Epstein Secrets

dant, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OMNIBUS MOTION IN LIMINE Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, herein moves for an Orde

er-Plaintiff, JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OMNIBUS MOTION IN LIMINE Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, herein moves for an Order in Limine precluding Defendant/Counter-Plaintiff Bradley Edwards ("Edwards") a

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

laintiff has no evidence, nor can he prove, that Mr. Epstein lacked probable cause at the time he filed his l

his litigation. See Deposition Transcript of Jef•ey Epstein. When Edwards's inquiry turned to questions rega

ards is the only alleged victim in this case. 6 Tonja Haddad, P.A. • 315 SE 7d. Street, Fort Lauderdale, FL 33301• EFTA00585425 57. Expert Dr. L. Dennison Reed's Report of Victim. This is so overbroad that Epstein cannot possibly make a determination as to whether or not he seeks to exclude anything under th

Epstein and MC2 or any modeling agencies 27. Yearbooks of plaintiff, Jane Doe 28. 29. 30. 31. Affidavit and Application for Search Warrant on Jeffrey Epstein's home EFTA00728818 PLAINTIFF DOE. EXHIBIT LIST CONTINUATION Do* vs. Epstein —CASE NO. 08-CV-10393-CIV-MARRAUOHNSON DEF. NO. PLF. NO. DATE OF

laves and Their Owners" 6. Non-Prosecution Agreement 7. Jane Doe 102 Complaint EFTA00728817 PLAINTIFF DOE. EXHIBIT LIST CONTINUATION Dos vs. Epstein - CASE NO. 08-CV-501393•CIV-MARRAMOHNSON DEF. NO. PLF. NO. DATE OFFERED MARKED ADMITTED DESCRIPTION OF EXHIBITS 8. Messages taken from mes

N DISTRICT OF FLORIDA JANE DOE, Plaintiff Vs. JEFFREY EPSTEIN, ct al. Defendant. Related Cases: CASE

r evidencing Jeffrey Epstein's donations to law enforcement 56. Victim Notification Letter from US Attorney's Office to Plaintiff 57. Expert Dr. L. Dennison Reed's Report of Plaintiff 58. Palm Beach Police Department Incident Report dated 4/20/06 59 All reports and documentation generated by Palm Beach Polic

nformation from Epstein's criminal case and prior civil cases; not one of which is an abuse of process or malicious prosecution case. 4. Video of Jeffrey Epstein's home and route from victim to Epstein's home 9. Documents related to Jeffrey Epstein produced by Alfredo Rodriguez 11. Jeffrey Epstein phone reco

N LIMINE TO PRECLUDE AT TRIAL THE USE OF THE FOLLOWING ITEMS LISTED ON EDWARDS'S REVISED EXHIBIT LIST Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel moves for an Order in Limine precluding Defendant/Counter- Plaintiff Bradley Edwards ("Edwards") and his C

UNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, JUDGE: D

o or evidencing Jeffrey Epstein's donations to law enforcement 56. Victim Notification Letter from US Attorney's Office to Victim 57. Expert Dr. L. Dennison Reed's Report of Victim 59. All reports and documentation generated by Palm Beach Police Department related to Jeffrey Epstein EFTA00598333 60. All W