Epstein Secrets

h Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Philip M. Burlington Nichole J. Segal Burlington & Rockenbach, Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 Co-Counsel for Defendant1Counter-Plainhff Bradley J. Edwards

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

ey, M. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Nichole J. Segal Burlington & Rockenbach, M. Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 Co-Counsel for Defendant1Counter-Plaintiff Bradley J. Edwar

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

ey, M. 2139 Palm Beach Lakes Boulevard West Palm Reach. FL 33409 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Nichole J. Segal Burlington & Rockenbach, M. Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwar

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

ley, M. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel Jro DeJendan&Counter-Plaintiff Bradley J. Edwards Nichole J. Segal Burlington & Rockenbach, Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards

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

ey, •. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Co-Counsel for Defendant/Counter-Plaintiff Bradley J. Edwards Nichole J. Segal Burlington & Rockenbach, Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 Co-Counsel for Defendant/Counter-Plaintiff Bradley 2 Edwards

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

nue S, Suite 1400 West Palm Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691 Attorneys for Jeffrey Epstein Nichole J. Se al Es uire • Burlington & Rockenbach, 444 W Railroad Avenue, Suite 350 West Palm Beach, FL 33401 Phone: (561)-721-0400 Attorneys for Bradley J. Edwards Bradle J. Edwards Es uire Fa

V. EPSTEIN Case No.: S02009CA040800XXXXMBAG Order Specially Setting Hearing Response in Opposition to Jeffrey Epstein's Omnibus Motion in Limine; Edwards' Motion in Limine to Strike the June 30, 2017 Affidavit of Jeffrey Epstein and to Exclude Evidence as to which Discovery was withheld under Claims of Privil