3
Shared Docs
3
Same-Page
7 / 3
Mentions
not "to ascertain the facts and fairly present [Edwards'] defenses." Id. 6 For example, Edwards' counsel asked Plaintiff whether he socialized with Donald Trump in the presence of women under the age of 18. Plaintiff responded by invoking his right against self-incrimination. (Plaintiff at 89). Plaintiff a
he noticed Bill Clinton, Alan Dershowitz, Donald Trump, David Copperfield and Bill Richardson for depos
to why he noticed Bill Clinton, Alan Dershowitz, Donald Trump, David Copperfield and Bill Richardson for
btain summary judgment. Third, Edwards has not demonstrated the absence of material issues of fact. His alleged participation in and/or knowledge of the Rothstein Ponzi scheme and the validity of, and motivation in conducting, the discovery at issue in the underlying Epstein actions are matters of considerable deba
they are recovered from Edwards or Rothstein. It is Edwards' abusive litigation (i.e., deposition notices for President Clinton and now President Trump) that generated materials for Rothstein to use to defraud investors in the Ponzi scheme. It was Epstein's costs in the defense of that abusive liti
E.W., and Jane Doe VIA U.S. MAIL The Honorable Donald W. Hafele Palm Beach County Courthouse 205 N. D
deposition notices for President Clinton and now President Trump) that generated materials for Rothstein to use to
aim against both Rothstein and Edwards) in connection with the use of Epstein case materials, which were improperly utilized to lure investors into the Rothstein Ponzi scheme is clearly and irrefutably related to Edwards' counterclaim against Epstein for filing that original claim. Yet, to mislead this Court into
his 5 Tlay ,Pattet. (74) of Becent&T, 20, TH DONALD W. HAFELE CIR T CO UDGE SERVICE LIST Jack Sc
Tort Claimants and possibly others. Epstein denies this motivation EFTA00805158 and maintains his probable cause was grounded in media reports of the Rothstein Ponzi scheme and the realization of the possible connection for Edwards' litigation behavior unrelated to the claims of his three clients. Court's Rulin
Entities connected to both Donald Trump and the Rothstein Ponzi

Jeffrey Epstein
PERSON
Prince Andrew
PERSON
George W. Bush
PERSON
Bill Clinton
PERSON
Ghislaine Maxwell
PERSON
Bradley Edwards
PERSON
Barry Diller
PERSON
Alfredo Rodriguez
PERSONJack Goldberger
PERSONJane Doe
PERSON
Las Vegas
LOCATIONScott Rothstein
PERSONJack Scarola
PERSON
Lauderdale
LOCATIONMarc S. Nurik
PERSONPalm Beach Lakes Boulevard
LOCATIONGoldberger & Weiss
ORGANIZATIONFlorida Bar
ORGANIZATION
Scott J. Link
PERSON
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATION