Epstein Secrets

y Lefkowitz in Support of Their Motion for a Protective Order Concerning Production, Use, and Disclosure of Plea Negotiations (Doc. 161); Intervenor Jeffrey Epstein's 3 EFTA00177813 A. The Applicability of Rule 410. Any assessment of the merits of the intervenors' contentions must begin with an understanding

tion agreement" ("the agreement") between the United States Attorney's Office for the Southern District of Florida (USAO/SDFL) and Jeffrey Epstein (Epstein) pursuant to the Crime Victims' Rights Act of 2004 (CVRA), 18 U.S.C. §3771. Under the agreement, Epstein agreed to (1) plead guilty to two then pend

the Southern District of Florida (USAO/SDFL) and Jeffrey Epstein (Epstein) pursuant to the Crime Victims'

ould render Rule 410 ambiguous and would violate Mr. Epstein's Fifth Amendment rights. The rule's central fea

ding risk of irreparable harm because "a court cannot restore confidentiality to documents after they are disclosed"); Gill v. Guyitream Park Racing Ass'n, Inc., 399 F.3d 391, 398 (1st Cir. 2005)("once the documents are turned over to Gill with no clear limitation on what he may do with them, the cat is out

THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMBAG JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISQUALIFY TRIAL JUDGE Plaintiff/Counter-Defendant Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorney and

: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISQUALIFY TRIAL JUDGE Plaintiff/Counter-Defendant Jeffrey Epstein (hereinafter "Epstein"), by and through his undersigned attorney and pursuant to Rule 2.330 of the Florida Rules of Judicial Administration and § 38.10 of the Florida St

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

ts that I have 16 reviewed, for example, reflect Mr. Epstein's 17 access to airplanes. See Transcript of Oct

ing is an essential part of justice; and an overspeaking judge is no well tuned cymbal." Great Am. Ins. Co. of New York v. 2000 Island Blvd. Condo. Ass'n, Inc., 153 So. 3d 384, 390 (Fla. 3d DCA 2014) (citations omitted). Florida law mandates recusal of a judge when a litigant establishes a reasonable, well

eving that Bill Clinton was on the airplane with Mr. Epstein and these young woman ..." (18:24-19:4.) • "I c

/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR AN IN CAMERA INSPECTION OF 30 E-MAILS Counter-Defendant, Jeffrey Epstein ("Epstein"), moves' this Court for an in camera inspection of

liver the accompanying sealed Memorandum by November 9, 2018. Edwards was instructed to deliver a response sealed Memorandum by November 16, 2018. 2Epstein has reduced the original 47 e-mails for in camera review down to 30 e-mails. 3Farmer Jaffe agreed to produce all work-product related to closed case

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

ion of legal services to the client. 2. Those reasonably necessary for the transmission of the communication. Las Olas River House Condo. Ass'n, Inc. v. Lorh, LLC, 181 So. 3d 556, 557-58 (Fla. 4th DCA 2015); § 90.502(1Xc), Fla. Stat. (2017); Witte v. Witte, 126 So. 3d 1076 (Fla. 4th DCA 2012)(sec

y Lefkowitz in Support of Their Motion for a Protective Order Concerning Production, Use, and Disclosure of Plea Negotiations (Doc. 161); Intervenor Jeffrey Epstein's Motion for a Protective Order and Opposition to Motions of Jane Doe 1 and Jane Doe 2 for Production, Use, and Disclosure of Plea Negotiations (Doc.

ecutors in the Southern District of Florida made with the specific purpose of obtaining a favorable resolution of the criminal investigation of Mr. Epstein through attorney-to-attorney settlement negotiations. In determining whether to grant a stay pending appeal, the Court is to consider four factors:

rs Roy Black, Martin Weinberg, Jay Lefkowitz, and Jeffrey Epstein hereby request that this Honorable Court

ntinuing exchanges of letters and memos in which Mr. Epstein's counsel addressed the reasons why Mr. Epstein s

ing risk of irreparable harm because "a court cannot restore confidentiality to documents after they are disclosed"); Gill v. Gulfstream Park Racing Ass'n, Inc., 399 F.3d 391, 398 (1st Cir. 2005)("once the documents are turned over to Gill with no clear limitation on what he may do with them, the cat is out

INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the

Agreement ("NPA") with the government in September, 2007. Under that agreement, contrary to the impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor state offenses." Motion at 4. Instead, he pled guilty to two state felony offenses and served a prison

