Epstein Secrets

T COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, BRADLEY EDWARDS, individually, Defendants/Counter-Plaintiffs. TRANSCRIPT OF PROCEEDINGS VOLUME I DATE TAKEN: Tuesday, October 3r

4 25 of the primary element of the malicious prosecution claim, what may have been in the mindset of Mr. Epstein when he filed the claim against Rothstein, Edwards and LM -- initials being used only since she was allegedly a minor at the time that the suit was brought -- is of importance to the Court

his deposition testimony, his response to certain discovery requests, the undisputed facts available at the time he filed suit, the indictment of Scott Rothstein, every report in which it's discussed what Mr. Edwards and RRA were doing in these Epstein cases, as well as the filings in the federal court, and

01 By W. CHESTER BREWER, JR., P.A., ESQUIRE For Jeffrey Epstein: TONJA HADDAD, P.A. 315 S.E. 7th Street, Suite 301 Fort Lauderdale, FL 33301 By TONJA HADDAD COLEMAN, ESQUIRE For Jeffrey Epstein: ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Ave. South, Suite 1400 West Palm Beach, FL 33401 By JACK A. GOL

EENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, -VS- SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' MOTION TO STRIKE

URLINGTON Florida Bar No. 285862 By:/s/ Nichole J. Segal NICHOLE J. SEGAL Florida Bar No. 41232 /kbt 6 EFTA00613506 SERVICE LIST Epstein v. Rothstein/Edwards Case No. 502009CA040800XXXXMB W. Chester Brewer, Jr., Esq. W. CHESTER BREWER, JR., P.A. 250 S. Australian Ave., Ste. 1400 West Palm Beac

dismiss), rev. denied, 81 So. 3d 414 (Fla. 2012). STATEMENT OF THE CASE AND FACTS In December 2009, Appellee, Jeffrey Epstein, filed suit against Scott Rothstein ("Rothstein") and Appellant, Bradley J. Edwards, based upon Epstein's justifiable belief at the time of filing his Complaint that these two individu

/ FOURTH DISTRICT COURT OF APPEAL STATE OF FLORIDA CASE NO.: 4D14-2282 L.T. Case No.: 502009CA040800 ANSWER BRIEF OF APPELLEE JEFFREY EPSTEIN TONJA HADDAD COLEMAN, ESQ. Florida Bar No.: 176737 TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 JOHN BERANEK Fla. Bar No.: 0005419

ied, 81 So. 3d 414 (Fla. 2012). STATEMENT OF THE CASE AND FACTS In December 2009, Appellee, Jeffrey Epstein, filed suit against Scott Rothstein ("Rothstein") and Appellant, Bradley J. Edwards, based upon Epstein's justifiable belief at the time of filing his Complaint that these two individuals, and ot

dismiss), rev. denied, 81 So. 3d 414 (Fla. 2012). STATEMENT OF THE CASE AND FACTS In December 2009, Appellee, Jeffrey Epstein, filed suit against Scott Rothstein ("Rothstein") and Appellant, Bradley J. Edwards, based upon Epstein's justifiable belief at the time of filing his Complaint that these two individu

FOURTH DISTRICT COURT OF APPEAL STATE OF FLORIDA CASE NO.: 4D14-2282 L.T. Case No.: 502009CA040800 I ANSWER BRIEF OF APPELLEE JEFFREY EPSTEIN TONJA HADDAD COLEMAN, ESQ. Florida Bar No.: 176737 TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 (954) 467-1223 6 4 337-3716 facsimil

THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants. TRANSCRIPT OF HEARING PROCEEDINGS DATE TAKEN: Monday, January 27, 2014 TIME:

row 3 involving this case, I had no knowledge whatsoever 4 that a separate and independent action had been 5 brought by Mr. Epstein against the Rothstein 6 entities and Mr. Edwards. So to that extent, I 7 just to want let you know, as you probably already 8 did already know, that I handled those

DBERGER, ESQUIRE [email protected] 12 13 TONJA HADDAD, PA 315 SE 7th Street 14 Suite 301 Fort Lauderdale, FL 33301 15 954.467.1223 BY: TONJA HADDAD COLEMAN, ESQUIRE [email protected] 16 17 On behalf of Bradley J. Edwards: 18 SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. 19 2139 Palm Beach

TEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800SSSSMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, vs. SCOTT ROTHSTEIN, INDIVIDUALLY and BRADLEY J. EDWARDS, INDIVIDUALLY, Defendants/Counter-Plaintiffs. / PROCEEDINGS HELD BEFORE JUDGE DONALD HAFELE Epstein's Mot

PSTEIN, Plaintiff/Counter-Defendant, vs. SCOTT ROTHSTEIN, INDIVIDUALLY and BRADLEY J. EDWARDS, INDIVIDUAL

te 1400 West Palm Beach, FL 33401 By: W. CHESTER BREWER, JR. LAW OFFICES OF TONJA HADDAD, P.A. 315 S.E. 7th St. Ft. Lauderdale, FL 33301 By: TONJA HADDAD COLEMAN, ESQUIRE ATTERBURY, GOLDBERGER & WEISS, P.A. 250 S. Australian Ave Suite 1400 West Palm Beach, FL 33401 By: JACK GOLDBERGER, ESQUIRE ON BEHAL

