Epstein Secrets

21 22 23 24 25 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800SSSSMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, vs. SCOTT ROTHSTEIN, INDIVIDUALLY and BRADLEY J. EDWARDS, INDIVIDUALLY, Defendants/Counter-Plaintiffs. / PROCE

. . EFTA00617907 2 1 2 1 7 8 9 10 11 12 13 -14 15 16 17 18 19 20 21 22 23 24 25 APPEARANCES: ON BEHALF OF THE PLAINTIFF EPSTEIN: W. CHESTER BREWER, JR., P.A. 250 S. Australian Ave., Suite 1400 West Palm Beach, FL 33401 By: W. CHESTER BREWER, JR. LAW OFFICES OF TONJA HAD

COURT: Thank you. Good morning. This is counter-defendant Epstein's motion for fees and costs pursuant to an offer

COUNTY, FLORIDA CASE NO.: 502009CA040800SSSSMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, vs. SCOT

e record, my name is Chester Brewer. I represent Mr. Epstein. We have with us also representing Mr. Epstein M

forever. And there is no reference to what the remedies would be. So under the guidance of Schwartzle, the criteria that had been laid out by the Fourth DCA have clearly not been met. That's defect Number 1 in the confidentiality provision. Defect Number 2 is that obviously because this confidentialit

asked about whether there is any appellate authority that assists the Court in addressing this issue, and the answer to that question is there is Fourth DCA precedent that is in fact very directly on point. PALM BEACH REPORTING SERVICE, INC. 561-471-2995 PJW@PalTseacWPotftscp EFTA00617917 12 1 2

2'2009 Page 1 of 26 UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA JANE DOE, CASE NO.: 08-CIV- 80893 - MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendants. Defendant's, Epstein. Motion To Dismiss, For More Definite Statement & To Strike Directed To Plaintiff Jane Doe's Amended Complaint,

Plaintiff. . .was called on the telephone by. . .Epstein and other employees. . ., and transported to. . .

Florida Civil Rico action is, at this time, only defendant Epstein. . . ." However, the RICO enterprise must be dis

.: 08-CIV- 80893 - MARRA/JOHNSON Plaintiff, v. JEFFREY EPSTEIN, Defendants. Defendant's, Epstein. Moti

nderlying wrong of continued childhood sexual abuse brought against the Archdiocese did not allow for recovery under RICO). Finally, even Florida's Fourth DCA confirms that in order to have a claim for RICO, there must be damage to "business or property." Petrol. LTD. v. Radulovic, 764 So.2d 878 (Fla. 4th

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

esponse in Opposition to Epstein'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

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 UNCERTIFIED TRANSCRIPT DISCLAIMER IN THE MATTER OF EPSTEIN v. EDWARDS DRAFT ONLY !!!! NOT PROOFREAD EFTA00792811 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

y were not passengers on the planes. And that is true. It is true that all of Brad Edwards' clients acknowledged that they were not passengers on Jeffrey Epstein's private jets. But both the Florida Evidence Code and federal rules of evidence expressly permit the federal rules are very explicit about this: Ex

nto details with regard to what happened between Jeffrey Epstein and each of the three claimants against

ith -- have a seat, please. Thank you. -- being Mr. Epstein and Mr. Edwards, and the counterclaim brought by

ck is a DRAFT ONLY !!!! NOT PROOFREAD EFTA00792856 47 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Fourth DCA decision called Frazier versus Security and Investments, 1993. What does Frazier tell us? Not only do we build off the US Supreme Court and say yo