Epstein Secrets

vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiff. AFFIDAVIT OF JEFFREY EPSTEIN The undersigned, Jeffrey E. Epstein, having first been duly sworn, hereby deposes and says: 1. I am over eighteen (18) years old and have personal knowledge of the facts stated here

or leave to file the supplemental argument contained herein on the following grounds: 1. The trial judge entered summary final judgment in favor of Epstein on the ground that the litigation privilege bars the malicious prosecution and abuse of process claims filed against Epstein by the appellant, Brad

unrelated to the underlying litigation against me, and (b) asserting my causes of action against Edwards and Rothstein in the Action. FURTHER AFFI JEFFREY EPS STATE OF NEW YORK ) ) ss.: COUNTY OF NEW YORK ) _ - Sworn and subscribed to before me, the undersigned authority, by Jeffrey Epstein, this 25t

e of these potentially explosive facts, putative defendant Epstein had allegedly offered $200,000,000.00 for settle

. 4D14-2282 BRADLEY J. EDWARDS, Appellant, v. JEFFREY EPSTEIN, Appellee. MOTION FOR LEAVE TO FILE SUP

sponse to the same line of questioning when asked about all of the other attorneys with whom Edwards worked, such as Gary Fanner, Seth Lehrman, and Mark Fistos was, unequivocally, "yes", that they would have reported illegal activity." In the afternoon session of his deposition on that same day, Rothstein

Esq.? How about Mark Fistos, Esq.? Were they all secret co- conspirators who have managed to avoid justice for the past nine years? Justice that only Jeffrey Epstein and his counsel can deliver upon? Does Epstein plan to report his "bombshell" findings to 3 Edwards is somewhat confused as to how Epstein could hav

, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and ■l., individually, Defendants. RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION FOR COURT TO DECLARE RELEVANCE AND NON-PRIVILEGED NATURE OF DOCUMENTS AND REQUEST FOR ADDITIONAL LIMITED DISCOVERY, EVIDENTIARY HEARING, A

OUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

cause a media circus, taint the jury pool, and prevent the parties to the Malicious Prosecution action from picking a jury as presently scheduled. B. Epstein and His Counsel Have "Jumped the Shark."2 5. In his Notice of Filing Appendix. Epstein, through counsel, includes privileged materials under a sect

or over 5 years!; 7. Is Epstein accusing Matt Weissing, Esq. of being directly involved in Rothstein's Ponzi scheme? Steven Jaffe, Esq.? How about Mark Fistos, Esq.? Were they all secret co- conspirators who have managed to avoid justice for the past nine years? Justice that only Jeffrey Epstein and his co

the discovery of admissible evidence; protected by privacy rights 02411-02413 05/12/2009 Attorneys at RRA Bradley J. Edwards Jane Doe II v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protect

the discovery of the admissible evidence; protected by privacy rights 01003-01005 10/12/2009 Bradley Edwards Paul Cassell Asset movement by Jeffrey Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protect

calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05403-05405 04/27/2009 Marc Nurik Bradley Edwards Jeffrey Epstein Wikipedia page Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; pr

0 09/13/2009 Bradley Edwards Paul Cassell "Is Jeffrey Epstein the new Madoff — Running a giant Ponzi

and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 08454 10/23/2010 Attorneys at RRA Mark Fistos Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; pr

the discovery of admissible evidence; protected by privacy rights 02411-02413 05/12/2009 Attorneys at RRA Bradley J. Edwards Jane Doe II v. Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protect

the discovery of the admissible evidence; protected by privacy rights 01003.01005 10/12/2009 Bradley Edwards Paul Cassell Asset movement by Jeffrey Epstein Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; protect

calculated to lead to the discovery of the admissible evidence; protected by privacy rights 05403-05405 04/27/2009 Marc Nurik Bradley Edwards Jeffrey Epstein Wikipedia page Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence; pr

0 09/13/2009 Bradley Edwards Paul Cassell "Is Jeffrey Epstein the new Madoff — Running a giant Ponzi

and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 08454 10/23/2010 Attorneys at RRA Mark Fistos Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; pr

OLA BARNHART Fr-SHIPLEYp. MAIL March 22, 2011 Robert B. Carney, Special Master 2281 Saratoga Lane West Palm Beach, FL 33409 Re: Edwards adv. Epstein Our File No.: 291874 Dear Judge Carney: OTAI LAHARSFE OFFICE- Attached please find the Master Contact List pursuant to your Interim Report in this

Litigation Team RRA attorneys and staff Marc Nurik Attorney RRA Margaret Berk Legal Assistant to Spencer Kuvin Maribel Matiska RRA Paralegal Mark Fistos Attorney RRA Mercedes Estrada Katherine Ezell's Assistant MG Client (Epstein Case) Michael Wheeler Attorney RRA Mike Fisten Investigators RR

TOWLE HO SE TALLAHASSEE. FL 32331-1231 TALLAHASSEE, March 22, 2011 Robert B. Carney, Special Master West Palm Beach, FL 33409 Re: Edwards adv. Epstein Our File No.: Dear Judge Camey: Attached please find the Master Contact List pursuant to your Interim Report in this matter. Sincerely, Dictate

Litigation Team RRA attorneys and staff Marc Nurik Attorney RRA Margaret Berk Legal Assistant to Spencer Kuvin Maribel Matiska RRA Paralegal Mark Fistos Attorney RRA Mercedes Estrada Katherine Ezell's Assistant Client (Epstein Case) Michael Wheeler Attorney RRA Mike Fisten Investigators RRA C

DRAFT OF: February 18, 2011 EPSTEIN NAMES IN APPEARING IN VARIOUS DEPOSITIONS FROM RUSSELL Jack Simone Gary Farmer Steve Lippman Robert Buschel Russell Mix Frank Veilson Jacky

chet Mark Melvin Jack Samoney Lawrence King Steve Jackel Michael Legamaro Kevin Draber David Boden Andrew Barnett Alan Sakowitz Mark Nurik Mark Fistos Tommy Mottola Officer Recarey Interviewed by Michael Fisten Investigator FBI Agent FBI Agent US Attorney Rothstein's right arm (Deposed by E

. tb La) VIA EMAIL AND U.S. MAIL March 22, 2011 Robert B. Carney, Special Master 2281 Saratoga Lane West Palm Beach, FL 33409 Re: Edwards adv. Epstein Our File No.: Dear Judge Carney: 291874 (TALLAHASSEE OFFICE: THE TOWLE HOUSE 517 NORTH CALHOUN STREET TALLAHASSEE, FL. 32301-1231 P.O. BOX 1230

itz Litigation Team RRA attorneys and staff Marc Nurik Attorney RRA Margaret Berk Legal Assistant to Spencer Kuvin Maribel Matiska RRA Paralegal Mark Fistos Attorney RRA Mercedes Estrada Katherine Ezell’s Assistant MG Client (Epstein Case) Michael Wheeler Attorney RRA Mike Fisten Investigators RRA N.