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

DCA 2009). Moreover, any mention of or use of information from any other case is absolutely improper, as such information is unfairly prejudicial. Honeywell Intern., Inc. v. Guilder, 23 So. 3d 867 (Fla. 3d DCA 2009); Long Term Care Found., Inc. v. Martin, 778 So. 2d 1100, 1102-03 (Fla. 5th DCA 2001) (allegatio

ter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' REQUEST FOR JUDICIAL NOTICE Plaintiff/Counter-Defendant, Jeffrey Epstein ("

RESPONSE IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' REQUEST FOR JUDICIAL NOTICE Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), responds in opposition to the Request for Judicial Notice Pursuant to Florida Statutes Section 90.202 and 90.203 dated December 4, 2017 [D.E. 11

UNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

ds did not represent is absolutely improper, as such evidence has no bearing on the malicious prosecution Counterclaim and is unfairly prejudicial. Honeywell Intern., Inc. v. Guilder, 23 So. 3d 867 (Fla. 3nd DCA 2009); Long Tenn Care Found., Inc. v. Martin, 778 So. 2d 1100, 1102-03 (Fla. 5th DCA 2001) (allegati

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

is germane to the issues in this case, any mention of or use of information from any other case is not. Such information is unfairly prejudicial. Honeywell Intern., Inc. v. Guilder, 23 So. 3d 867 (Fla. 3d DCA 2009). As seen from Edwards's trial exhibit list items above, it is apparent that he intends to use as