Epstein Secrets

t within his law firm and his client, that being Mr. Epstein. When further asked by the court, has Mr. Epstein

-RBR Doc 6482 Filed 10/19/18 Page 4 of 97 COURT: I disagree with you. .... Take that up in your state court litigation. (Apr. Tr. 43:19-45:6.) B. Epstein has Provided Sworn Testimony and His Attendance at the Show Cause Hearing is Not Necessary. The Court allowed Movants to take Epstein's deposition

bove cause, testified on his oath as follows: THE WITNESS: Yes. DIRECT EXAMINATION BY MR. SCAROLA: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each of your residence addresses? MR. GOLDBERGER: I think it's beyond the scope. I'm going to object to Fifth

ief Expedited Hearing Requested on or before October 24, 2018, so that the Court may rule prior to the October 26, 2018, hearing) Jeffrey Epstein ("Epstein") moves the Court, on an expedited basis, to be excused from attending the October 26, 2018, show cause hearing, and states: INTRODUCTION On April

n the United States Virgin Islands, August /‘(2018. I declare under penalty of perjury that the foregoing is true and correct. APPROV FORM: RNEY REY EPSTEIN EFTA00793497

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

1555 Palm West Palm October 13th, 2018 - 11:00 a.m. Beach Lakes Boulevard, #930 Beach, Florida 33401 Examination of the witness taken before Sonja D. Hall Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 Palm Beach Reporting Service, Inc. 561-471-

bove cause, testified on his oath as follows: THE WITNESS: Yes. DIRECT EXAMINATION BY MR. SCAROLA: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each of your residence addresses? MR. GOLDBERGER: I think it's beyond the scope. I'm going to object to Fifth

wed to intervene in this action, now respectfully submits this Motion to Compel Jeffrey Epstein to Provide Answers to Deposition Questions. Because Epstein has improperly refused to answer multiple questions at his recent deposition, the motion should be granted. Relevant Factual Background The facts

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

A: Q Would you please state your full name? A Jeffrey E. Epstein. Q Would you list for us, please, each

he Agreed Order." DE 6366 at 5 (citing DE 1194). Mr. Epstein improperly refused to answer many questions about

1555 Palm West Palm October 13th, 2018 - 11:00 a.m. Beach Lakes Boulevard, #930 Beach, Florida 33401 Examination of the witness taken before Sonja D. Hall Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 Palm Beach Reporting Service, Inc. 561-471

HE COURT: Let's go ahead and proceed with the substance of the motion and we will go from there, please. MS. HADDAD COLEMAN: Good morning, Judge. Jeffrey Epstein's motion for summary judgment is based on a very simple issue that was not addressed by this Court in a Palm Beach Reporting Service, Inc. 561-471-2

12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: We have various motions on the Edwards counterclaim that was brought against Mr. Epstein relative to the remaining count of malicious prosecution. I have read as much as the materials that someone can sit down and read for the better

id, I would like to begin with Plaintiff/Counter-Defendant Epstein's motion for summary judgment on Defendant/ Cou

H COUNTY, FLORIDA Case No. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, indiv

he Edwards counterclaim that was brought against Mr. Epstein relative to the remaining count of malicious pro

afele, Presiding Judge This cause came on to be heard at the time and place aforesaid, when and where the following proceedings were reported by: Sonja D. Hall Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 (561) 471-2995 Palm Beach Reporting Servi

3 i 2 3 THE COURT: Good morning. Have a seat. Thank you. Needless co say the recent barrage, as 3 4 opposed to flurry, of activity that has JEFFREY EPSTEIN, S transpired is of extreme consternation to Plaintiff/Counter-Defendant, vs. 4 the court. It has caused me to have to SCOTT ROTHSTEIN, indivi

ck. So I look forward to discussing the privileged nature of the documents. And I thank Hr. Cassell for being here today. Your Honor, this is Mr. Epstein's motion to remove this case from the trial docket. It was prompted by Mr. Edwards' motion to separate the trials, which was motion -- for the ob

