Epstein Secrets

r 15, 2017 VIA E-MAIL Bradley J. Edwards Edwards Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33401 RE: Jeffrey Epstein v. Scott Rothstein and Bradley J. Edwards 15'h Judicial Circuit Case No. 50-2009CA0408001OOOCMBAG Dear Jack and Brad: Our client has watched the video of Brad's depo

o with if probable cause existed at the time of the filing of the Complaint. Brad confirmed that in November 2009 there were news reports about Mr. Rothstein's Ponzi scheme, the Ponzi scheme was tied to real and alleged cases against Mr. Epstein and that Mr. Rothstein had access to and used Brad's files

result in Brad having to file personal bankruptcy. In light of the testimony given by Brad at his recent deposition, the speculative nature of Dr. Jansen's expert report, and the exorbitant amount Brad is seeking, our client has reevaluated his position and has now authorized us to offer Brad a "walk

EENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO STRIKE

heme singled Mr. Edwards out from among all other innocent RRA employees. Those accusations were the only source falsely linking Bradley Edwards to Rothstein's criminal enterprise, and absent those allegations there is no basis to believe that Bradley Edwards' impeccable professional reputation would hav

would be reversible error. Edwards' Expert is a Defamation Expert. Not a Malicious Prosecution Expert The error is compounded by the fact that Dr. Jansen's testimony is focused on defamation per se, without regard to the actual damages proximately caused by the malicious prosecution (if any). Edwards

TEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO R

a consequence of the filing of this false lawsuit making up that I am a criminal associated with who is known to be a terrible and horrible person [Rothstein]." (Edwards' 11/10/17 Tr. 23:5-16.) ("[M]y reputation ... suffered damages that, unless and until a jury returns a verdict in my favor, can't be un

dwards' 11/10/17 Tr. 22:5-17.) To the contrary, however, Edwards' counsel has stated that he was successful in discrediting Epstein's allegations. (Jansen's 12/1/17 Tr. 62:24-25.)2 In addition, Edwards himself testified that his reputation has been "resurrected" and is "better than it has been": "With

Ponzi Scheme Money Was Spent hrip://miami.cbslocalcomr2011il2+30/rodistein-reveals-how-l-2-billion- porin-scheme-money-was-spent: The Ultimate Ponzi: Scott Rothstein Book Excerpts Reveal Juicy Details httpsurAvww.huffingtonpost.comr2Ol3103/I2fscott-rothstein-book-the-ultimate-ponzi_n_2862093.html; Scott Rothstein's Ch

wsuit against Mr. Edwards? 3 EFTA00601579 10. For brevity, I refer to the statements associating Mr. Edwards with the illegal activities of Mr. Rothstein as a result of Mr. Epstein's lawsuit as the defaming statements, the statements, or the defaming statements associating Mr. Edwards with Rothstein's

2016 President's Award for Engagement with Students, The Pennsylvania State University, University Park, Pennsylvania. 2015 Best Paper: Liu, Z. and Jansen, B.J. (2015) Subjective versus Objective Questions: Perception of Question Subjectivity in Social Q&A. 2015 International Conference on Social Comp

KR. SCAROLA: May I now to this podium now? JEFFREY EPSTEIN, biaintirs/countor -Defendant, vs 4 THE CO1RT: Sure. 'at. SCAROLA: Thank you, sir. SCOTT ROTHSTEIN, individually; • Your 110nOr, have we decided what notions were BRADLEY EDWARDS, individually, , going to hoar? boranciants/countor -Plaintiffs

ng CO your Honor that 12 during a very CUTUICUOUSI period of CIAO these would I) the first notice we got of an Intent CO attempt. to to be the Rothstein fines, erployee. 14 use chose documents was March S. The first notice 14 KR. SMOLA: Yes, air. Let ne go through IS wo got of an intent CO attem

. I don't 2 KR. BURLIAVTON: Your Honor, it's his action. 3 think there's another set of files somewhere. 3 KR. SCAMLA: The notion to ➢trite Dr. Jansen. 4 Fowler White had asked me to return them once we 4 THE COURT: All right. 5 went through them, and if the Court can instruct me s MR. BURLIA

KR. SCAROLA: May I now to this podium now? JEFFREY EPSTEIN, biaintirs/countor -Defendant, vs 4 THE CWRT: Sure. 'at. SCAROLA: Thank you, sir. SCOTT ROTHSTEIN, individually; • Your Honor, have we wowed what notions were BRADLEY EDWARDS, individually, boranciants/countor -Plaintiffs. , 10 going to hoa

ng CO your Honor that 12 during a very CUTUICUOUSI period of CIAO these would I) the first notice we got of an Intent CO attempt. to to be the Rothstein fines, erployee. 14 use chose documents was March S. The first notice 14 KR. SMOLA: Yes, air. Let ne go through IS wo got of an intent CO attem

. I don't 2 KR. BURLIAVTON: Your Honor, it's his action. 3 think there's another set of files somewhere. 3 KR. SCAMLA: The notion to ➢trite Dr. Jansen. 4 Fowler White had asked me to return them once we 4 THE COURT: All right. 5 went through them, and if the Court can instruct me s MR. BURLIA

went well beyond legitimacy and ultimately existed to serve another master, a sinister Ponzi scheme that operated out of Edwards's and co-defendant Scott Rothstein's law firm, Rothstein, Rosenfeldt Adler. As is now well-known, at that law firm, despite what its name implies, the main business was the creation and

and ultimately existed to serve another master, a sinister Ponzi scheme that operated out of Edwards's and co-defendant Scott Rothstein's law firm, Rothstein, Rosenfeldt Adler. As is now well-known, at that law firm, despite what its name implies, the main business was the creation and perpetration of a P

dwards instructed Epstein: Please confirm receipt of the materials provided by Dropbox, and further confirm that these materials, together with Dr. Jansen's report and the information disclosed last week regarding Dr. Jansen, satisfy the expert witness discovery you recently propounded. If there is a

11/8/17 hearing on Motion to Bifurcate based on 1.20 900.00 probable cause and overlapping facts of J. Epstein's abuse of process action against Rothstein in order to remove the "mini-trial" issue 750.00/hr AMM Analyze Volume I of II deposition transcript of B. Edwards (147 3.20 1,264.00 pages) da

2,745.00 225.00/hr EFTA00804041 11/21/2017 TLC Jeffrey Epstein Page 5 Hrs/Rate Amount Notice of Deposition and Subpoena Duces Tecum for Dr. Jansen; follow up with J. Scarola re same; work on trial notebooks 11/14/2017 KBR Work on response to B. Edwards' Request for Judicial Notice; work 6.50

Trial Exhibits 7.50 0.00 03/03/18 SJL Work on Response to Motion to B. Edwards' Compel re Request for Admissions; strategize re default against S. Rothstein and options to proceed with trial or seek to strike trial setting; work on preparations for special set hearings; work on trial preparations 7.30

rgue at all-day special set hearing on J. Epstein's Motion to Strike Matter from Trial Docket, Motion to Sever Trials, Motion to Strike Expert Dr. Jansen, Edwards' Motion to Strike Exhibits, and other issues surrounding the 27,000 page disc of e-mails located in Fowler White's files; follow up with

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

stein ever talked to you 24 or loud enough to which you could hear him discussing the zs modeling agency? 154 A. Jeffrey, -• David Mullen, 2 Jansen. 3 O. Do you know who Jansen Is? 4 A. No. 5 O. David Mullen travels a lot. Do you have any 6 idea what his relationship is with Mr. Epstein?