Epstein Secrets

lEENTH 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 FOR PROTE

trial, the total amount paid, again, goes back to that place in time when Mr. Epstein would have brought this lawsuit at or near the time of Mr. Rothstein's arrest; at or near the time of federal and perhaps state agents raiding the offices of the firm; at or near the time of these cases reaching a c

m privacy, it was apparent to the Fourth District Court of Appeal that personal finances are among those private matters kept secret by most people. Woodward v. Berkery, 714 So. 2d 1027, 1035 (Fla. 4th DCA 1998); citing Winfield v. Division of Pari—Mutuel Wagering, 477 So. 2d 544 (Fla. 1985) (law in Flor

reasonably calculated to lead to the discovery of admissible evidence. b. None. 6. All fee sharing agreements between Bradley J. Edwards, RRA, or Scott W. Rothstein and/or any other attorney or investor relating to any aspect of any Plaintiff's case. ANSWER: Objection, relevance, not reasonably calculated to l

ent to his cause of action. Moreover, discovery relating to Edwards's financial incentives to join RRA and to engage in conduct in cooperation with Rothstein in support of RRA's illicit activities is most certainly relevant to Edward's allegations in this case and Epstein's defense of the same. Accordingl

ily puts his personal financial information at issue, courts will compel production of personal financial information. Friedman, 863 So. 2d at 194; Woodward v. Berkey, 714 So. 2d 1027, 1036 (Fla. 4th DCA 1998). A party's finances, if relevant to the disputed issues of the underlying action, are not exce

reasonably calculated to lead to the discovery of admissible evidence. b. None. 6. All fee sharing agreements between Bradley J. Edwards, RRA, or Scott W. Rothstein and/or any other attorney or investor relating to any aspect of any Plaintiff's case. ANSWER: Objection, relevance, not reasonably calculated to l

ent to his cause of action. Moreover, discovery relating to Edwards's financial incentives to join RRA and to engage in conduct in cooperation with Rothstein in support of RRA's illicit activities is most certainly relevant to Edward's allegations in this case and Epstein's defense of the same. Accordingl

ily puts his personal financial information at issue, courts will compel production of personal financial information. Friedman, 863 So. 2d at 194; Woodward v. Berkey, 714 So. 2d 1027, 1036 (Fla. 4th DCA 1998). A party's finances, if relevant to the disputed issues of the underlying action, are not exce

reasonably calculated to lead to the discovery of admissible evidence. b. None. 6. All fee sharing agreements between Bradley J. Edwards, RRA, or Scott W. Rothstein and/or any other attorney or investor relating to any aspect of any Plaintiff's case. ANSWER: Objection, relevance, not reasonably calculated to l

nt to his causes of action. Moreover, discovery relating to Edwards's financial incentives to join RRA and to engage in conduct in cooperation with Rothstein in support of RRA's illicit activities is most certainly relevant to Edward's allegations in this case and Epstein's defense of the same. Accordingl

ily puts his personal financial information at issue, courts will compel production of personal financial information. Friedman, 863 So. 2d at 194; Woodward v. Berkey, 714 So. 2d 1027, 1036 (Fla. 4th DCA 1998). A party's finances, if relevant to the disputed issues of the underlying action, are not exce

sq. Bruce E. Reinhart, P.A. Brad Edwards, Esq. Rothstein Rosenfeldt Adler 40 l East Las Olas Boulevard S

. Furney Charters, 212 F.R.D. at 590-91; see also Woodward v. Berkery, 714 So.2d I 027 (Fla. 4th DCA l 998)