Epstein Secrets

ff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and •I., individually, Defendants. RESPONSE IN OPPOSITION TO DEFENDANT JEFFREY EPSTEIN'S MOTION TO ALLOW AMENDMENT TO EXHIBIT LIST AND SUPPLEMENT TO MOTION TO ALLOW AMENDMENT TO EXHIBIT LIST Bradley J Edwards ("Edwards"), by and throug

ibit List and Supplement thereto, and as grounds therefor states as follows: Delay. Delay. Delay When the Court peels back the layers of Defendant Epstein's attempt to drastically alter his Exhibit List, it will be left with a rather basic question: How far will the Defendant be permitted to go in his

y. Delay When the Court peels back the layers of Defendant Epstein's attempt to drastically alter his Exhibit List,

OUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

040800XXXXMBAG Response in Opposition to Epstein's Motion to Amend Exhibit List. nothing more than another hyper-technical argument. Les Goodwin v. Blu Murray Ins. Agency, Inc., 939 So. 2d 1098, 1104 (Fla. 5th DCA 2006) ("The elements of waiver are: (1) the existence at the time of the waiver of a right, priv

position to PlaintifUCounter-Defendant Jeffrey Epstein's Motion for Temporary Stay of Proceedings, and as grounds therefor states as follows: un 5 ana Jeffrey Epstein initiated this litigation in 2009. For three years, he carried the burden of proof to establish that Bradley Edwards had fabricated his clients' sex

n 2009. For three years, he carried the burden of proof to establish that Bradley Edwards had fabricated his clients' sexual assault claims against Epstein, in furtherance of a Ponzi scheme. Substantial discovery was taken by both parties. In 2012, Epstein voluntarily dismissed his complaint, and the so

DCA 2010) (stating that, in the context of arbitration, a party's "active participation in litigation" serves to waive the right to arbitration). b. Epstein is Estopped from Seeking a Stav/Continuance. Epstein's attempt to stay/continue this case is also barred by the doctrine of equitable estoppel, whi

UNTY, FLORIDA CASE NO.: 502009CA040800)OOOCMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

ge or benefit which may be waived; (2) the actual or constructive knowledge of the right; and (3) the intention to relinquish the right. Goodwin v. Blu Murray Ins. Agency. Inc. 939 So. 2d 1098, 1104 (Fla. 5th DCA 2006). Epstein clearly waived any argument that the Doe v. United States proceeding justifies a s

r-Plaintiff Bradley J. Edwards, by and through undersigned counsel, hereby submits this Response in Opposition to PlaintifVCounter-Defendant Jeffrey Epstein's Motion to Continue Hearing Scheduled for October 3, 2017 and/or Extend Time to File Motions Related to Collateral Quasi-Criminal Cases, and as groun

efendant Jeffrey Epstein filed suit against attorney Bradley J. Edwards, alleging that Mr. Edwards had fabricated certain civil claims arising from Epstein's systematic sexual abuse of minor female children as part of a fraudulent Ponzi scheme that Edwards was running with Scott Rothstein and one of Edw

OUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

ge or benefit which may be waived; (2) the actual or constructive knowledge of the right; and (3) the intention to relinquish the right. Goodwin v. Blu Murray Ins. Agency, Inc., 939 So. 2d 1098, 1104 (Fla. 5th DCA 2006). Epstein clearly waived any argument that the 2008 Doe v. United States proceeding impeded

-Plaintiff Bradley J. Edwards, by and through undersigned counsel, hereby submits this Response in Opposition to Plaintiff/Counter-Defendant Jeffrey Epstein's Motion to Continue Hearing Scheduled for October 3, 2017 and/or Extend Time to File Motions Related to Collateral Quasi-Criminal Cases, and as groun

efendant Jeffrey Epstein filed suit against attorney Bradley J. Edwards, alleging that Mr. Edwards had fabricated certain civil claims arising from Epstein's systematic sexual abuse of minor female children as part of a fraudulent Ponzi scheme that Edwards was running with Scott Rothstein and one of Edw

OUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

d for October 3, 2017 Page 4 of 8 (2) the actual or constructive knowledge of the right; and (3) the intention to relinquish the right. Goodwin v. Blu Murray Ins. Agency, Inc., 939 So. 2d 1098, 1104 (Fla. 5th DCA 2006). Epstein clearly waived any argument that the 2008 Doe v. United States proceeding impeded