Epstein Secrets

IN, Plaintiff/Counter-Defendant, Case No. 50 2009 CA 040800XXXXMBAG v. BRADLEY J. EDWARDS, et al., Defendants/Counter-Plaintiff. JUDGE: HAFELE JEFFREY EPSTEIN'S RESPONSE TO BRADLEY EDWARDS'S MOTION IN LIMINE TO STRIKE THE JUNE 30.2017 AFFIDAVIT OF JEFFREY EPSTEIN AND TO EXCLUDE EVIDENCE AS TO WHICU DISCOVE

JEFFREY EPSTEIN AND TO EXCLUDE EVIDENCE AS TO WHICU DISCOVERY WAS WITHHELD UNDER CLAIMS OF PRIVILEGE Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, hereby files his Response to Defendant/Counter-Plaintiff Bradley Edwards's ("Edwards") Motion in Limine

DICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FL JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No.

millions of dollars. Q. And trying to find out, Mr. Epstein, whether you have any evidence whatsoever that

and 6 generate cases. See Deposition of Jeffi•ey Epstein, p. 28; line13-p. 29; line 6. BY MR. SCAROLA: Q

dence [is] substantially outweighed by the danger of unfair prejudice" to the party asserting the privilege. Id. at 1266 (citing Fed. R. Evid. 403; Brink's Inc. v. City of New York, 717 F.2d700, 710 (2d Cir. 1983)). Moreover, the inference may be drawn only when there is independent evidence of the fact abo

pursuant to Fed. R. Civ. Proc. 26(c)( I). PRELIMINARY STATEMENT Plaintiff Jane Doe has failed to carry her burden of showing that anything on the Epstein interview tape sought through the subpoenas challenged here may be compelled from movants under either the reporter's privilege recognized in this

prove perjury (a federal crime) on the part of Epstein." Edwards then cites a deposition transcript, without providing the relevant pages, "wherein Jeffrey Epstein clearly impresses that he does not recognize George Rush from the New York Daily News." Offering this as a "criminal event," Edwards states that, "[

on PACER. S.D. Fla. Civil Docket for Jane. Doe v. Jeffrey Epstein. Case # 9:08-cv- 80893-KAM ("Docket"), DE

on that any of those people . . . have spoken to Mr. Epstein about Jane Doe or any of the other specific victi

aut Ins. Co. 757 F.2d 523 (2d Cir. 1985) 12 Best Canvas Products & Supplies. Inc. v. Ploof Truck Lines. Inc., 713 F.2d 618 (II th Cir. 1983) 12 Brink's Inc. v. City of New York 717 F.24 700 (2d Cir. 1983) 7 Drown & Williamson Tobacco Coro. v. Wigand, No. 101678/96, 1996 WL 350827 (N.Y. Sup. Ct. Feb. 2

ve Order pursuant to Fed. R. Civ. Proc. 26(c)( I). PRELIMINARY STATEMENT Plaintiff has failed to carry her burden of showing that anything on the Epstein interview tape sought through the subpoenas challenged here may be compelled from movants under either the reporter's privilege recognized in this

prove perjury (a federal crime) on the part of Epstein." Edwards then cites a deposition transcript, without providing the relevant pages, "wherein Jeffrey Epstein clearly impresses that he does not recognize George Rush from the New York Daily News." Offering this as a "criminal event," Edwards states that, "[

found on PACER. S.D. Fla. Civil Docket for ME v. Jeffrey Epstein, Case # 9:08-cv- 80893-KAM ("Docket"), DE

on that any of those people . . . have spoken to Mr. Epstein about or any of the other specific victims," Edw

aut Ins. Co. 757 F.2d 523 (2d Cir. 1985) 12 Best Canvas Products & Supplies. Inc. v. Ploof Truck Lines. Inc., 713 F.2d 618 (II th Cir. 1983) 12 Brink's Inc. v. City of New York 717 F.24 700 (2d Cir. 1983) 7 Drown & Williamson Tobacco Coro. v. Wigand, No. 101678/96, 1996 WL 350827 (N.Y. Sup. Ct. Feb. 2