Epstein Secrets

2010 seeking the similar relief. The grounds for this motion are: 1. Late last year, Epstein filed this action to recover damages from Defendants, Scott Rothstein ("Rothstein") and Edwards, based on Epstein's well founded belief that the two, and possibly others, had perpetrated an illegal pyramid scheme direc

WLER WHITE BURNETT P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA00606624 Epstein v Rothstein, Edwards CASE NO. 502009CA040800=OCMBAG Notice of Hearing PLEASE GOVERN YOURSELVES ACCORDINGLY. In accordance with the Americans With Disabilitie

EFTA00606629 1.) For example, Edwards's attorney instructed him when Edwards was asked how one plaintiff, E.W., came to contact referring attorney Howell. Id. at 89, lines 9-19. Edward's attorney told him he could not even answer the threshold "yes" or "no" question: Did [Mr. Howell] ever relate that

referring attorney Howell. Id. at 89, lines 9-19. Edward's attorney told him he could not even answer the threshold "yes" or "no" question: Did [Mr. Howell] ever relate that to you." Id. 9. Edwards in one instance when asked what his client E.W. told him on the phone, himself claimed privilege. Id. a

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH C

. The topic of the examination next turned to Scott Rothstein and his involvement in the Epstein cases. Counsel for Epstein asks Edwards to discuss Rothstein's general knowledge regarding the Epstein cases, specifically a meeting he attended in Rothstein's office with Russell Adler: Q: Was a question po

nswering. Id. at page 89; lines 4-8. Q: With regard to E.W. you filed a case — well, let me ask you this: Do you know how E.W. come to contact Mr. Howell? Did he ever relate that to you? Id. at page 89; lines 9 -12. MR. SCAROLA: If it's in information that you obtained from your client, I instruct y

R. SCAROLA: If it's in information that you obtained from your client, I instruct you not to answer. If it's information that you obtained from Mr. Howell, I also instruct you not to answer. Both instructions are on the basis of attorney-client and work-product privileges. Id. at page 89; lines 3-19.

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH C

. The topic of the examination next turned to Scott Rothstein and his involvement in the Epstein cases. Counsel for Epstein asks Edwards to discuss Rothstein's general knowledge regarding the Epstein cases, specifically a meeting he attended in Rothstein's office with Russell Adler: Q: Was a question po

nswering. Id. at page 89; lines 4-8. Q: With regard to E.W. you filed a case — well, let me ask you this: Do you know how E.W. come to contact Mr. Howell? Did he ever relate that to you? Id. at page 89; lines 9 -12. MR. SCAROLA: If it's in information that you obtained from your client, I instruct y

R. SCAROLA: If it's in information that you obtained from your client, I instruct you not to answer. If it's information that you obtained from Mr. Howell, I also instruct you not to answer. Both instructions are on the basis of attorney-client and work-product privileges. Id. at page 89; lines 3-19.

EACH COUNTY, FLORIDA CASE NO. 50 2009CA040800XXXXMB AG Complex Litigation, Fla.R.Civ.Pro. 1201 JEFFREY EPSTEIN, Plaintiff, -vs- VOLUME I OF II SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and III. individually, Defendants. VIDEOTAPED DEPOSITION OF BRADLEY J. EDWARDS, ESQUIRE Tuesday

video record. This is Media Number One in the 10 videotaped deposition of Bradley Edwards in the 11 matter of Jeffrey Epstein versus Scott 12 Rothstein, Bradley J. Edwards, and 13 Today is Tuesday, March 23rd, 2010 at 14 10:00 a.m. We're here in the law offices 15 of Searcy, Denney, Scarola, Ba

RA, if those cases had resolved 11 during that time period, RRA, you would have paid 12 RRA that portion to which you were been entitled and 13 Howell and a Cassell would have gotten their 14 percentage? 15 A. Correct. 16 Q. And with regard to, with the new firm, the 17 Farmer, Jaffe firm,

ose cases there was a, 13 there is also another lawyer that was involved -- 14 well, let me strike that. In one or more of those 15 cases is Mr. Howell involved, or was he at the time 16 you were a solo practitioner? 17 A. What do you mean by involved? 18 Q. Involved, was he a referring lawye

Investments 19.1 D3 Capital CLub concerned Epstein alleged settlements? 19.2 Were you aware? 19.3 Did other lawyers in the firm (partners) know Scott Rothstein ran investments? 19.4 Did lawyers at the firm know of the structured settlement business? 19.5 How could they not know? 19.6 Did Edwards know?

E NO.: 80743 DRAFT 4 18 11 8:21 PM Epstein v. Rothstein & Edwards Outline for Russell Adler Deposition,

d BE bring active filed cases agst JEE to RRA when he joined? 14.9 Did you know Paul Cassell? If yes, since when and how did you meet? 14.10 A Mr. Howell? same as for Cassell. 14.11 3 files: State court was ■. (Jane Doe # 2), E.W. (Jane Doe #1) and . 14.12 Who staffed the Epstein files? 14.12.1 BE

TATE OF FLORIDA FOURTH DISTRICT Appellate Case No.: 4D18-0762 LT Case No: 502009CA0408003C3C3CXMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants. MOTION TO STRIKE UNAUTHORIZED AND INAPPROPRIATE "JOINDER" FILED BY N

his case. Moreover, Epstein has been careful throughout the course of his litigation with Mr. Cassell's clients, as well as in this litigation with Rothstein and Edwards, to use initials and pseudonyms in order to maintain the identities of Mr. Cassell's 4 EFTA00805461 clients in confidence, including

t the Palm Beach County Bench Bar Conference likely delayed Edwards' efforts at submitting an order. 6 EFTA00805463 For Mr. Cassell, through Mr. Howell, to suggest anything contrary to Epstein's counsel's complete cooperation and compliance with the trial court's rulings is unfounded, scandalous, i