Epstein Secrets

SCOVERY TO TAKE DEPOSITIONS Counter-Plaintiff, Bradley J. Edwards, by and through undersigned counsel, hereby files this Response in Oppositions to Jeffrey Epstein's Motion to Reopen Discovery to Take Depositions, and as grounds therefor states as follows: The Motion Fails to Meet the Court's Requirements to Reo

, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION TO REOPEN DISCOVERY TO TAKE DEPOSITIONS Counter-Plaintiff, Bradley J. Edwards, by and through undersigned counsel, hereby files this Resp

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

wards who is seeking to reconfirm the deadline. Mr. Epstein is objecting to that reconfirmation. THE COURT:

going was sent via E-Serve to all Counsel on the attached list, this Id- --day of '--. A-°" 1111 2018. JACK/SC RO Flola ar No.: 169440 DA I i P. VITALE JR. Flo • a Bar No.: 115179 Attorney E-Mail(s): [email protected] and [email protected] Primary E-Mail: [email protected] Searcy Denney

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

copy of the foregoing was sent via E-Serve to all Counsel on the attached list, this II) day of October, 2017. JAC OLA Flo s a No.: 169440 D P. VITALE JR. a Bar No.: 115179 orney E-Mail: [email protected] and [email protected] Primary E-Mail: [email protected] Seamy Denney Scarola Bar

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 L.M., individually, Defendants. SUPPLEMENT TO EDWARDS' MO

communications between counsel in this matter regarding the source of the untimely Supplemental Exhibits improperly obtained and publicly filed by Epstein, the undersigned received a hand-delivered communication from counsel for Epstein enclosing "a flash drive which duplicates the disc we located in F

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

ect copy of the foregoing was sent via E-Serve to all Counsel on the attached list, this 7th day of March, 2018. JACK OLA Flor r No.: 169440 D P. VITALE JR. nda Bar No.: 115179 Attome E-Mails: and Primary E-Mail: Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West P