Epstein Secrets

privacy. 5. This is strictly a "fishing expedition" unrelated to any aspect of this case. A similar Request to Produce was served in the casel v. Jeffrey E. Epstein and , Case No. 502008CA025129XXXXMB Al, in front of Judge Garrison. A copy of the objection to the Notice is attached as Exhibit "B" and Judge Garr

BOARD CERTIFIED CVO-TRIAL LAWYER Sent by Fax and U.S. Mail Isidro M. Garcia, Esq. A LIMITED LIABILITY PARTNERSHIP April 13, 2009 Re: Doe II v. Epstein, et al. Case No. 09-80469-Civ-MARRA/JOHNSON ADELQUI.LBENAVENTE rmukumALINVBSTIOMOR BARBARA M. NkKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALE

kKENNA ASHLIE STOKEN-BARING BETTY STOKES PARALEGALS RITA H. BUDNYK OP COUNSEL Dear Sid: Please be informed thal subpoenaed deposition in thel.L. Epstein case on April 16th, 2009 is hereby cancelled. Cordially Robert D. Critton, Jr. RDC/clz cc: Jack A. Goldberger, Esq. L•A•W•Y•E •R•S TELEPHONE

py of the case law and Florida Statutes cited in Defendant Epstein' otion to Dismiss, For More Definite Statement, a

ar Request to Produce was served in the casel v. Jeffrey E. Epstein and , Case No. 502008CA025129XXXXMB Al,

ar Request to Produce was served in the casel v. Jeffrey E. Epstein and , Case No. 502008CA025129XXXXMB Al,

OW CAB Defendant, Jeffrey Epstein, (hereinafter "Mr. Epstein"), by and through his undersigned attorneys, pur

tprfl=HTMLEttifm=NotSet&mt... 4/10/2009 EFTA00722723 Page 3 of 3 800 So.2d 706 800 So.2d 706,26 Fla. L. Weekly D283I (Cite as: 800 So.2d 706) (Fla.1999), the supreme court again discussed 800 So.2d 706,26 Fla. L. Weekly D2831 Langston and, without expressly overruling it, stated that the principle

o privacy. 5. This is strictly a "fishing expedition" unrelated to any aspect of this case. A similar Request to Produce was served in the caa v. Jeffrey E. Epstein and Case No. 502008CA025129XXXXMB Al, in front of Judge Garrison. A copy of the objection to the Notice is attached as Exhibit "B" and Judge Garris

RIAL LAWYER Sent by Fax and U.S. Mail Isidro M. Garcia, Esq. Garcia Law firm P.A. A LIMITED LIABILITY PARTNERSHIP April 13, 2009 Re: Doe II v. Epstein, et al. Case No. 09-80469-Civ-MARRA/JOHNSON ADELQUI.LBENAVENTE rmemeom. I INVBSTIOMOR BARBARA M. NkKENNA ASHLER STOKEN-BARING BETTY STOKES PAR

OW CAB Defendant, Jeffrey Epstein, (hereinafter "Mr. Epstein"), by and through his undersigned attorneys, pur

ilar Request to Produce was served in the caa v. Jeffrey E. Epstein and Case No. 502008CA025129XXXXMB Al, i

py of the case law and Florida Statutes cited in Defendant Epstein' otion to Dismiss, For More Definite Statement, a

CASE NO. 502008CA037319XXXXMB AB Plaintiff, v. JE an Defendants. DEFENDANT'S, JEFFREY EPSTEIN, O

ilar Request to Produce was served in the caa v. Jeffrey E. Epstein and Case No. 502008CA025129XXXXMB Al, in

MLEttifm=NotSet&mt... 4/10/2009 EFTA00614453 Page 3 of 3 800 So.2d 706 Page 2 800 So.2d 706, 26 Fla... Weekly D2831 (Cite as: 800 So.2d 706) (Fla.1999), the supreme court again discussed 800 So.2d 706, 26 Fla.'. Weekly D2831 Langston and, without expressly overruling it, stated that the principle

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

ll be upheld if there is any basis which would support the judgment in the record." 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, su

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

s 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 claims."). Here, Edwards fails to do so,