Epstein Secrets

ned herein including, but not limited to, the discovery abuses and bad faith litigation tactics that Epstein has been the subject of at the hands of Scott Rothstein and his-co-conspirators, any tax returns must be redacted to preserve confidently and to prevent further abuses. See supra. Further, Epstein's com

ermore, as set forth in a Civil Complaint attached hereto as Exhibit ar attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A., deliberately engaged in a pattern of racketeering that involved a staggering series of gravely serious obstructions o

s and the defenses in the litigation"). W. The information simply falls under the "highly protected category of opinion work-product." Id; see also Fla.R.Civ.Pro. 1.280. Also, Counsel for Jane Does 2-8 in the Federal companion cases apparently obtained a copy of the file retained by the Palm Beach State

09/16/2010 15:13 FAX SEARCY DENNEY lit 001/008 #21874/mep JEFFREY EPSTEIN, Plaintiff, vs. S TT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants. IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNT

this lawsuit against Bradley J. Edwards, you knew that there was no evidence that he was involved in any &Ise statements that may have been made by Scott Rothstein concerning lawsuits against you. 22. Bradley J. Edwards never made any false statements of fact to you. 23. All attorneys' fees and costs incurre

ff'Counterdefendant, JEFFREY EPSTEIN, and requests that PlaintiffiCountenlefendant admit or deny the following facts, in accordance with Rule 1.370, Fla.R.Civ.P.: ADMISSIONS 1. You have acted on a sexual preference for minor females' on multiple occasions over the course of at least the last decade. 2.

ach, FL 33401-5012 Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., #700 Fort Lauderdale, FL 33301 Re: Jeffrey Epstein v. Scott Rothstein, etc., et al. Case No.: 50 2009 CA 040800XXXX1WB-AG Gentlemen: We need to reset the deposition of Scott Rothstein so I am sending this out to star

al or for such other purposes as are permitted under the applicable Statutes, Rules of Civil Procedure or Rules of Court. EFTA00722565 Epstein v. Rothstein, et al. 3 Case No. 50 2009 CA 040800)OOOCMDAG Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale,

EY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, Individually, BRADLEY J. EDWARDS, Individually, and.., Individually Defendants. Complex Litigation, Fla.R.Civ.Pro. 1201 Case No. 502009CA040800XXXXMBAG NOTICE OF TAKING DEPOSITION BY VIDEO TO: All Counsel of Record PLEASE TAKE NOTICE that the undersigned

BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla.R.Civ.Pro. 1.201 Case No. 502009CA040800XXXXMBAG Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, Individually, BRADLEY J. EDWARDS, Individually, and L.M., Individually Defendants/Counter-Plaintiffs. PLAINTIFF, JEFFREY EPSTEIN'S NOTICE OF PRO

33401 Telephone: (561) 802-9044 Facsimile: (561) 802-9976 Attorneys for Jeffrey Epstein, Plaintiff/ Counter-defendant EFTA00724374 Epstein v. Rothstein, et al. Case No. 50 2009 CA 040800XXXXMBAG Epstein's NOS of Expert Int to Edwards and RTP Experts Reports EPSTEIN'S EDWARDS EXPERT INTERROGATORIES

IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla.R.Civ.Pro. 1.201 Case No. 502009CA040800XXXXMBAG Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, Individually, BRADLEY J. EDWARDS, Individually, and

N AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN Complex Litigation, Fla. R. Civ. Pro.1201 Plaintiff, Case No. 50 2009CA040800XXXXMB AG v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M., individually, Defendants. Motion to Compel Bradley Edwards To Appear For Follow-Up Depos

Accordingly, EPSTEIN states: I. Introduction As this court is aware, attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A. for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and prof

vidence that would be inadmissible at trial, so long as it is reasonably calculated to lead to the discovery of admissible evidence. Rule 1.280(b), Fla.R.Civ.P. (2008). Wherefore, Epstein requests that this court grant the relief requested herein, including, but not limited to, ordering that Edwards retu

N AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN Complex Litigation, Fla. R. Civ. Pro.1201 Plaintiff, Case No. 50 2009CA040800XXXXMB AG v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M., individually, Defendants. Motion to Compel Bradley Edwards To Appear For Follow-Up Depos

Accordingly, EPSTEIN states: I. Introduction As this court is aware, attorney Scott Rothstein aided by other lawyers and employees at the firm of Rothstein, Rosenfeldt, and Adler, P.A. for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and prof

vidence that would be inadmissible at trial, so long as it is reasonably calculated to lead to the discovery of admissible evidence. Rule 1.280(b), Fla.R.Civ.P. (2008). Wherefore, Epstein requests that this court grant the relief requested herein, including, but not limited to, ordering that Edwards retu

09/16/2010 15:13 FAX 5616845816 SEARCY DENNEY lit 001/008 #21874/mep JEFFREY EPSTEIN, Plaintiff, vs. S TT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants. IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNT

this lawsuit against Bradley J. Edwards, you knew that there was no evidence that he was involved in any &Ise statements that may have been made by Scott Rothstein concerning lawsuits against you. 22. Bradley J. Edwards never made any false statements of fact to you. 23. All attorneys' fees and costs incurre

ff'Counterdefendant, JEFFREY EPSTEIN, and requests that PlaintiffiCountenlefendant admit or deny the following facts, in accordance with Rule 1.370, Fla.R.Civ.P.: ADMISSIONS 1. You have acted on a sexual preference for minor females' on multiple occasions over the course of at least the last decade. 2.

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

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH 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. individual

each, FL 33409 561-686-6300 Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Su

n of litigation or for trial. ace Alachua General Hospital. Inc. v. Zimmer USA. Inc., 403 So.2d 1087 (Fla. 1st DCA 1981); Fed.R. Civ.Pro. 26(bX3XB); Fla.R.Civ.Pro. 1.280; In re Faro Technologies Securities Litigation, 2008 WL 205318 (M.D. Fla. 2008); Lake Shore Radiator. Inc. v. Radiator Express Warehouse