Epstein Secrets

efendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO EDWARDS' MOTION FOR SANCTIONS FOR VIOLATION OF COURT ORDER AND THE INTERVENORS' JOINDER Plaintiff/Counter-Defendant Jeff

OPPOSITION TO EDWARDS' MOTION FOR SANCTIONS FOR VIOLATION OF COURT ORDER AND THE INTERVENORS' JOINDER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") responds in opposition to Counter- Plaintiff Bradley J. Edwards' ("Edwards") April 3, 2018, Motion for Sanctions for Violation of Court Order', an

Berard Rockenbach (FBN Rachel J. Glasser (FBN Primary: Primary: Primary: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant Jay Epstein 13 EFTA00808684 SERVICE LIST Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, . 2139 Palm Beach

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

en into consideration is the appellate rights of Mr. Epstein and how they're going to preserve those rights i

Fourth District Court of Appeal. Obviously, however, Epstein's general references to documents could not possibly have violated the Court's ruling. Edwards' Motion is just another attempt to derail an in camera review of 'A written Order has not been issued on the Court's March 8, 2018, rulings. EFTA00808672

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 EDWARDS' MOTION FOR PROTECTIVE ORDER RELATING TO =.'S DEPOSITION AND MOTION TO COMPE

O COMPEL M. TO ANSWER OUESTIONS RELATING TO THE CRIMES VICTIMS' RIGHTS ACT AND TO REOPEN DEPOSITION Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), responds in opposition to the Motion for Protective Order [D.E. 1026] filed by Defendant/Counter-Plaintiff, Bradley Edwards ("Edwards"), relatin

ction was to, among other things, force Edwards to abandon his efforts to set aside the NPA through the CVRA action: 10 And we intend to prove that Jeffrey 11 Epstein's motive in filing these knowingly 12 false claims against Brad Edwards - his 13 motive was to extort Bradley Edwards into 14 abandoni

agreement. (11/29/17 Tr. 106:10-18, e.s.) 3 And Mr. Epstein clearly knows that 4 Mr. Edwards is lead counsel

d the NPA and there was no legitimate purpose for them to make the agreement public. Furthermore, the CVRA court had recently (February 2009) denied Edwards' Motion to Unseal the NPA in that action. (Jane Doe v. U.S., Case No. 08-CV-80736, D.E. 36.) Edwards wants the Court to believe, however, that Epstein's mo

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 EDWARDS' MOTION FOR LEAVE TO PROPOUND LIMITED REOUESTS FOR ADMISSION Plaintiff/Coun

DANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' MOTION FOR LEAVE TO PROPOUND LIMITED REOUESTS FOR ADMISSION Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), responds in opposition to the Motion for Leave to Propound Limited Requests for Admission dated December 1, 2017 [D.E. 1098] filed by Defendant/

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

Co-Counsel for Plaintiff/Counter-Defendant Jea•ey Epstein Marc S. Nurik Law Offices of Marc S. Nurik One

cutoff date" and Edwards objected "to any effort to expand existing deadlines." Id. On November 27, 2017, the Court agreed with Edwards and granted Edwards' Motion finding that, "to the extent that wholesale additional discovery will not be permitted but individual discovery requests may be allowed on a matter

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

very 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 the issues in the pleadings resolved before addressing discove

ockenbach FBN Rachel J. Glasser Primary: Primary: Primary: Seconda Seconda Seconda Trial & Appellate Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein 23 EFTA00793715 CERTIFICATE OF TYPE SIZE & STYLE I certify that the type, size, and style utilized in this Petition is 14-point Times New Roman

cing investors he had negotiated multi-million settlements in high-profile cases. Three of Edwards' clients at the time alleged tort claims against Epstein, which Epstein ultimately settled. Based on publicly available information about 3 All background information is derived from the complaints and Jo

Case No.: LT Case No: 502009CA0408003OOOCMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHST

nday, March 5, 2018, Epstein filed his to motion to remove the case from trial docket in order to comply with the mandate of Rule 1.440 and opposed Edwards' Motion for Pursuant to the clear language of the rule, if the action involves a main claim or counterclaim which has neither been answered nor defaulted,

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

aint. Significant to this case and Epstein having probable cause to continue with this suit against Edwards was Judge Crow's finding when he denied Edwards' Motion to Dismiss Epstein's Second Amended Complaint. Edwards' Motion to Dismiss asserted the litigation privilege as an absolute bar to Epstein's cause of

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 EDWARDS' MOTION FOR LEAVE TO PROPOUND LIMITED REOUESTS FOR ADMISSION Plaintiff/Coun

DANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' MOTION FOR LEAVE TO PROPOUND LIMITED REOUESTS FOR ADMISSION Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), responds in opposition to the Motion for Leave to Propound Limited Requests for Admission dated December 1, 2017 [D.E. 1098] filed by Defendant/

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

t to avoid the Florida Evidence Code by propounding the tardy discovery requests should be rejected. CONCLUSION Epstein respectfully requests that Edwards' Motion be denied. Edwards asked for confirmation of the pretrial deadlines and must be held to that request. There was no court ruling "on motions current

205 North Dixie Highway, West Palm Beach, FL 33401 in Courtroom 10-C at which time the following matters will be heard: Plaintiff/Counter-Defendant Jeffrey Epstein's Motion for Temporary Stay of Proceedings; Response in Opposition to Plaintiff/Counter-Defendant Jeffrey Epstein's Motion for Temporary Stay of Proc

in's Motion for Temporary Stay of Proceedings; Plaintiff/Counter-Defendant Jeffrey Epstein's Omnibus Motion in Limine; EFTA00595673 EDWARDS ADV. EPSTEIN Case No.: S02009CA040800XXXXMBAG Order Specially Setting Hearing Response in Opposition to Jeffrey Epstein's Omnibus Motion in Limine; Edwards' M

OUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, in

V. EPSTEIN Case No.: S02009CA040800XXXXMBAG Order Specially Setting Hearing Response in Opposition to Jeffrey Epstein's Omnibus Motion in Limine; Edwards' Motion in Limine to Strike the June 30, 2017 Affidavit of Jeffrey Epstein and to Exclude Evidence as to which Discovery was withheld under Claims of Privil