Epstein Secrets

02/01/2012 16:11 FAX 5616845816 SEARCY DENNEY liboovois JEF v REY EPSTEIN, Plaintiff, SCOTT ROTHSTELN, individually, BRAD I LEY J. EDWARDS, individually, and individually, Defendant, 1 IN THE CIRCUIT COURT OF THE FI

, EPSTEIN alleges that EDWARDS engaged in discovery without "leg timate purpose" by asking three of EPSTEIN's jet pilots about sexual activities on EPS1TEIN's aircraft. Second Amended Complaint at I 32(1). To defend against this allegation, ED .WARDS is now entitled to ask EPSTEIN whether he was sexually

AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408003OOOOvIBAG DEFENDANT/COUNTER-PLAINTIFF, BRADLEY J. EDWARDS, RESPONSE IN dPPOSITION TO JEFFERY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER RBLATING TO HIS DEPOSITION AND IN SUPPORT OF EDWARDS' MOTINO TO COMPEL AND IMPOSE SANCTIONS j Defendant/Counterplai

effrey Epstein's (hereinafter EPSTELN) motion for a protective orde[ and to terminate his deposition. The motion is ffivolous and should be denied. EPSTEIN has filed a Complaint against EDWARDS that alleges that EDWARDS filed lawsltits making "unfounded . . . sexual allegations" and pleading "a causc of

in opposition to Plan tiff/Counterdefendant, Jeffrey Epstein's (hereinafter EPSTELN) motion for a prot

aim. I want to know about the connection between Mr. Epstein and each one of those alleged victims. I want to

iate, state and federal law. These RICO claims alleged that it was no accident that young girls like his clients L. , E.W. and Jane Doe ended up in EPSTE1N's mansion where he sexually abused them. Inst d, the RICO claims contended that EPSTEIN ran an entire criminal organization that was desiLn ed to s

plaintiff's answers can be used against him through adverse inferences. See, e.g , In re J.E.B., 971 So.2d 187, 188 (Fla.App. 2 Dist. 2007) (citing Baxter v. Palmigiano, 425 U.S. 308 (1976) ("[T]he Fifth Amendment does not forbid adverse inferences against parties to civ I actions when they refuse to testify in res

rth is in the hundreds of millions of dollars - if not, indeed, a billion dollars. See, e.g., New York Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionaires became a billionaire himself, left his estate on Little St. James Island, with its staff of 70 and its fl

ant PLAINTIFF, JANE DOE'S MOTION FOR INJUNCTION RESTRAINING FRAUDULENT TRANSFER OF ASSETS, APPOINTMENT OF A RECEIVER TO TAKE CHARGE OF PROPERTY OF EPSTEIN, AND TO POST A $15 MILLION BOND, TO SECURE POTENTIAL JUDGMENT COMES NOW Plaintiff Jane Doe, by and through undersigned counsel, and hereby files t

IS ASSETS. As noted in the material facts above, defendant Epstein is currently making fraudulent transfers of his

ork Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionair

ork Time, July 1, 2008, at A2 ("Over the weekend Jeffrey E. Epstein, who after years of advising billionaire

#23. 14. Epstein has blocked all discovery, in this and other related cases, regarding his assets. Affidavit of Paul Cassell at ¶¶ 7, 8. ARGUMENT I. EPSTEIN IS FRAUDULENTLY TRANSFERRING HIS ASSETS. As noted in the material facts above, defendant Epstein is currently making fraudulent transfers of his as

e to permit an adverse inference to be drawn from exercise of the privilege does not implicate the policy considerations underlying the privilege." Baxter v. Palmigiano, 425 U.S.308, 335 (1976). An adverse inference is entirely justified in this case. Epstein has remained silent when asked such straightforward requ

egan speaking with the agents and then excused herself to go upstairs to check on her sleeping child. While upstairs, Ms. telephoned the defendant, Jeffrey Epsteiriand informed him that the FBI agents were at her home. Mr. Epstein instructed Ms= not to speak with the agents and reprimanded her for allowing them i

ing specific facts as the undisputed material facts in this case. Each of the following facts is numbered separately and individually to facilitate Epstein's required compliance with Fla. R. Civ. P. 1.510(c) ("The adverse party shall identify . . . any summary judgment evidence on which the adverse part

