Epstein Secrets

I R, 2008 United States Attorney's Office Southern District of Florida 500 South Australian Avenue, Suite 400 West Palm Beach, Florida 33401 Re: Jeffrey Epstein Dear Marie: Fauzintikt: I write in response to your letter dated August 15. 2008 regarding the civil restitution portion of the Deferred Prosecut

lete any of the names on the list provided to Mi..Epstein's counsel, you do not confirm that the prior list

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no.* CRDCOAL STATE or FLORIDA, Plaintiff, vs. JE/OVEY Eft:EYE, Defendant. rrocuormos NEW BEFORE

greement, which resulted in state charges against Mr. Epstein. has caused several miscommunications with respe

e majority resolved the issue by granting a narrow role to privacy based on considerations re- lating to the legitimate expectations of privacy. In the Florida Supreme Court's well-developed pri- vacy jurisprudence, the fundamental basis of the right of privacy is a legitimate expectation of pri- vacy. Not every fact in ev

1 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants. TRANSCRIPT OF HEARING PROCEEDINGS DATE TAKEN: Mon

don't think this has anything whatsoever to do 23 with the matter, but I should let you know that I 24 handled the state claims that involved Mr. Epstein 25 when I was in Division B. So I have a significant www.phippsreporting.com 888 811-3408 EFTA00606512 1 amount of familiarity with the claim

6 35:1443:18,20 27:16 36:745:9,10 1:18 33:5 58:6 www.phippsreporting.com 888 811-3408 EFTA00606578 70 impeachment ... 27:5 3:24 5:11,13 Jeffrey (2) juncture (1) 7:10 influence (1) 7:21 17:20 1:4 6:11 5:24 implicitly (3) 33:1 29:21 31:5 jgoldberger@... jurisdiction (1) 27:22,24 30:2

hat I 24 handled the state claims that involved Mr. Epstein 25 when I was in Division B. So I have a signif

e Olson case, respectfully, that 11 can gather here. So based on the Third District 12 Court's decisions in Wolfe quoting in large part 13 from the Florida Supreme Court's decision in 14 Echevarria, whereas here all of the allegations 15 made in both the abuse of process claim and the 16 malicious prosecution clai

f his clients is the purported victim. Accordingly, I will address facts related to C.W., T.M., and S.R. All three of those clients were victims of Jeffrey Epstein's while they were minors beginning when they were fifteen years old. 'Please note that the dates on the U.S. Attorney's Office letters to C.W. and T.

tates receives a Freedom of Information Act request or any compulsory process commanding the disclosure of the agreement, it will provide notice to Epstein before making that disclosure. (NPA, paragraph 13(emphasis added.) The first sentence of the above quote does no more than state an expectation b

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have signed off and said they will not prosecute Mr. Epstein in the Southern District of Florida for any offe

e majority resolved the issue by granting a narrow role to privacy based on considerations re- lating to the legitimate expectations of privacy. In the Florida Supreme Court's well-developed pri- vacy jurisprudence, the fundamental basis of the right of privacy is a legitimate expectation of pri- vacy. Not every fact in ev

-Plaintiff, Bradley J. Edwards, individually, by and through his undersigned counsel, hereby files this Motion to Strike Plaintiff/Counter-Defendant Jeffrey Epstein's Motion for Summary Judgment on the Fourth Amended Counterclaim and Supporting Memorandum of Law, based on the law of the case doctrine. RELEVANT PR

of Law, based on the law of the case doctrine. RELEVANT PROCEDURAL BACKGROUND In the Fourth Amended Counterclaim, Edwards raised two claims against Epstein: 1) abuse of process and 2) malicious prosecution. As to the malicious prosecution claim, Edwards alleged that the filing of the original complaint

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hat I 24 handled the state claims that involved Mr. Epstein 25 when I was in Division B. So I have a signif

Olson case, respectfully, that I 11 can gather here. So based on the Third District 12 Court's decisions in Wolfe quoting in large part 13 from the Florida Supreme Court's decision in 14 Echevarria, whereas here all of the allegations 15 made in both the abuse of process claim and the 16 malicious prosecution clai

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

efendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY J. EDWARDS' SECOND SUPPLEMENT TO MOTION IN LIMINE ADDRESSING SCOPE OF ADMISSIBLE EVI

FF BRADLEY J. EDWARDS' SECOND SUPPLEMENT TO MOTION IN LIMINE ADDRESSING SCOPE OF ADMISSIBLE EVIDENCE Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), opposes Defendant/Counter- Plaintiff Bradley J. Edwards' ("Edwards") December 11, 2017, Second Supplement to Motion in Limine Addressing Scope of

e Crow ruling that Epstein's Second Amended Complaint properly stated a cause of action for abuse of process. It would be a tortured application of the Florida Supreme Court's Levin decision to allow Edwards to bar Epstein from presenting his defense and constitutes reversible error. CONCLUSION Epstein respectfully reque