Epstein Secrets

vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiff. AFFIDAVIT OF JEFFREY EPSTEIN The undersigned, Jeffrey E. Epstein, having first been duly sworn, hereby deposes and says: 1. I am over eighteen (18) years old and have personal knowledge of the facts stated here

or leave to file the supplemental argument contained herein on the following grounds: 1. The trial judge entered summary final judgment in favor of Epstein on the ground that the litigation privilege bars the malicious prosecution and abuse of process claims filed against Epstein by the appellant, Brad

unrelated to the underlying litigation against me, and (b) asserting my causes of action against Edwards and Rothstein in the Action. FURTHER AFFI JEFFREY EPS STATE OF NEW YORK ) ) ss.: COUNTY OF NEW YORK ) _ - Sworn and subscribed to before me, the undersigned authority, by Jeffrey Epstein, this 25t

e of these potentially explosive facts, putative defendant Epstein had allegedly offered $200,000,000.00 for settle

. 4D14-2282 BRADLEY J. EDWARDS, Appellant, v. JEFFREY EPSTEIN, Appellee. MOTION FOR LEAVE TO FILE SUP

d." Dade Cnty. Sch. Bd. v. Radio Station WQBA, 731 So. 2d 638, 644 (Fla.1999). "This rule applies in cases of summary judgments as well." Landis v. Allstate Ins. Co., 546 So. 2d 1051, 1053 (Fla. 1989); see also Rivernider, supra (holding that although trial judge erred in granting summary judgment based upon the

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

, 48 So. 3d 976 (Fla. 3d DCA 2010) (probative value outweighed by prejudicial effect when evidence improperly becomes focus of trial); Maldonado v. Allstate Ins. Co., 789 So. 2d 464 (Ha. 2d DCA 2001) (probative value of bicyclist's status as an illegal alien was outweighed by unfair prejudice, confusion of the i

F THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: CROW PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S MOTION FOR A PROTECTIVE ORDER Plaintiff/Counter-Defendant Jeffrey

OF LAW IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S MOTION FOR A PROTECTIVE ORDER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, hereby files his Memorandum of Law in Opposition to Defendant/Counter-Plaintiff Bradley Edwards's ("Edwa

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

he onus of supplying the information or documents is inordinate." Topp Telecom, Inc. v. Atkins, 763 So. 2d 1197, 1199 (Fla. 4th DCA 2000). See also Allstate Ins. Co. v. Boecher, 733 So. 2d 993, 994 (Fla.1999) (noting the lack of "affidavits, depositions or other sworn testimony in the record to support Allstate's

nformation from Epstein's criminal case and prior civil cases; not one of which is an abuse of process or malicious prosecution case. 4. Video of Jeffrey Epstein's home and route from victim to Epstein's home 9. Documents related to Jeffrey Epstein produced by Alfredo Rodriguez 11. Jeffrey Epstein phone reco

N LIMINE TO PRECLUDE AT TRIAL THE USE OF THE FOLLOWING ITEMS LISTED ON EDWARDS'S REVISED EXHIBIT LIST Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel moves for an Order in Limine precluding Defendant/Counter- Plaintiff Bradley Edwards ("Edwards") and his C

UNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, JUDGE: D

, 48 So. 3d 976 (Fla. 3d DCA 2010) (probative value outweighed by prejudicial effect when evidence improperly becomes focus of trial); Maldonado v. Allstate Ins. Co., 789 So. 2d 464 (Fla. 2d DCA 2001) (probative value of bicyclist's status as an illegal alien was outweighed by unfair prejudice, confusion of the

THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO STAY PROCEEDINGS OR ALTERNATIVE MOTION TO CONTINUE THE TRIAL DATE SET IN THIS MATTER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epste

EIN'S MOTION TO STAY PROCEEDINGS OR ALTERNATIVE MOTION TO CONTINUE THE TRIAL DATE SET IN THIS MATTER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 9.310 of the Florida Rules of Appellate Procedure, hereby requests that this Court s

JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, indiv

r the circuit courts not to interfere with the jurisdiction of the courts of appeal when issues are then pending before them." Id. at 983. See also Allstate Ins. Co. v. Titusville Total Health Care, 848 So. 2d 1166, 1167 (Fla. 5th DCA 2003) ("Courts have often held that it is appropriate for one court to stay an

HE 15th JUDICIAL CIRCUIT 5/1/118:14 PM IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN. Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF'S MOTION TO OUASH SUBPOENA AND FOR PRO

009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN. Plaintiff, v. SCOTT ROTHSTEIN, individually a

NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN. Plaintiff, v. SCOTT ROTHSTEIN, indivi

are reasonably calculated to lead to the discovery of admissible evidence in the case in which the discovery is sought. Fla. R. Civ. P. 1.280(b)(1); Allstate Ins. Co. v. Langston, 655 So. 2d 91, 94 (Fla. 1995). 10. "Pretrial discovery was implemented to simplify the issues in a case, to eliminate the element of

JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408007OOOCMBAG JUDGE: HAFELE Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RENEWED MOTION TO STAY PROCEEDINGS OR ALTERNATIVE MOTION TO CONTINUE THE TRIAL DATE SET IN THIS MATTER Plaintiff/Counter-Defendant Jeffrey Epstein

NEWED MOTION TO STAY PROCEEDINGS OR ALTERNATIVE MOTION TO CONTINUE THE TRIAL DATE SET IN THIS MATTER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 9.310 of the Florida Rules of Appellate Procedure, hereby requests that this Court s

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

r the circuit courts not to interfere with the jurisdiction of the courts of appeal when issues are then pending before them." Id. at 983. See also Allstate Ins. Co. v. Titusville Total Health Care, 848 So. 2d 1166, 1167 (Fla. 5th DCA 2003) ("Courts have often held that it is appropriate for one court to stay an