INTRODUCTION AND FACTUAL BACKGROUND Intervenor Jeffrey Epstein entered into a Non-Prosecution Agreement

e impression which the plaintiffs seek to create, Mr. Epstein did far more than plead guilty to "two minor sta

ng risk of irreparable harm because "a court cannot restore confidentiality to documents after they are disclosed"); Gill v. Gulfstreant Park Racing Ass'n, Inc., 399 F.3d 391, 398 (1st Cir. 2005X"once the documents are turned over to Gill with no clear limitation on what he may do with them, the cat is out o

/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LAW ON EDWARDS' WAIVER OF ATTORNEY-CLIENT AND WORK PRODUCT PROTECTIONS Counter-Defendant Jeffrey Epstein ("Epstein"), submits this M

FENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LAW ON EDWARDS' WAIVER OF ATTORNEY-CLIENT AND WORK PRODUCT PROTECTIONS Counter-Defendant Jeffrey Epstein ("Epstein"), submits this Memorandum of Law as to the Doctrines of Waiver of Attorney-Client and Work Product protections as claimed by Edwards and at issue

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

ilege where that disclosure is inconsistent with maintaining secrecy from the disclosing party's adversary." Tumelaire v. Naples Estates Homeowners Ass'n, Inc., 137 So. 3d 596, 599 (Fla. 2d DCA 2014). In Tumelaire, the plaintiff was accused of conspiring with a mobile home park's owner in litigation agains

UIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF'

aintiffs. PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT EDWARDS' RENEWED MOTION FOR SUMMARY JUDGMENT Plaintiff, Jeffrey Epstein ("Plaintiff" or "Epstein"), hereby files the following Response in Opposition to Defendant Bradley J. Edwards' ("Edwards") Renewed Motion for Summary Judgment ("Motion") an

SE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

icated documentary evidence may not be relied on or considered in support of a motion for summary judgment. See, e.g., Hollywood Towers Condominium Ass'n, Inc. v. Hampton, 993 So. 2d 174, 175-176 (Fla. 4th DCA 2008) (unauthenticated photocopies of check, letter and bank statement attached to motion for sum

O DISCLOSE EXPERT WITNESS Plaintiff, Bradley J. Edwards, by and through undersigned counsel, hereby files this Response in Opposition to Defendant Jeffrey Epstein's Renewed Motion for Leave to Disclose Expert Witness, and as grounds therefor states as follows: &nicer Does Not Permit a Party to Ignore Trial Cour

PSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and individually, Defendant, RESPONSE IN OPPOSITION TO EPSTEIN'S RENEWED MOTION FOR LEAVE TO DISCLOSE EXPERT WITNESS Plaintiff, Bradley J. Edwards, by and through undersigned counsel, hereby files this Respons

OUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

expert should not be allowed to testify concerning questions of law." Edward J. Seibert, Architect & Planner, P.A. v. Bayport Beach & Tennis Club Ass'n, Inc., 573 So. 2d 889, 892 (Fla. 2d DCA 1990) citing Devin v. City of Hollywood, 351 So. 2d 1022, 1022 (Fla. 4th DCA 1976). Thus, Smith's purported opinio

s federal civil actions in Florida. Compl. ¶ 8-21, 26-27. Ms. Maxwell was not a party to any of those litigations: not the criminal case against Mr. Epstein (Compl. ¶ 14), any non-prosecution agreement between Mr. Epstein and the U.S. Attorney's Office (Comp1.11 11-13), the litigation concerning the Cri

those litigations: not the criminal case against Mr. Epstein (Compl. ¶ 14), any non-prosecution agreement bet

Winslet, 218 A.D.2d 148, 153 (1st Dep't 1996) 13 Celle v. Filipino Reporter Enters, Inc., 209 F.3d 163 (2d Cir. 2000) 17 Club Valencia Homeowners Ass'n, Inc. v. Valencia Associates, 712 P.2d 1024 (Colo. App. 1985) 13 Cohen v. Stevanovich, 772 F.Supp.2d 416, 423 (S.D.N.Y. 2010) 7 Collier v. Possum Cere

07 (emphasis added). This conclusion underscores the inapplicability of Mohawk in the present circumstances. Quite unlike the Mohawk appellant, Mr. Epstein and the attorney intervenors are not parties to the litigation, having intervened solely for the limited purpose of seeking to prevent the disclosu

ircumstances. Quite unlike the Mohawk appellant, Mr. Epstein and the attorney intervenors are not parties to

Cir. 2007)(Perlman jurisdiction "does not depend on the validity of the appellant's underlying claims for relief'); Gill v. Gulfstream Park Racing Ass'n, Inc., 399 F.3d 391, 398, 402 (1st Cir. 2005)(asserting jurisdiction under Perlman, but concluding that informant privilege was not available to private