complaint, this Court reiterated that it wanted to get the issues in the pleadings resolved before addressing discove

dale, FL 33301 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Counsel for Defendant Scott Rothstein Jack A. Goldberger Atterbury, Goldberger & Weiss, .. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein Paul Cassell 383

Fourth District Court of Appeal. Obviously, however, Epstein's general references to documents could not possibly have violated the Court's ruling. Edwards' Motion is just another attempt to derail an in camera review of 'A written Order has not been issued on the Court's March 8, 2018, rulings. EFTA00808672

rdale, FL 33301 Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley I Edwards Jack A. Goldberger Atterbury, Goldberger & Weiss, .. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 Co-Counsel for Plaintiff/Counter-Defendant Je E stein 9 EFTA00808703

aint. Significant to this case and Epstein having probable cause to continue with this suit against Edwards was Judge Crow's finding when he denied Edwards' Motion to Dismiss Epstein's Second Amended Complaint. Edwards' Motion to Dismiss asserted the litigation privilege as an absolute bar to Epstein's cause of

dale, FL 33301 Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Jack A. Goldberger Atterbury, Goldberger & Weiss, M. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 Co-Counsel for Plaintiffitoimter-Defendant Je E stein 12 EFTA00808644

d the NPA and there was no legitimate purpose for them to make the agreement public. Furthermore, the CVRA court had recently (February 2009) denied Edwards' Motion to Unseal the NPA in that action. (Jane Doe v. U.S., Case No. 08-CV-80736, D.E. 36.) Edwards wants the Court to believe, however, that Epstein's mo

dale, FL 33301 Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Jack A. Goldberger Atterbury, Goldberger & Weiss, M. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 Co-Counsel for Plaintiffitoimter-Defendant Je E stein EFTA00808725

t to avoid the Florida Evidence Code by propounding the tardy discovery requests should be rejected. CONCLUSION Epstein respectfully requests that Edwards' Motion be denied. Edwards asked for confirmation of the pretrial deadlines and must be held to that request. There was no court ruling "on motions current

ndrews Avenue, Suite 2 Ft. Lauderdale, FL 33301-3268 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Jack A. Goldberger Atterbury, Goldberger & Weiss, M. 250 Australian Avenue S., Suite 1400 West Palm Beach, FL 33401 Co-Counsel for Plaintiff/Counter-Defendant Jea•ey Epstein Marc S. Nurik Law

cutoff date" and Edwards objected "to any effort to expand existing deadlines." Id. On November 27, 2017, the Court agreed with Edwards and granted Edwards' Motion finding that, "to the extent that wholesale additional discovery will not be permitted but individual discovery requests may be allowed on a matter