Epstein Secrets

IN, Plaintiff/Counter-Defendant, Case No. 50 2009 CA 040800XXXXMBAG v. BRADLEY J. EDWARDS, et al., Defendants/Counter-Plaintiff. JUDGE: HAFELE JEFFREY EPSTEIN'S RESPONSE TO BRADLEY EDWARDS'S MOTION IN LIMINE TO STRIKE THE JUNE 30.2017 AFFIDAVIT OF JEFFREY EPSTEIN AND TO EXCLUDE EVIDENCE AS TO WHICU DISCOVE

JEFFREY EPSTEIN AND TO EXCLUDE EVIDENCE AS TO WHICU DISCOVERY WAS WITHHELD UNDER CLAIMS OF PRIVILEGE Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, hereby files his Response to Defendant/Counter-Plaintiff Bradley Edwards's ("Edwards") Motion in Limine

DICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FL JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No.

millions of dollars. Q. And trying to find out, Mr. Epstein, whether you have any evidence whatsoever that

and 6 generate cases. See Deposition of Jeffi•ey Epstein, p. 28; line13-p. 29; line 6. BY MR. SCAROLA: Q

her through a proper motion or at trial, so that this Court can properly examine the issue and rule on Edwards's request that it be precluded. See Tomlinson-McKenzie v. Prince, 718 So. 2d 394, 396 (Fla. 4th DCA 1998); Aguila-Rojas v. City Management Group Corp., 606 So.2d 765, 766 (Fla. 3d DCA 1992). In the case

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

tein's Motion to Amend Exhibit List. McKenzie v. Prince, 718 So. 2d 394, 396 (Fla. 4th DCA 1998) (citing Binger). As the Fourth DCA aptly stated in Tomlinson-McKenzie: The objecting party is prejudiced by the admission of such evidence if the party might have taken some action to protect itself had it had timely

O DISCLOSE EXPERT WITNESS Plaintiff, Bradley J. Edwards, by and through undersigned counsel, hereby files this Response in Opposition to Defendant Jeffrey Epstein's Renewed Motion for Leave to Disclose Expert Witness, and as grounds therefor states as follows: &nicer Does Not Permit a Party to Ignore Trial Cour

PSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and individually, Defendant, RESPONSE IN OPPOSITION TO EPSTEIN'S RENEWED MOTION FOR LEAVE TO DISCLOSE EXPERT WITNESS Plaintiff, Bradley J. Edwards, by and through undersigned counsel, hereby files this Respons

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

n Case No.: 502009CA040800XXXXMBAG Response in Opposition to Epstein's Renewed Motion for Leave to Disclose Expert Witness "expert" testimony. See Tomlinson-McKenzie v. Prince, 718 So. 2d 394, 396 (Fla. 4th DCA 1998) ("There was no finding that appellants failed to comply with the pretrial order in bad faith. Th