Epstein Secrets

Epstein, Tyler McDonald, Tyler McDonald D/B/A/ YLORG Case No.: 14-21348 CA 01 Dear Judge Smith: Please find enclosed a courtesy copy of Defendant, Jeffrey Epstein's, Response to Motion for Ruling on Service of Process on Defendant, Jeffrey Epstein without a Hearing. Because the Plaintiffs attorney, Mr. Titone,

ion for Ruling on Service of Process Defendant, Jeffrey Epstein, filed his Memorandum in Opposition to Motion for Ruling on Service of Process. Mr. Epstein maintains his prior positions with regard to Plaintiffs failure to properly serve him in what is now 2 years and 10 months after the filing of Plain

that failed attempt. 3. The undersigned counsel promptly fded a motion to quash on behalf of Mr. Epstein in April 2015, which motion included Mr. Bpstoin's affidavit confirming the location of his residence and usual place of abode in the United States Virgin Islands. 4. Plaintiffs waited a full yea

dividually and MCI Model & Talent Miami, LLC vs. Jeffrey Epstein, Tyler McDonald, Tyler McDonald D/B/A/ YL

tion to Motion for Ruling on Service of Process. Mr. Epstein maintains his prior positions with regard to Plai

frey Epstein case. From my review it is clear that once again the attempt to serve runs afoul of Florida Statutes 48.031, as well as the holding in the Third District in HAUSER VS. SCHIFF, I have attached a copy of that case for your ready reference. It is now almost two years past the January 2015 filing date of

IN THE COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA037319XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendants. EPSTEIN'S RESPONSE IN OPPOSITION TO MOTION FOR LEAVE TO ADD A CLAIM FOR PUNITIVE DAMAGES Defendant, Jeffrey Epstein ("Epstein"), su

FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502008CA037319XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendants. EPSTEIN'S RESPONSE IN OPPOSITION TO MOTION FOR LEAVE TO ADD A CLAIM FOR PUNITIVE DAMAGES Defendant, Jeffrey Epstein ("Epstein"), submits this Response in

inconceivable what relevance Ms. deposition has to claim for punitive damages if she has no knowledge of her. In addition, Ms. testified that: a. Epstein never used physical force or coercion, nor made any threats against her. Id. at 252-53; b. She was never afraid or concerned for her safety. Id: c

CASE NO. 502008CA037319XXXXMB AB Plaintiff, v. JEFFREY EPSTEIN, Defendants. EPSTEIN'S RESPONSE IN OPPO

the amendment at all, based on the facts, even if they were undisputed ... I'm only allowing it in a fraud count and I'm only allowing it because the Third District says that I must. Id. (Emphasis in original). 22. In reversing the trial court, the Third District Court of Appeal noted that "the trial court's

lvd. Suite 1200 West Palm Beach, FL 33401 Re: Jeffrey Epstein v. Scott Rothstein and Bradley J. Edwards

nse to your November 27, 2018, e- mail to outline Mr. Epstein's potential claims relating to Fowler White's rep

i, FL 33131-2113 November 29, 2018 Via E-Mail Joseph lanno, Jr. Carlton Fields 525 Okeechobee Blvd. Suite 1200 West Palm Beach, FL 33401 Re: Jeffrey Epstein v. Scott Rothstein and Bradley J. Edwards 15'h Judicial Circuit Case No. 50-2009-CA-040800XXXXMBAG In re Rothstein Rosenfeldt Adler, P.A. U.S. Ban

9-34791-RBR Dear Niall and Joe: I am writing on behalf of my client, Jeffrey Epstein, in response to your November 27, 2018, e- mail to outline Mr. Epstein's potential claims relating to Fowler White's representation of him in the above-referenced matters during the period of June 2010 through May 2012.

res, Inc. v. Berlowitz, 211 So. 3d 259, 263 (Fla. 4th DCA 2017). Even when a release pertains to claims the parties ever had, now have or can have, the Third District found it would only encompass claims that had matured at the time of signing the release. SoUile v. Gaines Const. Co., 281 So. 558, 560-61 (Ha. 3d D

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

did not have to respond to questioning regarding the initial conversation that took place between Diaz and him. On petition for writ of certiorari, the Third District concluded that the trial court had departed from the essential requirements of the law by directing that Rabin need not respond to questions about w

