Epstein Secrets

• IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, v. cor.50.2929aufactigIVP111, CASE NO. • A Aq SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and .M., individu

OTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and .M., individually, Defendants. COMPL CO Plaintiff, JEFFREY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually,

ases and thus by using the deposition sell the cases (or a part of them) to third parties. #4S 37. Because of these facts, ROTHSTEIN claimed that Epste wanted to make certain none of these individuals would be deposed and therefoie he had offered $200,000,000.00 to settle the claims of RRA female

EPSTEIN and like other RRA clients, sought tens of millions of dollars. a. For example, in her sworn statement to the FBI, L.M. was insistent that "Jeffrey is an awesome man." (p. 21 — FBI); At the conclusion of she stated: "I hope Jeffrey, nothing happens to Jeffrey because he's an awesome man and it

hat the evidence is really going to show is that Mr. Epstein — at least dating back as completely irrelevant

Litigation Team knew or should have known of the improper purpose that ROTHSTEIN was pursuing in the continuation of thMheme, ROTHSTEIN used RRA's Litigation Team in the EPSTEIN cases to put issues and evidence unrelated to and unnecessary to the claims pled in th Actions, but significantly beneficial to lu

32 08/06/2009 Adam Horowitz Bradley J. Edwards Epsteins assets Joint-privilege 16 EFTA00310063 Privi

ATE TO FROM DESCRIPTION OBJECTION Confidential 07030 09/22/2009 Bradley J. Edwards Spencer Kuvin v. Epstein — defendant, Joint-privilege Jeffrey Epstein's response to plantiff 07090.07091 9/29/2009 Bradley J. Edwards Katherine W. Ezell Leslie Wexner Joint-privilege 07092 10/29/2009 Stuart Me

Edwards Adam Horowitz Jeffrey Epstein DUI W35755 Joint-privilege 02462 09/22/09 Spencer Kuvin Bradley J. Edwards III v. Epstein — Defendant, Jeffrey Epstein"s Response to Plantiff Motion for Protective Order Joint-privilege 02476-02477 09/25/2009 Spencer Kuvin Bradley J. Edwards LM v EPST

Katherine W. Bradley J. Edwards Is Mark Epstein JE's brother? Joint-privilege 18 EFTA00310065 P

privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 00150 04/24/2009 Litigation Team Rob Buschel Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of adm

2 08/06/2009 Adam Horowitz Bradley J. Edwards Epsteins assets Joint-privilege 16 EFTA00602850 Privi

man BATES DATE TO FROM DESCRIPTION OBJECTION Confidential 07030 09/22/2009 Bradley J. Edwards Spencer Kuvin IM v. Epstein — defendant, Jeffrey Epstein's response to plantiff Joint-privilege 07090-07091 9/29/2009 Bradley J. Edwards Katherine W. Ezell Leslie Wexner Joint-privilege 07092 10/29

Edwards Adam Horowitz Jeffrey Epstein oat W35755 Joint-privilege 02462 09/22/09 Spencer Kuvin Bradley J. Edwards I■ v. Epstein — Defendant, Jeffrey Epstein"s Response to Plantiff •'s Motion for Protective Order Joint-privilege 02476-02477 09/25/2009 Spencer Kuvin BradleyJ. Edwards LM v

Katherine W. Bradley J. Edwards Is Mark Epstein JE's brother? Joint-privilege 18 EFTA00602852 P

privilege;irrelevant & reasonably calculated to lead to the discovery of admissible evidence;protected by privacy rights 00150 04/24/2009 Litigation Team Rob Buschel Litigation Strategy Work Product;attorney client privilege;irrelevant & reasonably calculated to lead to the discovery of adm