Epstein Secrets

40800XXXXMBAG Plaintiff/Counter-Defendant, JUDGE HAFELE v. BRADLEY J. EDWARDS, et al., Defendant/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RENEWED MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S FOURTH AMENDED COUNTERCLAIM, OR, IN THE ALTERNATIVE, MOTION F

DERATION OF ORAL SUMMARY JUDGMENT RULING, REOUEST FOR ORAL ARGUMENT AND SUPPORTING MEMORANDUM OF LAW Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.510 of the Florida Rules of Civil Procedure, hereby files this Renewed Motion for

of March 23, 2010; dockets and pleadings in LM v. Jeffrey Epstein, 502008C44028051)OOCXMB AB; EW v. Jeffrey Epstein, 502008CA028058DOCAMB AB; LM v. Jay Epstein, 09-81092 Marra/Johnson and Jane Doe v. Jeffrey Epstein, 08-80893-CIV Marra/Johnson; copies of subpoenas; Deposition Transcript of Jeffrey Epstein,

e of these potentially explosive facts, putative defendant Epstein had allegedly offered $200,000,000.00 for settlem

CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY JEFFREY EPSTEIN, No. 50 2009 CA 040800XXXXMBAG Plaintif

(the "Epstein Cases"). See pleadings in LM v. Jee•ey Epstein, 502008CA028051XXXXMB AB; EW v. Jeffrey Epstein,

connection whatsoever to any specific claims of misconduct against the plaintiffs in the Epstein Cases. See letter dated 6 Edwards was a partner at Rothstein Rosenfeld Adler ("RRA") from April 2009 through November 2009, which was during the same period when, according to the Razorback Complaint, the Epstein cases were

vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiff. AFFIDAVIT OF JEFFREY EPSTEIN The undersigned, Jeffrey E. Epstein, having first been duly sworn, hereby deposes and says: 1. I am over eighteen (18) years old and have personal knowledge of the facts stated here

or leave to file the supplemental argument contained herein on the following grounds: 1. The trial judge entered summary final judgment in favor of Epstein on the ground that the litigation privilege bars the malicious prosecution and abuse of process claims filed against Epstein by the appellant, Brad

unrelated to the underlying litigation against me, and (b) asserting my causes of action against Edwards and Rothstein in the Action. FURTHER AFFI JEFFREY EPS STATE OF NEW YORK ) ) ss.: COUNTY OF NEW YORK ) _ - Sworn and subscribed to before me, the undersigned authority, by Jeffrey Epstein, this 25t

e of these potentially explosive facts, putative defendant Epstein had allegedly offered $200,000,000.00 for settle

. 4D14-2282 BRADLEY J. EDWARDS, Appellant, v. JEFFREY EPSTEIN, Appellee. MOTION FOR LEAVE TO FILE SUP

nces to supporting documentation. (R. 808-818). Those facts, along with the references as footnotes, are recounted below. Edwards was a partner at Rothstein Rosenfeld Adler ("RRA") from April 2009 through November 2009.' During that time, his firm was a front for the largest Ponzi scheme in Florida's history,2 and RRA,

IRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION CASE NOs.: 2006-CF9454 AXX and 2008-CF9381 AXX STATE OF FLORIDA, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PROCEEDINGS HELD BEFORE THE HONORABLE JEFFREY J. COLBATH JUNE 10, 2009 11:09 A.M. - 11:25 A.M. PALM BEACH COUNTY COURTHOUSE WEST P

when I reviewed the file. So, Pm thinking that it might 22 be appropriate and the burden might be on the moving 23 party, being the State and Mr. Epstein, to give them the 24 opportunity to jump through the hur — hoops to seal the 25 documents if they are entitled to have them sealed, then 1 2 3

8-CF9381 AXX STATE OF FLORIDA, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PROCEEDINGS HELD BEFORE TH

be on the moving 23 party, being the State and Mr. Epstein, to give them the 24 opportunity to jump throug

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 On behalf of Third Patty E.W. WILLIAM J. BERGER, ESQUIRE BRADLEY J. EDWARDS, ESQUIRE Rothstein Rosenfeld Adler 401 E. Las Olas Blvd., Suite 1650 Fort Lauderdale, FL 33394 On behalf of Third Party, The Post DEANNA SHULLMAN, ESQUIRE Thomas, LoCiero & Bralow

IRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CRIMINAL DIVISION CASE NOs.: 2006-CF9454 AXX and 2008-CF9381 AXX STATE OF FLORIDA, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PROCEEDINGS HELD BEFORE THE HONORABLE JEFFREY J. COLBATH JUNE 10, 2009 11:09 A.M. - 11:25 A.M. PALM BEACH COUNTY COURTHOUSE WEST P

when I reviewed the file. So, Pm thinking that it might 22 be appropriate and the burden might be on the moving 23 party, being the State and Mr. Epstein, to give them the 24 opportunity to jump through the hur — hoops to seal the 25 documents if they are entitled to have them sealed, then 1 2 3

