Epstein Secrets

OTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. / DRAFT 4/26/11 PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S AMENDED MOTION FOR A PROTECTIVE ORDER TO PRECLUDE OPPOSING COUNSEL AND DEFENDANT/COUNTER-PLAINTIFF FROM MAKING EXTRAJUDICIAL STATEMENTS AND COMMEN

EXTRAJUDICIAL STATEMENTS AND COMMENTARY TO THE MEDIA AND PRESS, WITH INCORPORATED LEGAL AUTHORITIES Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.280(c) of the Florida Rules of Civil Procedure, files this Amended Motion for a Pr

CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1

n the justified prosecution of his claims against Mr. Epstein"; and 2) "This constitutes a very substantial cl

e," as he has done. (See Exhibit 10). By using the epithet in open court, it becomes part of the public record and fodder for the media. Pursuant to Fla. R. Evid. 404, Mr. Scarola could not use such an epithet during the trial or introduce evidence to support the disparaging characterizations 24. The extra

SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, ead-laiadividually3 Defendants. DRAFT 4/26/11 PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S AMENDED MOTION FOR A PROTECTIVE ORDER TO PRECLUDE OPPOSING COUNSEL AND DEFENDANT/COUNTER-PLAINTIFF FROM MAKING EXTRAJUDICIAL STATEMENTS AND COMMEN

EXTRAJUDICIAL STATEMENTS AND COMMENTARY TO THE MEDIA AND PRESS, WITH INCORPORATED LEGAL AUTHORITIES Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.280(c) of the Florida Rules of Civil Procedure, files this Amended Motion for a Pr

CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1

n the justified prosecution of his claims against Mr. Epstein"; and 2) "This constitutes a very substantial cl

e," as he has done. (See Exhibit 10). By using the epithet in open court, it becomes part of the public record and fodder for the media. Pursuant to Fla. R. Evid. 404, Mr. Scarola could not use such an epithet during the trial or introduce evidence to support the disparaging characterizations 24. The extra

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

of Edwards' "facts" detail in graphic terms alleged misconduct by Epstein wholly unrelated to the allegations in the instant litigation. Pursuant to Fla. R. Evid. §90.404(1), evidence of other crimes, wrongs or acts is inadmissible when the evidence is introduced solely to prove bad character, or that the pe