Epstein Secrets

Post, moyes pursuant to Fla, R. Civ. P. 1.510(a) for Summary Judgment and states: I. INTRODUCTION The material facts in this case are not in dispute. Jeffrey Epstein was an extraordinarily wealthy, influential, and serial pedophile. It is indisputable that the State failed or refused to use the tools available to

therwise available in the public record-to inform the public as to whether the then State Attorney for Palm Beach County presented truncated evidence ofEpstein’s criminal wrongdoing to the 2006 grand jury in a manner that precluded Epstein’s indictment for the serious crimes he committed, including sex traff

effrey Epstein, till when he had been informed of Mr. Epstein’s reputation and his wealth, and I just thought t

e material facts in this case are not in dispute. Jeffrey Epstein was an extraordinarily wealthy, influenti

are the subject of this action.” Clerk Answer 3 J 71. The Defendants’ Motions to Dismiss were heard on June 3, 2020. While this “case is assigned to Division AG, which is currently presided over by the Honorable Donald Hafele ... ”, Chief Judge ofthe Fifteenth Judicial Circuit, [Hon. Krista Marx] presided ove

NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, indivi

you put into Q-task regarding the claims against Mr. Epstein? Edwards had filed suits against Epstein on beha

rrett, 742 So. 2d 451 (Fla. 5th DCA 1999. Therefore, if the answer was evident from the complaint eventually filed by Edwards ("to seek redress from Jeffrey Epstein"), it would not be privileged. Likewise, if L.M. had initially hired Edwards to consult him about a claim she never pursued, the subject might argua

lm Beach County Courthouse, 205 North Dixie Highway, Courtroom 9C, West Palm Beach, Florida 33401 on Friday, April 1, at 9:00 a.m., the following: EPSTEIN'S AMENDED AND SUPPLEMENTAL MOTION OF PLAINTIFF TO OVERRULE OBJECTIONS AND COMPEL DEFENDANT EDWARDS TO ANSWER QUESTIONS AND APPEAR FOR FURTHER DEPOS

NDANT EDWARDS TO ANSWER QUESTIONS AND APPEAR FOR FURTHER DEPOSITION The following procedures must be noted on all specially set hearing notices in Division AG: 1. The JA cannot cancel this hearing unless the issue is resolved. 2. No add-ons are permitted without contacting the JA. 3. Any Memorandums subm

ives or any other electronic format and any written transcriptions). 13. All conversations recorded from any telephones which purported to be from Jeffrey Epstein's attorneys including Roy Black, Alan Dershowitz or Jack Goldberger, that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives

Beach County Courthouse, 205 North Dixie Highway, Courtroom 9C, West Palm Beach, Florida 33401, on Tuesday, April 5, at 8:30 a.m., the following: EPSTEIN'S MOTION TO COMPEL/MOTION TO DETERMINE IF PRIVILEGE CLAIMS ARE WAIVED The following procedures must be noted on all specially set hearing notices i

NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, indivi

and/or Scott Rothstein relating to any aspect of Mr. Epstein's case. Objections were based on relevance and o

MOTION TO COMPEL/MOTION TO DETERMINE IF PRIVILEGE CLAIMS ARE WAIVED The following procedures must be noted on all specially set hearing notices in Division AG: 1. The JA cannot cancel this hearing unless the issue is resolved. 2. No add-ons are permitted without contacting the JA. 3. Any Memorandums subm

iff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. ORDER ON PLAINTIFF JEFFREY EPSTEIN'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS FROM DEFENDANT BRADLEY EDWARDS AND FOR SANCTIONS THIS MATTER came before the Court on Plaintiff Jeffrey E

.1„ 11 ‘,„,--/;;„, g o aLevi o „Ni ,tart c.,. A144- 1..2.6b(9(5) dna.. 776- Liu/746'm / 7" 5‘->zel 33196'4- 91:1- c'c-"D°0- --274 EFTA00609375 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Division AG Order on Epstein's Motion to Compel and for Sanctions Page 2 of 2 74 Attais 7

