Epstein Secrets

ter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO STRIKE DEFENDANT/COUNTER-PLAINTIFF'S DAMAGES EXPERT WITNESS, DR. BERNARD JANSEN. AND TO EXCLUDE HIS TESTIMONY Plaintiff/Counter-Defendan

FENDANT/COUNTER-PLAINTIFF'S DAMAGES EXPERT WITNESS, DR. BERNARD JANSEN. AND TO EXCLUDE HIS TESTIMONY Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), moves to strike the expert witness and to exclude the admission of any testimony from Defendant/Counter-Plaintiff, Bradley J. Edwards' ("Edwards

UNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

which he believes was "successful in discrediting Mr. Epstein's charges." (Jansen's 12/1/17 Tr. 62.) (Ex. E.)

ies of Mr. Scott Rothstein as a result of Mr. Jef•ey Epstein's lawsuit against Mr. Edwards have been dissemin

alse statement of fact is absolutely necessary if there is to be recovery in a defamation action."'). Fid. Warranty Services, Inc. v. Firstate Ins. Holdings, Inc., 74 So. 3d 506, 515 (Fla. 4th DCA 2011) ("A party cannot recover for defamation based on statements which are pure opinion."). Consistent with Edwa

l activity without physical force. These opinions may also assist a jury in assessing evidence that some alleged victims repeatedly interacted with Jeffrey Epstein, seemingly voluntarily, even after they suffered abuse. Dr. Rocchio's fourth opinion is similarly relevant to the charges that require proving inten

leged victims repeatedly interacted with Jeffrey Epstein, seemingly voluntarily, even after they suffered

some alleged victims repeatedly interacted with Jeffrey Epstein, seemingly voluntarily, even after they s

with their own `common knowledge and common sense,' no expert testimony is warranted." Edmondson v. RCI Hosp. 7 EFTA00016477 --- PAGE BREAK --- Holdings, Inc., No. 16-CV-2242 (VEC), 2020 WL 1503452, at *6 (S.D.N.Y. Mar. 30, 2020) (quoting 4 Weinstein's Federal Evidence § 702.03 (2019)); see also United Sta

l activity without physical force. These opinions may also assist a jury in assessing evidence that some alleged victims repeatedly interacted with Jeffrey Epstein, seemingly voluntarily, even after they suffered abuse. Dr. Rocchio's fourth opinion is similarly relevant to the charges that require proving inten

leged victims repeatedly interacted with Jeffrey Epstein, seemingly voluntarily, even after they suffered

some alleged victims repeatedly interacted with Jeffrey Epstein, seemingly voluntarily, even after they s

he jury could reach with their own `common knowledge and common sense,' no expert testimony is warranted." Edmondson v. RCI Hosp. 7 EFTA00040113 Holdings, Inc., No. 16-CV-2242 (VEC), 2020 WL 1503452, at *6 (S.D.N.Y. Mar. 30, 2020) (quoting 4 Weinstein's Federal Evidence § 702.03 (2019)); see also United Sta

l activity without physical force. These opinions may also assist a jury in assessing evidence that some alleged victims repeatedly interacted with Jeffrey Epstein, seemingly voluntarily, even after they suffered abuse. Dr. Rocchio's fourth opinion is similarly relevant to the charges that require proving inten

leged victims repeatedly interacted with Jeffrey Epstein, seemingly voluntarily, even after they suffered

some alleged victims repeatedly interacted with Jeffrey Epstein, seemingly voluntarily, even after they s

he jury could reach with their own `common knowledge and common sense,' no expert testimony is warranted." Edmondson v. RCI Hosp. 7 EFTA00094659 Holdings, Inc., No. 16-CV-2242 (VEC), 2020 WL 1503452, at *6 (S.D.N.Y. Mar. 30, 2020) (quoting 4 Weinstein's Federal Evidence § 702.03 (2019)); see also United Sta

LDERS ARE REQUIRED TO SIGN BELOW: IF SIGNATURES ARE ON BEHALF OF ENTITY ACCOUNTHOLDER. PLEASE SPECIFY NAME OF ENTITY: DI . ..------ ??/// i 27 Jeffrey Epstein, President Si tart ( unilyldet) Date Rini Nan, C> Steamy (AJJatonal Ace:mit:NO Dale Pnnt Name C> Signature (AddtOonal Accouttlia) Dale P

OF ENTITY: DI . ..------ ??/// i 27 Jeffrey Epstein, President Si tart ( unilyldet) Date Rini Na

FY NAME OF ENTITY: DI . ..------ ??/// i 27 Jeffrey Epstein, President Si tart ( unilyldet) Date

The Morgan Account Application: Signature Page JP Morgan J.P. MORGAN USE ONLY VS007 2:99 Title ASK' Holdings, Inc. SPN ACCOuPtS Opead la ASSET O PAAS la BROKERAGE O 00A O MMIA O MARGIN O 1 M THIS APPLICATION MUST BE COMPLETED BEFORE J.P. MORGAN WILL BE