31:18,19 38:16 41:20 57:14 81:8 81:25 84:3 88:20 iteration 36:8,23 73:12 79:4 iterations 43:8 51:9 J 2:6 JACK 2:9,18 JAMES 2:13 Jane 2:12 Jeffrey 1:5 2:16 joined 30:2 joint 10:2044:25 JR 2:10 judge 1:164:14 7:23 8:2,17 9:3 15:19 21:21 29:11 30:1,2,3 36:16 40:14,22,22 41:6 41:17 43:25 4

assell for being here today. Your Honor, this is Mr. Epstein's motion to remove this case from the trial doc

gh the materials, and proceedings wore reported by: 21 I had some assistance, which I appreciate, 22 from ono of our staff attorneys, in trying Sonja D. Hall Palm Beach Reporting service, Inc. 13 to simply wade through the extensive, 1665 Palm Beach Lakes Boulevard, Suite 1001 24 complicated, and in ma

Have you over pied any allegations, Mr. Berger, that turned out to be untrue. down the lino? 1 4 S 147 Epstein? A It's patently [also that Jeffrey Epstein wan not Intel injured by anything that Brad Edwards did or if -- I don't deny that there wan a 0042l scheme that used the three cases we had as bait.

Boulevard, Suite 1001 $ 9:27 West Palm Beach, FL 33401 4 This is the videotaped deposition of 4 1561) 471-2995 5 Berger in the matter of Jeffrey 5 APPEARANCES: 6 For Plaintiff: 4 Epstein versus Scott Rothstein and Bradley 7 LINK 4 ROCKENBACH, . Edwards. 1555 Palm Beach Lakes Boulevar

, FL 33401 4 This is the videotaped deposition of 4 1561) 471-2995 5 Berger in the matter of Jeffrey 5 APPEARANCES: 6 For Plaintiff: 4 Epstein versus Scott Rothstein and Bradley 7 LINK 4 ROCKENBACH, . Edwards. 1555 Palm Beach Lakes Boulevard, Suite 301 0 9 West Palm Beach, FL 33401 B

th Florida. He had a case -- ho had cases against Mr. Epstein. Or he had clients -- I don't know if he actuall

were tacked.) Boca Raton, Florida 33431 13 24 25 2 4 1 Examination of the witness taken before 1 THE VIDEOGRAPHER: This is the 23rd day 2 Sonja D. Hall 2 of February 2028. The time is approximately Palm Beach Reporting Service, Inc. 9 1665 Palm Beach Lakes Boulevard, Suite 1001 $ 9:27 West Pa

ter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER AND IN LIMINE OF UNRELATED SETTLEMENTS Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), moves for a protectiv

NTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER AND IN LIMINE OF UNRELATED SETTLEMENTS Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), moves for a protective order pursuant to Florida Rule of Civil Procedure 1.280(c) on the production and disclosure of any additional confidentia

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

And again, the degree of financial exposure that Mr. Epstein was facing is reflected by the settlements of al

afele, Presiding Judge This cause came on to be heard at the time and place aforesaid, when and where the following proceedings were reported by: Sonja D. Hall Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 (561) 471-2995 Palm Beach Reporting Servi

flsb.uscourts.gov IN RE: CASE NO.: 09-34791-RBR ROTHSTEIN ROSENFELDT ADLER, P.A., CHAPTER 11 Debtor. BRADLEY EDWARDS' RESPONSE IN OPPOSITION TO JEFFREY EPSTEIN'S EXPEDITED MOTION TO BE EXCUSED FROM ATTENDING SHOW CAUSE HEARING AND SUPPLEMENT THERETO Bradley J. Edwards ("Edwards"), by and through undersigned

hearing on October 23, 2018 and states as follows: The Disc Did Not Sit in a Box Contrary to what has been repeatedly stated by Jeffrey Epstein ("Epstein") and Fowler White, the disc that Fowler White retained in violation of this Court's November 30, 2010 Agreed Order did not "sit in a box" for the

