Epstein Secrets

efendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO EDWARDS' MOTION FOR SANCTIONS FOR VIOLATION OF COURT ORDER AND THE INTERVENORS' JOINDER Plaintiff/Counter-Defendant Jeff

OPPOSITION TO EDWARDS' MOTION FOR SANCTIONS FOR VIOLATION OF COURT ORDER AND THE INTERVENORS' JOINDER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") responds in opposition to Counter- Plaintiff Bradley J. Edwards' ("Edwards") April 3, 2018, Motion for Sanctions for Violation of Court Order', an

Berard Rockenbach (FBN Rachel J. Glasser (FBN Primary: Primary: Primary: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant Jay Epstein 13 EFTA00808684 SERVICE LIST Jack Scarola Karen E. Terry David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, . 2139 Palm Beach

OUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

en into consideration is the appellate rights of Mr. Epstein and how they're going to preserve those rights i

to even assertedly privileged documents in any context other than at trial is completely nonsensical. Even a privilege log required under Florida's Rules of Civil Procedure as a condition to withhold documents on the basis of privilege must sufficiently identify the specific documents withheld with enough detail to fac

en into consideration is the appellate rights of Mr. Epstein and how they're going to preserve those rights i

efendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO EDWARDS' MOTION FOR SANCTIONS FOR VIOLATION OF COURT ORDER AND THE INTERVENORS' JOINDER Plaintiff/Counter-Defendant Jeff

OPPOSITION TO EDWARDS' MOTION FOR SANCTIONS FOR VIOLATION OF COURT ORDER AND THE INTERVENORS' JOINDER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") responds in opposition to Counter- Plaintiff Bradley J. Edwards' ("Edwards") April 3, 2018, Motion for Sanctions for Violation of Court Order', an

Berard Rockenbach Rachel J. Glasser (FBN Primary: Primary: Primary: Secondary: Secondary: FBN Trial Counsel for Plaintiff/Counter-Defendant Jay Epstein SERVICE LIST Jack Scarola Karen E. Teny David P. Vitale, Jr. Searcy, Denny, Scarola, Barnhart & Shipley, M. 2139 Palm Beach Lakes Boulevard We

OUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

to even assertedly privileged documents in any context other than at trial is completely nonsensical. Even a privilege log required under Florida's Rules of Civil Procedure as a condition to withhold documents on the basis of privilege must sufficiently identify the specific documents withheld with enough detail to fac

from the U.S. Attorney's Office to Epstein's counsel (see ¶6) specifically in support of his contention that there was a 'joint attempt to minimize Epitein's civil exposure." 3 EFTA00208199 Case 9:08-cv-80736-KAM Document 177-1 Entered on FLSD Docket 06/06/2012 Page 16 of 22 Epstein v. Rothstein an

FLSD Docket 06/06/2012 Page 1 of 22 Tonja Haddad Coleman From: Sent: To: Subject: Thank you. Jack Scarola Tuesday, May 08, 2012 3:41 PM Re: Epstein discovery On May 8, 2012. at 3:27 PM. "Tonja Haddad Coleman" MINIMI > > Fine. > Tonja Haddad Coleman. Esq. > Tonja Haddad, P.A. > Justice Buildi

iffiCounter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. ORDER ON PLAINTIFF JEFFREY EPSTEIN'S MOTION TO COMPEL AND AMEND PROTECTIVE ORDER THIS MATTER came before the Court on PlaintiffJeffrey Epstein's Motion to Compel and Amend Protective

NO. 502009CA0408003OOO134B Judge David F. Crow JEFFREY EPSTEIN, PlaintiffiCounter-Defendant, v. SCOTT

pstein is entitled to reasonable attorney's fees necessitated by Defendant's flagrant disregard of both this Court's Order and the afore- referenced Rules of Civil Procedure. CONCLUSION Accordingly, for all of the reasons delineated above and in reliance upon the applicable law cited herein, Plaintiff Jeffrey Epstein r

eving that Bill Clinton was on the airplane with Mr. Epstein and these young woman ..." (18:24-19:4.) • "I c

/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR AN IN CAMERA INSPECTION OF 30 E-MAILS Counter-Defendant, Jeffrey Epstein ("Epstein"), moves' this Court for an in camera inspection of

liver the accompanying sealed Memorandum by November 9, 2018. Edwards was instructed to deliver a response sealed Memorandum by November 16, 2018. 2Epstein has reduced the original 47 e-mails for in camera review down to 30 e-mails. 3Farmer Jaffe agreed to produce all work-product related to closed case

OUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

dwards' failure to comply with the Court's Order. Because Edwards blatantly disregarded the Court's Order, as well as the requirements of Florida's Rules of Civil Procedure and the TIG case, the February 23, 2011 privilege log remains for any number of wholly deficient and worse - misleading. The privilege log misstate