Epstein Secrets

idually, and individually, Defendants. Complex Litigation, Fla. R. Civ. Pro. 1201 Case No. 50 2009 CA 040800XXXXMBAG PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR PROTECTIVE ORDER TO PRECLUDE OPPOSING COUNSEL AND DEFENDANT/COUNTER-PLAINTIFF FROM MAKING EXTRA-JUDICIAL STATEMENTS AND COMMENTARY TO T

XTRA-JUDICIAL STATEMENTS AND COMMENTARY TO THE MEDIA AND PRESS, WITH INCORPORATED LEGAL AUTHORITIES Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("EPSTEIN"), by and through his undersigned counsel and pursuant to Rule 1.280(c) of the Florida Rules of Civil Procedure, files this Motion for Protective O

mentary in order to insure that Plaintiff/Counter-Defendant EPSTEIN receives a fair trial. See State ex. rd. Miami H

CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, indiv

ant to obtain additional details on the scope of Mr. Epstein's alleged sexual abuse of children — when, where,

CERTIFICATE OF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was mailed this day of March, 2011 to: Jack Scarola, Esq. Searcy Denney Scarola Bamhart & Shipley, P.A Jack A. Goldberger, Esq. Goldber er & Weiss P.A. - 5 - EFTA00616240 CASE NO. 50 2009 CA 040800 XXXXMB AG West Palm Beach, FL 33401-5012

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 08-ev-80119-MARRAMM JANE DOE NO. 2, Plaintiff, vs. JEFFREY EPSTEIN, Defendant / Related cases: 08-80232, 08-08380, 08-80381, 08-80994, 08-80993, 08-80811, 08-80893, 09-80469, 09-80591, 09-80656, 09-80802, 09-

ry, for use at trial, or for such other purposes as are permitted under the applicable Statutes of Ryes of Court. tton, Jr. Attorney for Defendant Epstein EFTA00727547 Certificate of Service I HEREBY CERTIFY that the foregoing document is being served this day on all counsel of record identified on

atutes of Ryes of Court. tton, Jr. Attorney for Defendant Epstein EFTA00727547 Certificate of Service I HEREBY

stein) Certificate of Service Jane Doe No. 2 v. Jeffrey E stein Case No. 08-CV-80119-MARRA Swan S. Mermel

q. No. MI Law Firm, P.A. 224 Datum Street, Suite 900 West Palm Beach, FL 33401 561-832-7732 561-832-7137 F Jack Scarola, Esq. Jack P.M, Esq. Searcy Denney Scarola Bamhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 561-686-6300 Fax: 561-383-9424 Bruce Reinhart, Esq. Bruce E. Reinhart, P.A. 2

ives or any other electronic format and any written transcriptions). 13. All conversations recorded from any telephones which purported to be from Jeffrey Epstein's attorneys including Roy Black, Alan Dershowitz or Jack Goldberger, that are contained in any media (audio tapes, CDs, DVDs, zip drives, hard drives

Beach County Courthouse, 205 North Dixie Highway, Courtroom 9C, West Palm Beach, Florida 33401, on Tuesday, April 5, at 8:30 a.m., the following: EPSTEIN'S MOTION TO COMPEL/MOTION TO DETERMINE IF PRIVILEGE CLAIMS ARE WAIVED The following procedures must be noted on all specially set hearing notices i

NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, indivi

and/or Scott Rothstein relating to any aspect of Mr. Epstein's case. Objections were based on relevance and o

and correct copy of the foregoing has been mil) y furnished via U.S. ee Mail to ell counsel on the attached list on #0.- ' 2010. Jack Scarola Searcy Denney Scarola Bamhart & Shipley, P.A. Attorneys for Defendant, Bradley Edwards 2139 Palm Beach Lakes Boulevard West Pakn Beach, Florida 33409 Jack a Flor". a %ar No.: a fle(e

ve received this. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 5O2009CAO4O800XXXXMBAG JEFFREY EPSTEiN, Plaintiff, vs. SCOTT ROTHSTEJIN, individually, BRADLEY J. EDWARDS, individually, and EM., individually, Defendants. NOTICE OF FILING

ipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Pho Fax Attorney for Defendant/CounterClaimant Edwards Edwards adv. Epstein CaseNo.: 5O2009CAO4O800XXXXJvIBAG Notice of Filing Supplement COUNSEL LIST Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 250

u to do is to give me the highest number that you are comfortable in saying there were definitely more than X number of underage girls that I know Jeffrey Epstein engaged in sex with while I had a relationship with him. How would you fill in that blank? Definitely more than how many? V: I'd say definitely mo

us about the circumstances of your first meeting Mr. Epstein. V: Ok. I was introduced to Mt Epstein by Ghisla

the foregoing has been furnished by U.S. Mail to all Counsel on the attached list on this day ofMay 2011. Jack Scarola Florida Bar No.: 169440 Searcy Denney Scarola Bamhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Pho Fax Attorney for Defendant/CounterClaimant Edwards Edwards adv. Epste

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS. individually, and individually, Defendants. RESPONSE IN OPPOSITION TO EPSTE

STEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS. individually, and individually, Defendants. RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION TO REMOVE CASE FROM TRIAL DOCKET IN ORDER TO COMPLY WITH THE MANDATE SET FORTH IN RULE 1.440 Counter-Plaintiff Edwards, by and through un

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

egoing was sent via E-Serve to all Counsel on the attached list, thisIn day of March, 2018. ida Bar No.: Attorne E-Mails: ; and Primary E-Mail: Searcy Denney Scarola Bamhart & Shipley, 2139 Palm Beach Lakes Boulevard West Palm Beach, Florida 33409 Phone: Fax: Attorneys for Bradley J. Edwards 6 EFTA00808656 Edwards adv. Eps