8-CF9381 AXX STATE OF FLORIDA, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. PROCEEDINGS HELD BEFORE TH

be on the moving 23 party, being the State and Mr. Epstein, to give them the 24 opportunity to jump throug

11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 On behalf of Third Patty E.W. WILLIAM J. BERGER, ESQUIRE BRADLEY J. EDWARDS, ESQUIRE Rothstein Rosenfeld Adler 401 E. Las Olas Blvd., Suite 1650 Fort Lauderdale, FL 33394 On behalf of Third Party, The Post DEANNA SHULLMAN, ESQUIRE Thomas, LoCiero & Bralow

rives 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

ated third party litigation, such as this one. 6. While the Trustee has indicated in a different lawsuit his willingness to try to product to Mr. Epstein the documents he needs, in order that the Trustee's responsibility for winding-up the affairs of the Estate is not impeded and because of the limite

Civ. P. 1.201 Case No. 50 2009CA040800XVOCMB AG JEFFREY EPSTEIN, Plaintiff, V. SCOTT ROTHSTEIN, indivi

ent lawsuit his willingness to try to product to Mr. Epstein the documents he needs, in order that the Trustee

es: 1. On November 10, 2009, Rothstein Rosenfeld) Adler, P.A. ("RRA") was put into involuntary bankruptcy. That case is pending as In Re Estate of Rothstein Rosenfeld Adler, P,A., On November 20, 2009, Herbert Stettin was appointed Trustee of RRA. On November 30, 2009, an Order for Relief was entered by this Court. 2.

s. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, JUDGE: DAVID CROW PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEDIATION SUMMARY Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, hereby files this Mediation Su

nter-Plaintiff, JUDGE: DAVID CROW PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEDIATION SUMMARY Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, hereby files this Mediation Summary in preparation for the Mediation scheduled before you on October 11,

UNTY, FLORIDA CASE NO.: 502009CA0408003OOOCMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, vs. SCOT

were the facts upon which Epstein relied as requisite cause to assert his causes of action against Rothstein and Edwards: Edwards was a partner at Rothstein Rosenfeld Adler ("RRA") from April 2009 through November 2009. During that time, his firm was a front for the largest Ponzi scheme in Florida's history. Also durin

S SOON AS POSSIBLE. BERGER SINGERMAN Dora Raton Fort Lomat:Sale Worn, Tallahassee hi, EFTA00616223 MAR-15-2011 TUE 05:39 PM FAX NO. P. 03/07 JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. IN THE CIRCUIT COURT OF TH

-15-2011 TUE 05:39 PM FAX NO. P. 03/07 JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually,

23 MAR-15-2011 TUE 05:39 PM FAX NO. P. 03/07 JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, indivi

individually, and L.M., individually, Defendants. MOTION FOR FROTECTIVE ORDER FOR HERBERT STETTIN, TRUSTEE Herbert Stettin, Chapter 11 Trustee of Rothstein Rosenfeld Adler, P.A., ("RRA") hereby moves for a Protective Order as to a Subpoena issued upon him for records to be produced by March 16, 2011 and states: 1. F

40800XXXXMBAG Plaintiff/Counter-Defendant, JUDGE HAFELE v. BRADLEY J. EDWARDS, et al., Defendant/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWAFtDS'S FOURTH AMENDED COUNTERCLAIM, REOUEST FOR ORAL ARGUMENT AND SUPPORTIN

EDWAFtDS'S FOURTH AMENDED COUNTERCLAIM, REOUEST FOR ORAL ARGUMENT AND SUPPORTING MEMORANDUM OF LAW Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.510 of the Florida Rules of Civil Procedure, hereby files this Motion for Summary

s Rights Act: When asked whether Epstein "pulled you closer to him in a sexual way," [LM] replied: A. I wish. No, no, never, ever, ever, no, never. Jeffrey is an awesome man, no. At the end of her interview, [LM] was asked if she had any questions for the agents or AUSA Villafana. [LM] responded: A. N

ims of RRA's fraudulent scheme described in the Razorback Complaint received $170,000,000 to settle their claims. [Cite] 6 Edwards was a partner at Rothstein Rosenfeld Adler ("RRA") from April 2009 through November 2009, which was during the same period when, according to the Razorback Complaint, the fraudulent pleading

s. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, JUDGE: DAVID CROW PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEDIATION SUMMARY Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, hereby files this Mediation Su

nter-Plaintiff, JUDGE: DAVID CROW PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEDIATION SUMMARY Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, hereby files this Mediation Summary in preparation for the Mediation scheduled before you on October 11,

OUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, vs. SCOT

were the facts upon which Epstein relied as requisite cause to assert his causes of action against Rothstein and Edwards: Edwards was a partner at Rothstein Rosenfeld Adler ("RRA") from April 2009 through November 2009. During that time, his firm was a front for the largest Ponzi scheme in Florida's history. Also durin