Epstein Secrets

ENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, vs. Plaintiff/Counter-Defendant, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OMNI

EFTA00585430 142. All pleadings filed by Epstein in the Rothstein Bankruptcy Proceeding. 143. All submissions by Epstein in connection with the Rothstein deposition. 144. All Settlement Agreements between Epstein and victims of his sexual molestations. 145. Phone journal taken from Epstein's home a

DCA 1988) (holding that an opinion of a witness concerning his or her belief as to the truthfulness of another witness "was clearly inadmissible."); Morrison v. State, 818 So.2d 432, 451 (Fla.2002) (holding that it was improper to allow personal opinion to establish reputation for truthfulness without la

Esq. Brad Edwards, Esq. Adam D. Horowitz, Esq. Rothstein Rosenfeldt Adler Mermelstein & Horowitz, P.A. 4

ike that, so. §ee Excerpts of Deposition of Larry Eugene Morrison at 135-36; 175-76; 184 (attached as composite Exhibit B). 8. Again, whether Mr. Morrison would work for Mr. Epstein "considering what [he has] read and what [he] may or may not believe" (i.e. considering hearsay media accounts and inadm

rter 17 &ch. FL 33401 16 19 20 21 22 23 24 25 2 4 1 APPEARANCES OF COUNSEL 1 INDEX OF EXAMINATION e I On banal a the Flambe L.M.. ROTHSTEIN. 110SENFELDT a ADLER 2 BY: BRADLEY J. EDWARDS. ESO. 3 WITNESS: 4 111X1MICHAEL WHEELER. ESO.. 4 LARRY EUGENE MORRISON 401 East Las OHS 130.40

ged. 6 MR. EDWARDS: It's privileged between Mr. 7 Epstein and you, but is it privileged between 8 the two Of you? 9 MR. REINHART: Between Mr. Morrison and 10 me. 11 BY MR. EDWARDS: 12 O. Is it your understanding that he represents 13 you or he represents Mr. Epstein? 14 A. He represents me

CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, Vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, / DEFENDANT/COUNTER-PLAINTIFF’S RESPONSE IN OPPOSITION TO PLAIN

laint he carries forth the essence of all claims asserted in his original Complaint. In that pleading Epstein essentially alleges that Edwards joined Rothstein in the abusive prosecution of sexual assault cases against Epstein to “pump” the cases to Ponzi scheme investors. The purported “proof” of the allega

Rothstein falsely informed the investors that the potential settlement agreements were available for purchase. Plea Agreement at 2, United States v. Scott W. Rothstein, No. 9-60331-CR-COHN (S.D. Fla. Jan. 27, 2010) attached hereto as Exhibit “SS.” 87. It has been alleged that among other cases that Rothstein used t

as a possible witness because Epstein’s personal pilot testified to Richardson joining Epstein at Epstein’s New Mexico Ranch. See deposition of Larry Morrison, October 6, 2009, at 167-169. There was information indicating that Epstein had young girls at his ranch which, given the circumstances of the case,

at I had filed on behalf of my clients against Epstein and that it has been alleged that these lawsuits were used to fraudulently lure investors into Rothstein’s Ponzi scheme. I never met a single investor, had no part in any such presentations and had no knowledge any such fraud was occurring. If these alle

as a possible witness because Epstein’s personal pilot testified to Richardson joining Epstein at Epstein’s New Mexico Ranch. See deposition of Larry Morrison, October 6, 2009, at 167-169. There was information indicating that Epstein had young girls at his ranch which, given the circumstances of the case,

information to prove the cases against Jeffrey Epstein and accordingly I pursued them in discovery. In approximately November 2009, the existence of Scott Rothstein’s Ponzi scheme became public knowledge. It was at that time that I, along with many other reputable attorneys at RRA, first became aware of Rothstein c