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

rn District of Florida 15. Records Custodian of the Federal Bureau of Investigations 16. Spencer Kuvin, Esquire 17. Theodore Leopold, Esquire 18. Rinaldo Rizzo 19. Adam Horowitz, Esquire 20. Isidro M. Garcia, Esquire 21. All of the Lawyers who Represented Victims of Jeffrey Epstein. This is so overbroad th

limit, yet her proposed depositions are not calculated to lead to admissible evidence in this case. By way of example, Plaintiff identifies ), and Jeffrey Epstein as alleged "co-conspirators" with each other. She requests the depositions of each. Plaintiff anticipates each will invoke the Fifth Amendment — in

harassing questions Plaintiff posed to her concerning her adult, consensual sexual activities. In other words, depositions of Marcincova, Kellen and Epstein would serve Plaintiff's goal to make a convoluted legal argument, not to actually seek discoverable information. In light of this, the "burden or e

UMPTIVE TEN DEPOSITION LIMIT Laura A. Menninger Jeffrey S. Pagliuca HADDON, MORGAN, AND FOREMAN, P.C. E

and (identified as assistants to Ms. Maxwell or Mr. Epstein). The information Plaintiff claims each of the wi

above, such invocation has no bearing on the issues in this matter. Moreover, it is obviously cumulative and duplicative. Plaintiff also identifies Rinaldo Rizzo and Jean Luc Brunel but fails to provide any information from which Ms. Maxwell or the Court could identify the subject matter of their expected te

Memo Re: Jeffrey Epstein Background Premise Jeffery Epstein is a

Memo Re: Jeffrey Epstein Background Premise Jeffery Epstein is a Tier 3 registered sex offender with residences in the United States Virgin Islands, New York, New Mexico,

Epstein to all agencies to whom he is required to report under federal and state law. Obtain FAA flight information on his planes and helicopters. Epstein's Gulfstream (Make G 1 1 Model 59B) had Tag N908JE and now has Tag N909JE. Epstein's Boeing (B72731) had Tag N908JE and his Cessna (C421B) had Tag

ive American Healer) — Provides girls for Epstein Francis Peadon — (Palm Beach house keeper) These are people who are believed will remain loyal to JE during any criminal investigation. Individuals Who Have Engaged in Massages with Epstein Girls Frederic Fekkai Jes Staley Glen Dubin Important

FTA00098757 Victims Not Identified in the NPA People with Information Regarding Crimes Committed Outside Florida and Not Covered by the NPA "en Rinaldo Rizzo (New York) Former Employee of Glenn Dubin with knowledge of Epstein underage activity Igor Zinoview (Former Bodyguard in New York) Not loyal to E

E OF CONTENTS INTRODUCTION 1 BACKGROUND 3 LEGAL AUTHORITY 5 I. PLAINTIFF'S LACK OF DILIGENCE 6 6 B. Ross Gow 9 C. Jean Luc Brunel 10 D. Jeffrey Epstein 12 E. and 14 II. FIFTH AMENDMENT BY EPSTEIN, OR NOT ADMISSIBLE IN THIS CASE AGAINST MS. MAXWELL 15 III. PLAINTIFF'S BAD FAITH DISCOVER

5 I. PLAINTIFF'S LACK OF DILIGENCE 6 6 B. Ross Gow 9 C. Jean Luc Brunel 10 D. Jeffrey Epstein 12 E. and 14 II. FIFTH AMENDMENT BY EPSTEIN, OR NOT ADMISSIBLE IN THIS CASE AGAINST MS. MAXWELL 15 III. PLAINTIFF'S BAD FAITH DISCOVERY TACTICS SHOULD NOT BE REWARDED WITH EXTRA TIME 18

ONS FOR VIOLATION OF RULE 45 Laura A. Menninger Jeffrey S. Pagliuca HADDON. MORGAN, AND FOREMAN, P.C. E

hat deposition in the Virgin Islands. Last week, Mr. Epstein's counsel filed a Motion to Quash his deposition