NO. 502009CA040801:0OOCXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

9(5) dna.. 776- Liu/746'm / 7" 5‘->zel 33196'4- 91:1- c'c-"D°0- --274 EFTA00609375 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Division AG Order on Epstein's Motion to Compel and for Sanctions Page 2 of 2 74 Attais 75-e- Matt 710A: e et led 4- 4 lit if ad/ onzAa DONE AND ORDERED

FWB Matter No. 80743 Dear Judge Crow: Please find enclosed a Notice of Hearing (Uniform Motion Calendar) and a copy of Plaintiff/Counter-Defendant Jeffrey Epstein's Motion for Clarification Regarding Discovery. a.m. The hearing on this Motion is scheduled before your Honor on November 9, 2011 at 8:45 Thank you

eph L. Ackerman, Jr. ect fax 11 Re: Jeffrey Epstein v. Scott Rothstein, individually, Bradley J. Edwa

401 Joseph L. Ackerman, Jr. ect fax 11 Re: Jeffrey Epstein v. Scott Rothstein, individually, Bradley

Jr. ect fax 11 Re: Jeffrey Epstein v. Scott Rothstein, individually, Bradley J. Edwards, individually PBC Circuit Case No. 502009CA040800XXXXMB/Division AG FWB Matter No. 80743 Dear Judge Crow: Please find enclosed a Notice of Hearing (Uniform Motion Calendar) and a copy of Plaintiff/Counter-Defendan

ter-Defendant, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR CLARIFICATION REGARDING DISCOVERY Plaintiff/Counter-Defendant JEFFREY EPSTEIN ("Epstein") by and through undersigned counsel, her

tiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR CLARIFICATION REGARDING DISCOVERY Plaintiff/Counter-Defendant JEFFREY EPSTEIN ("Epstein") by and through undersigned counsel, hereby moves for clarification of prior court directives regarding a stay of discovery until the pleadings

SE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

e before addressing discovery objections and other discovery 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 th

ant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. ORDER ON PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO CONTINUE HEARING ON EDWARDS' RENEWED MOTION FOR SUMMARY JUDGMENT THIS MATTER came before the Court on Plaintiff/Counter-Defendant Jeffre

Av-1_, dApS1-1-z:J o Scab-? *e# sek, a X....2 -cia`;;C_ 2) 12, vlt i 6c, Az..se.kc Ay -A- en InetA ep —2 o /2. else- g e • EFTA00708802 Epstein v. Rothstein and Edwards Case No. 502009CA040800)OCOEMB/Division AG Order on Epstein's Motion to Continue Hearing on Edwards' Renewed Motion for S

SE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

12, vlt i 6c, Az..se.kc Ay -A- en InetA ep —2 o /2. else- g e • EFTA00708802 Epstein v. Rothstein and Edwards Case No. 502009CA040800)OCOEMB/Division AG Order on Epstein's Motion to Continue Hearing on Edwards' Renewed Motion for Summary Judgment Page 2 of 2 DONE AND ORDERED in Chambers at West Pa

EFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER TO POSTPONE DEPOSITION OF PLAINTIFF THIS MATTER came before the Court upon Plaintiff/Counter-Defendant JEFFREY EPSTEIN's Motion for Protective Order to Postpone Deposition of Plaintiff in the above-styled case. Tis Court having reviewed the Motion, having heard argumen

tiedn-t -Aloft 72,c,_ ‹- Act-& _et. e-14 der :Jet, oi „ 0 - Joel „a(' -7--(72t 2 afrn 4)A...c.c. 1.0 citi.c. erCri .00 EFTA00616109 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Division AG Order on Epstein's Motion for Protective Order Page 2 of 2 DONE AND QRDERED in

E NO. 502009CA040800XXX'XMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

- Joel „a(' -7--(72t 2 afrn 4)A...c.c. 1.0 citi.c. erCri .00 EFTA00616109 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Division AG Order on Epstein's Motion for Protective Order Page 2 of 2 DONE AND QRDERED in Chambers in West Palm Beach, Palm Beach C Florida this / day o