FL 33060 Re: Service of Process Dear Joe: I have had an opportunity to review the Notice Service of Process that you filed in the Jean Luc Brunel/Jeffrey Epstein case. From my careful review it is clear that once again the attempt to serve runs afoul of Florida Statutes 48.031, as well as the holding in the

of that case for your ready reference. It is now almost two years past the January 2015 filing date of your clients' amended complaint joining Mr. Epstein as a defendant to the original action filed in August 2014. I remind you that no attempt was made to even serve Mr. Epstein until March 10, 2015. I

of Process that you filed in the Jean Luc Brunel/Jeffrey Epstein case. From my careful review it is clear

date of your clients' amended complaint joining Mr. Epstein as a defendant to the original action filed in A

tein case. From my careful review it is clear that once again the attempt to serve runs afoul of Florida Statutes 48.031, as well as the holding in the Third District in HAUSER VS. SCHIFF. I have attached a copy of that case for your ready reference. It is now almost two years past the January 2015 filing date of

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, -VS- SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiffs. RESPONSE IN

in Opposition to Plaintiff/Counter-Defendant's Motion for Fees and Costs, and as grounds therefor would state: INTRODUCTION This case arises from Epstein's lawsuit against Edwards, when Epstein sued Edwards merely for his legal representation of people accusing Epstein of misconduct. Edwards counter-

COUNTY, FLORIDA. CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, -VS- SCOT

e, even though Epstein is a non-lawyer. This Court dismissed Edwards' lawsuit, concluding it was bound under case precedent from a single case from the Third District to apply the litigation privilege. Epstein seeks attorneys' fees pursuant to his Proposal for Settlement served in 2011. Over Edwards objection, I

PLAINTIFF/COUNTER-DEFENDANT'S RESPONSE IN OPPOSITION TO: DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' MOTION TO STRIKE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT ON THE FOURTH AMENDED COUNTERCLAIM AND SUPPORTINGMEMORANDUM OF LAW Plaintiff/Counter-Defendant Jeffrey Epstein respect

49 Introduction Edwards' motion to strike is based solely upon his argument that this Court's consideration of the probable cause issue raised in Epstein's motion for summary judgment is barred by the law of the case doctrine. Edwards argues that the probable cause issue was raised by Epstein as a po

IRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. BRADL

Gabor & Co., Inc., 599 So. 2d 737 (Fla. 3d DCA 1992) "is directly on point." Motion to Strike at 5. Gabor is clearly distinguishable. In that case, the Third District held that, based upon law of the case, "it was error for the trial court to enter summary judgment on a point previously determined [on appeal] not

istrict of Florida (the "Federal Action") more than eight years ago. In the Federal Action, Edwards and Cassell represent certain alleged victims of Jeffrey Epstein, a client of Dershowitz's, who contend that the Government violated their rights under the Crime Victims Rights Act (the "CVRA"). Specifically, the

the Government violated their rights under the CVRA by failing to consult with them before negotiating a non-prosecution agreement (the "NPA") with Epstein, who allegedly subjected them to various sexual crimes when they were minors. On December 30, 2014 — more than eight years after the Federal Action

and Cassell represent certain alleged victims of Jeffrey Epstein, a client of Dershowitz's, who contend t

tain information that had no "possible relevance" to the issues in dispute. For example, in Calvo v. Calvo, 489 So. 2d 833, 834 (Fla. 3d DCA 1986), the Third District held that an ex-wife's financial records had no "possible relevance" to her post-judgment action seeking to compel payments that the ex-husband owed

and Cassell represent certain alleged victims of Jeffrey Epstein, a client of Dershowitz's, who contend t

istrict of Florida (the "Federal Action") more than eight years ago. In the Federal Action, Edwards and Cassell represent certain alleged victims of Jeffrey Epstein, a client of Dershowitz's, who contend that the Government violated their rights under the Crime Victims Rights Act (the "CVRA"). Specifically, the

the Government violated their rights under the CVRA by failing to consult with them before negotiating a non-prosecution agreement (the "NPA") with Epstein, who allegedly subjected them to various sexual crimes when they were minors. On December 30, 2014 — more than eight years after the Federal Action

tain information that had no "possible relevance" to the issues in dispute. For example, in Calvo v. Calvo, 489 So. 2d 833, 834 (Fla. 3d DCA 1986), the Third District held that an ex-wife's financial records had no "possible relevance" to her post-judgment action seeking to compel payments that the ex-husband owed

defendant-appellant Miguel Plascencia-Alvarado. Jeffrey E. Ellis, Law Offices of Ellis, Holmes & Witchley,

defendant-appellant Miguel Plascencia-Alvarado. Jeffrey E. Ellis, Law Offices of Ellis, Holmes & Witchley,

the Southern District of New York restraining, pending final hearing, the defendant McElligott, Acting and Deputy Collector of Internal Revenue of the Third District of New York, from refusing to issue licenses to the complainants as brewers of beer, or to issue revenue stamps in respect to their beer, provided