Jack Scarola on behalf of Bradley Edwards, Your Honor. 3 JEFFREY EPSTEIN, MR. BREWER: Chester Brewer on behalf Plaintiff, of Jeffrey Epstein. SCOTT ROTHSTEIN, individbally, BRADLEY SWARDS, individually, MS. HADDAD: Tonya Haddad on behalf of Jeffrey Epstein. Defendente/Covnter-Plaintlffe. I'm sorry. /

d 5:3 report 9:8 reported 1:19 Reporting 1:21 representative 6:25 requested 8:12 response 4:14 8:11 responses 3:20 8:7 Right 4:20 Room 1:15 ROTHSTEIN 1:8 rule 8:10 S S 2:8 S.E 2:12 Scarola 2:4,6 3:3,3 3:18,25 4:3,13 5:6 5:8,18,25 6:8,11 6:17 7:2 8:1,4,16 schedule 7:11,12 SCOTT 1:8 SEARCY

E. 7th Street, Suite 301 14 And, obviously, our response to the 13 Fort Lauderdale, FL 33301 15 motion for sumnary judgment, as wall, which By TONJA HADDAD COLEMAN, ESQUIRE 16 Includes a variety of legal issues. 14 15 17 THE COURT: Can you be ready by 16 IS Tuesday, October 3rd? It sounds like it's 17

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 III individually, Defendants. TRANSCRIPT OF HEARING PROCEEDINGS DATE TAKEN: December 17, 2

26f9-4cfa-bba3-4354ecd33a52 EFTA00598449 3 1 Thereupon, 2 the following proceedings began at 10:02 3 THE COURT: Okay. This is 4 Epstein vs. Rothstein. This is the motion of 5 the counterplaintiff for -- to add punitive 6 damages. I reviewed the materials you guys had 7 sent to me. I got the m

8 APPEARANCES: On behalf of Jeffrey Epstein: TONJA HADDAD, 315 Southeast 7 Street Suite 301 Fort Lauderdale, Florida 33301 (954)467-1223 BY: TONJA HADDAD COLEMAN, ESQ. and ATTERBURY, GOLDBERGER & WEISS, III. 250 Australian Avenue South Suite 1400 - One Clearlake Center West Palm Beach, Florida 33401 (561

dismiss), rev. denied, 81 So. 3d 414 (Fla. 2012). STATEMENT OF THE CASE AND FACTS In December 2009, Appellee, Jeffrey Epstein, filed suit against Scott Rothstein ("Rothstein") and Appellant, Bradley J. Edwards, based upon Epstein's justifiable belief at the time of filing his Complaint that these two individu

ied, 81 So. 3d 414 (Fla. 2012). STATEMENT OF THE CASE AND FACTS In December 2009, Appellee, Jeffrey Epstein, filed suit against Scott Rothstein ("Rothstein") and Appellant, Bradley J. Edwards, based upon Epstein's justifiable belief at the time of filing his Complaint that these two individuals, and ot

/ FOURTH DISTRICT COURT OF APPEAL STATE OF FLORIDA CASE NO.: 4D14-2282 L.T. Case No.: 502009CA040800 ANSWER BRIEF OF APPELLEE JEFFREY EPSTEIN TONJA HADDAD COLEMAN, ESQ. Florida Bar No.: 176737 TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 (954) 467-1223 (954) 337-3716 (facsi

7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 result of being sued by Mr. Epstein in 2009 and not by being partners with Scott Rothstein, we are entitled to pursue that. We're entitled to the discovery to show how much money he made while he was working at RRA, before he was working

e, Judge, if the Court looks to the specific complaint filed by Mr. Epstein against Mr. Edwards, the allegation that we are stuck to defend here, Rothstein and the litigation team knew or should have known that the three filed cases were weak and had minimal value for the following reasons. Judge, LM

01 By W. CHESTER BREWER, JR., P.A., ESQUIRE For Jeffrey Epstein: TONJA HADDAD, P.A. 315 S.E. 7th Street, Suite 301 Fort Lauderdale, FL 33301 By TONJA HADDAD COLEMAN, ESQUIRE For Jeffrey Epstein: ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Ave. South, Suite 1400 West Palm Beach, FL 33401 By JACK A. GOL

owing. It is therefore EFTA00602092 Epstein V. Rothstein, et at Case No. 502009CA040800 AG Order Page 2

County, Florida. DAVID F. CROW CIRCUIT COURT JUDGE Copy furnished: JACK SCAROLA, ESQUIRE, 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409 TONJA HADDAD COLEMAN, ESQUIRE, 315 S. E. 7th St., Suite 301, Ft. Lauderdale, FL 33301 FRED HADDAD, ESQUIRE, One Financial Plaza, Suite 2612, Ft. Lauderdale, FL 33394 JA