Epstein Secrets

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

judgment is proper as a matter of law. See Davis v. Hathaway, 408 So. 2d 688, 689 (Fla. 2d Dist. Ct. App. 1982); see also Holl, 191 So. 2d at 43. B. Epstein's Claims Regarding Edwards Have Absolutely No Factual Basis. 5 EFTA00725973 This is not a complicated case for granting summary judgment. To the co

WAIVED ANY PRIVILEGE THAT IT MIGHT OTHERWISE POSSESS 5 11. THE QUALIFIED JOURNALIST PRIVILEGE IS OVERCOME BY EDWARDS' COMPELLING NEED TO OBTAIN JEFFREY EPSTEIN'S OWN WORDS ABOUT HIS SEXUAL ABUSE OF MINOR GIRLS AND HIS LACK OF REMORSE 8 A. Edwards Needs Epstein's Own Words to Defend Against Epstein's Civil

Damages 8 B. Epstein's Statements Are Not Available from Any Other Source CONCLUSION 12 EFTA00729036 TABLE OF AUTHORMES Cases Doe No. 102 v. Epstein, No. 9:09-CV-80656-KAM (S. D. FIa. 2009) 4 Altemose Constr. Cot v. Building & Constr. Trades Council, 443 F. Supp. 489 (ED. Pa. 1977) 7 Flores

S OVERCOME BY EDWARDS' COMPELLING NEED TO OBTAIN JEFFREY EPSTEIN'S OWN WORDS ABOUT HIS SEXUAL ABUSE OF MI

le sources" since "the record is quite clear that Mr. Epstein has regularly been asserting, and will continue

A. Edwards Needs Epstein's Own Words to Defend Against Epstein's Civil Suit and to Pursue his Counterclaim for Compensatory and Punitive Damages 8 B. Epstein's Statements Are Not Available from Any Other Source CONCLUSION 12 EFTA00729036 TABLE OF AUTHORMES Cases Doe No. 102 v. Epstein, No. 9:09-CV-80

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:

ated by the Court, that the depositions be needed "solely" as a result of a recent ruling, and the Motion should be denied on those grounds alone. B. Epstein's Prior Counsel Failed to Set L.M. and Jane Doe's Depositions, Despite Requesting and Receiving Dates for Their Depositions in August 2017. 7. The M

, FJW on behalf of LM states as follows: I. BACKGROUND A. The Pending Summary Judgment and Protective Order Motions As this Court is well aware, Jeffrey Epstein (a convicted sex offender) has sued one of his alleged victims, ■ as well as attorney, Bradley J. Edwards, Esq.', in Florida state court for cond

rds, Esq.', in Florida state court for conduct that allegedly occurred in the course of Edwards' representation of multiple young female victims of Epstein's sexual abuse. While an employee of the now defunct Rothstein, Rosenfeldt, Adler firm and with his current firm, Edwards filed and pursued civil la

ctive Order Motions As this Court is well aware, Jeffrey Epstein (a convicted sex offender) has sued one o

nkruptcy Court. That Motion is set for hearing for January 27, 2011. A Notice of Filing containing that Motion was filed with this Court [DE 1197]. B. Epstein's Attempts to Involve this Court in the State Litigation Despite that summary and protective order motions are pending in state court, Epstein contin