26 disclosures served on November 11, 2015 and two of the six were specifically mentioned in Plaintiff's Complaint. Finally, the fact that witness Rinaldo Rizzo had a deposition re-scheduled from April until June does not have any bearing on the issue presented by this motion. Mr. Rizzo was deposed on June

ed Testimony of Tony Figueroa Volume 2 September 8, 2016 Designated Testimony of Brittany Henderson (M) September 9, 2016 Designated Testimony of Jeffrey Epstein (Exs. 1-6, 8) November 18, 2016 Designated Testimony of Ross Gow (Exs. 1-26) December 1, 2016 Designated Testimony of (Exs. 5-6, 9, 14) January

rson September 9, 2016 Exhibits 1-11 to Jeffrey Epstein Deposition November 14, 2016 Exhibits 1-20 to D

ny Henderson September 9, 2016 Exhibits 1-11 to Jeffrey Epstein Deposition November 14, 2016 Exhibits 1

ition of Dr. Steven Olson June 1, 2016 Deposition Transcript of Juan Alessi June 3, 2016 Deposition of David Rodgers June 10 2016 De osition of Rinaldo Rizzo June 20 2016 Deposition of June 21, 2016 Deposition of Joseph Recarey June 23, 2016 Deposition of James Austrich June 24, 2016 Deposition of

ny Henderson September 9, 2016 Exhibits 1-11 to Jeffrey Epstein Deposition November 14, 2016 Exhibits 1-20 to D

rson September 9, 2016 Exhibits 1-11 to Jeffrey Epstein Deposition November 14, 2016 Exhibits 1-20 to D

ny Henderson September 9, 2016 Exhibits 1-11 to Jeffrey Epstein Deposition November 14, 2016 Exhibits 1

ition of Dr. Steven Olson June 1, 2016 Deposition Transcript of Juan Alessi June 3, 2016 Deposition of David Rodgers June 10, 2016 De sition of Rinaldo Rizzo June 20, 2016 Deposition of June 21, 2016 Deposition of Joseph Recarey June 23, 2016 Deposition of James Austrich June 24, 2016 Deposition of

ecruitment of girls, including minors, for the purpose of sexual abuse. Plaintiff claims she was a minor when she was recruited by Defendant over to Jeffrey Epstein's house. Plaintiff further alleged that Defendant and Epstein commonly lured females to Jeffrey Epstein by telling them they would be paid for giving

Plaintiff claims she was a minor when she was recruited by Defendant over to Jeffrey Epstein's house. Plaintiff further alleged that Defendant and Epstein commonly lured females to Jeffrey Epstein by telling them they would be paid for giving a massage to Epstein; however, once at Epstein's house Plain

1-7364 Fax: 303-832-2628 [email protected] Jeffrey Pagliuca: Haddon Morgan and Foreman, P.C. 150 E

icating whether such witness will testify in person or by deposition: Plaintiff's Statement: 1. Daniel Wilson (live) 2. (video) 3. (live) 4. Rinaldo Rizzo (live) 5. Tony Figueroa (video) 6. (live) 7. (live) 8. (video) 9. (video) 10. Detective Recarey (video) 11. Alexander Hall (voice recor

witnesses that Defendants have listed on their Witness List not objected to by Plaintiff, Jane Doe. 151. All rebuttal witnesses. 152. All People on Jeffrey Epstein's Inmate Visitor Log while he was in jail. WITNESS TESTIMONY EXPECTED TO BE PRESENTED BY MEANS OF DEPOSITION 153' Mark Epstein 30 VANDAM STREET NEW

s Boulevard West Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: 561-383-9451 Attorneys for Bradley J. Edwards EFTA00798039 EDWARDS ADV. EPSTEIN Case No.: 502009CA040800XXXXMBAG Notice of Serving Answers to Interrogatories COUNSEL LIST William Chester Brewer, Esquire [email protected]; wcbla

OUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, in

ll also confirm the leadership role played by Edwards in the prosecution of civil claims against Epstein and the propriety of Edwards' actions. 21. Rinaldo Rizzo do Robert Lewis 228 East 45th Street I 17th Floor New York, NY 10017 2-3 Expected to testify about the malicious prosecution elements of absence

ecruitment of girls, including minors, for the purpose of sexual abuse. Plaintiff claims she was a minor when she was recruited by Defendant over to Jeffrey Epstein's house. Plaintiff further alleged that Defendant and Epstein commonly lured females to Jeffrey Epstein by telling them they would be paid for giving

Plaintiff claims she was a minor when she was recruited by Defendant over to Jeffrey Epstein's house. Plaintiff further alleged that Defendant and Epstein commonly lured females to Jeffrey Epstein by telling them they would be paid for giving a massage to Epstein; however, once at Epstein's house Plain

l: Defendant's Trial Counsel: Laura Menninger: Jeffrey Pagliuca: Haddon, Morgan and Foreman, P.C. 150

icating whether such witness will testify in person or by deposition: Plaintiff's Statement: 1. Daniel Wilson (live) 2. (video) 3. (live) 4. Rinaldo Rizzo (live) 5. Tony Figueroa (video) 6. (live) 8. (video) 9. (video) 10. (video) 11. (voice recording) 12. Jean Luc Brunel (live) 13. Jeff