Epstein Secrets

roperly captioned them as such on his Response. EFTA00808455 INTRODUCTION Disappointingly, Bradley Edwards ("Edwards") has used his Response to Jeffrey Epstein's ("Epstein") meritorious and well-grounded Petition as yet another vehicle for false and misleading ad hominem attacks against Epstein. Edwards' ina

q. Link & Rockenbach, PA Appellate Counsel for Petitioner 1555 Palm Beach Lakes Blvd. Suite 301 West Palm Beach, Florida 33401 'As set forth in Epstein's Petition, non-parties E.W. and Jane Doe have sought to intervene below on a limited and unrelated issue. As such, they are not parties in this c

. 4D18-0787 LT Case No. 502009CA040800XXXXMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHST

s to obfuscate with his vitriolic narrative about Mr. Epstein's past: (1) that this case was not at issue when

through his last-minute bifurcation gambit was a tactical advantage in presenting his counterclaim to the jury first. 7 EFTA00808462 ARGUMENT I. EPSTEIN WILL SUFFER IRREPARABLE HARM IF FORCED TO PROCEED WITH SEPARATE TRIALS BECAUSE THE CLAIMS INVOLVE INTERRELATED FACTUAL ISSUES AND, THEREFORE,

2d 733, 737 (Fla. 3d DCA 1981) (emphasis added). See also Estate of Carrillo v. Fed. Deposit Ins. Corp., No. 11-22668-CIV, 2012 WL 13013081, at *1 (M. Fla. Apr. 25, 2012) ("Bifurcation is the exception, not the rule, and the party seeking bifurcation shoulders the heavy burden of establishing that bifu

mmary judgment in the Ponzi Scheme Action. SJ Motion at 1 (Edwards "is entitled to summary judgment for all claims brought against him in Plaintiff Jeffrey Epstein's Complaint" because "the evidence uncontrovertibly demonstrates the propriety of every aspect of Edwards' involvement in the prosecution of legitimat

alternative sources before it may be subpoenaed from any non-party in New York. In fact, Edwards concedes in his own Florida court filings that the Epstein interview is, at best, cumulative of "overwhelming evidence" he has already obtained from several alternative sources. Second, even if Edwards were

made of a confidential unpublished interview of Jeffrey Epstein. PRELIMINARY STATEMENT In this ancillar

d not, publish the information imparted to me by Mr. Epstein during the interview. Rush Supp. Aft 17 (emphasi

,25 29 28,29 In re Zallie, 2009 WL 2844429 (Sup. Ct. M. Co. Aug. 13, 2009) 12, 15, 21 Johnson Law Group v. limadebt USA, LLC, 2010 WL 2035284 (M. Fla. May 24, 2010) 18 Kirkland & Ellis v. Chadl e & Parke LLP, 176 Misc.2d 73, 670 .2d 753 (Sup. Ct. Co. 1998) 12 Kooper v. Kooper, 74 El3d 6, 901

ICT OF FLORIDA FORT LAUDERDALE DIVISION www.flsb.uscourts.gov IN RE: ROTHSTEIN ROSENFELDT ADLER, M., Debtor. CASE NO. 09-34791-RBR CHAPTER 11 JEFFREY EPSTEIN'S REPLY TO THE INTERVENORS' RESPONSE TO EPSTEIN'S MOTION TO TAKE THE INTERVENORS' DEPOSITIONS AND TO COMPEL THEIR MENTAL EXAMINATIONS Jeffrey Epstei

rts.gov IN RE: ROTHSTEIN ROSENFELDT ADLER, M., Debtor. CASE NO. 09-34791-RBR CHAPTER 11 JEFFREY EPSTEIN'S REPLY TO THE INTERVENORS' RESPONSE TO EPSTEIN'S MOTION TO TAKE THE INTERVENORS' DEPOSITIONS AND TO COMPEL THEIR MENTAL EXAMINATIONS Jeffrey Epstein ("Epstein") replies to the Intervenors, IM

M., Debtor. CASE NO. 09-34791-RBR CHAPTER 11 JEFFREY EPSTEIN'S REPLY TO THE INTERVENORS' RESPONSE TO E

l states in controversy. See D.E. 6432; see also, e.g., Reaves v. Wayne Automatic Fire Sprinklers, Inc., No. 2:11-cv-00049-CEH-SPC, 2011 WL 4837253 (M. Fla. Oct. 12, 2011). As such, Rule 35 entitles Epstein to the Intervenors' independent mental examinations. The Intervenors suggest that Rule 35 does no