btor. BRADLEY EDWARDS' RESPONSE IN OPPOSITION TO JEFFREY EPSTEIN'S EXPEDITED MOTION TO BE EXCUSED FROM AT

LINK: You are not going to answer that question, Mr. Epstein. BY MR. SCAROLA: Q Were you told at the time t

r 13th, 2018 9:07 a.m. - 11:00 a.m. 1555 Palm Beach Lakes Boulevard, #930 West Palm Beach, Florida 33401 Examination of the witness taken before Sonja D. Hall Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 (561) 471-2995 EXHIBIT Palm Beach Report

r. Scarola 57 Certificate of Oath 62 Certificate of Reporter 63 Read & Sign Letter to Witness 64 EXHIBIT INDEX No. Description Page No 1 Jeffrey Epstein's Sworn Declaration 13 5 Bankruptcy Court Order 34 (Exhibits 2-4 are incorporated in the prior deposition, as agreed by Counsel.) Palm Beach Rep

ehalf of Jeffrey Epstein. MR. IANNO: Joseph Ianno, Carlton Fields on behalf of Fowler White. MR. GOLDBERGER: And Jack Goldberger on behalf of Mr. Epstein. MR. CASSELL: Paul Cassell, an attorney in Utah on behalf of L.M., E.W. and Jane Doe. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA0079360

to L.M. on that CD? MR. GOLDBERGER: I'm going to instruct Mr. Epstein to invoke his Fifth Amendment privileges as to that question, Mr. Cassell. Jeffrey, just say Fifth. THE WITNESS: Fifth. BY MR. CASSELL: Q When did you first learn about information regarding L.M. on that CD? A Sorry. The ques

MR. GOLDBERGER: And Jack Goldberger on behalf of Mr. Epstein. MR. CASSELL: Paul Cassell, an attorney in Utah

ge 102 of 165 2 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Examination of the witness taken before Sonja D. Hall Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 (561) 471-2995 APPEARANCES: For Jeffrey

Are you aware of strong reservations having been expressed by Gary Farmer to turning over the discs containing potentially privileged materials to Jeffrey Epstein's legal counsel. MR. IANNO: You're asking if he was aware then or based on reading this? BY MR. SCAROLA: Q Are you aware, as you sit here today, t

Farmer Jaffe. MR. IANNO: Joseph Ianno, Carlton Fields, on behalf of Fowler White. MR. LINK: Scott Link and let Jennifer Lettman on behalf of Mr. Epstein. Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00803635 5 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 2

EFTA00803632 L 1 2 3 4 APPEARANCES: For Jeffrey Epstein: LINK & ROCKENBACH, P.A. 1555 Palm Beac

Scott Link and let Jennifer Lettman on behalf of Mr. Epstein. Palm Beach Reporting Service, Inc. 561-471-2995

October 19th, 2018 10:05 a.m. - 2:29 p.m. 525 Okeechobee Boulevard, Suite 1200 West Palm Beach, FL 33401 Examination of the witness taken before Sonja D. Hall Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 (561) 471-2995 Palm Beach Reporting Servi

rivilege is very clearly defined in Florida Rule of Civil Procedure 1.280(b)(3). And, Your Honor, that is quoted in the response in opposition to Jeffrey Epstein's motion to overrule objections and compel answers to these questions. It is quoted in its entirety at page two of our response. And it says that a

urt is aware, the only thing pending at this point in time in the case is Mr. Edwards' claim of abuse of process malicious prosecution against Mr. Epstein. The abuse of process claim has been disposed of. It was successfully won on the summary judgment and is no longer an issue. So the only operativ

H COUNTY, FLORIDA Case No. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, indiv

f abuse of process malicious prosecution against Mr. Epstein. The abuse of process claim has been disposed o

afele, Presiding Judge This cause came on to be heard at the time and place aforesaid, when and where the following proceedings were reported by: Sonja D. Hall Palm Beach Reporting Service, Inc. 1665 Palm Beach Lakes Boulevard, Suite 1001 West Palm Beach, FL 33401 Palm Beach Reporting Service, Inc. EFTA00