. P. 1.510(c) ("The adverse party shall identify . . . any summary judgment evidence on which the adverse party relies."). Sexual Abuse of Children Dv Epstein 1. Defendant Epstein has a sexual preference for young children. Deposition of Jeffrey Epstein, Mar. 17, 2010, at 110 (hereinafter "Epstein Depo."

lot of fun to be with. It is even said that he likes beautiful women as much as I do, and many of them are on the younger side. No doubt about it -- Jeffrey enjoys his social life." Jeffrey Epstein: International Moneyman of Mystery; He's pals with a passel of Nobel Prize—winning scientists, CEOs like

ies."). Sexual Abuse of Children Dv Epstein 1. Defendant Epstein has a sexual preference for young children. Depos

unediate family that I send drafts to is Jeffrey" The Talented Mr. Epstein, By Vicky Ward on January, 2005 in Published Wor

does not forbid adverse inferences against parties to civil actions when they refuse to testify in respqmLwprobative evidence offered against them." Baxter v. Palmigiano, 425 U.S. 308, 318 (1976); accord v. State, 777 So.2d 1200, 1203 (Fla. App. 2001). The reason for this rule "is both logical and utilitarian. A pa

ne issue as to any material facts and that Bradley J. Edwards, Esq. is entitled to summary judgment for all claims brought against him in Plaintiff Jeffrey Epstein's Complaint. Not only is there an absence of competent evidence to demonstrate that Edwards participated in any fraud against Epstein, the evidence un

intiff Jeffrey Epstein's Complaint. Not only is there an absence of competent evidence to demonstrate that Edwards participated in any fraud against Epstein, the evidence uncontrovertibly demonstrates the propriety of every aspect of Edwards' involvement in the prosecution of legitimate claims against E

inafter "Epstein Depo.") at 67-68. Therefore summary judgment should be granted for Edwards on all claims involving any Ponzi scheme by Rothstein. b. Epstein Did Not Suffer Any Harm from Allegedly Fraudulent Presentations to Investors. 7 EFTA00725975 At various points in his Complaint, Epstein seems t

, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION FOR SETTLEMENT CONFERENCE, OR IN THE AL

Y, FLORIDA Case No.: 50 2009 CA 0408003OOOCMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

not forbid adverse inferences against parties to civil actions when they refuse to testify in response to probative evidence offered against them." Baxter v. Palmigiano, 425 U.S. 308, 318 (1976); accord Vasquez v. State, 777 So.2d 1200, 1203 (Fla. App. 2001). The reason for this rule "is both logical and utilitarian

mmary judgment in the Ponzi Scheme Action. SJ Motion at 1 (Edwards "is entitled to summary judgment for all claims brought against him in Plaintiff Jeffrey Epstein's Complaint" because "the evidence uncontrovertibly demonstrates the propriety of every aspect of Edwards' involvement in the prosecution of legitimat

alternative sources before it may be subpoenaed from any non-party in New York. In fact, Edwards concedes in his own Florida court filings that the Epstein interview is, at best, cumulative of "overwhelming evidence" he has already obtained from several alternative sources. Second, even if Edwards were

made of a confidential unpublished interview of Jeffrey Epstein. PRELIMINARY STATEMENT In this ancillar

d not, publish the information imparted to me by Mr. Epstein during the interview. Rush Supp. Aft 17 (emphasi

unds, 44.3d 324, 843 =2d 218 (1st Dep't 2007) 15 Associated Gen. Contractors of Conn., Inc. v. City of New Haven, 41 F.3d 62 (2d Cir. 1994) 13 Baxter v. Palmigiano, 425 U.S. 308 (1976) 21 Buttner v. Berg & Dorf, 138 ad 439, 525 MI.2d 858 (2d Dep't 1988) 19 Branzburg v. Hayes, 408 U.S. 665 (1972) 23 Bro