Epstein Secrets

EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individua

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 RENEWED MOTION F

ealing with an expert which is otherwise qualified to testify to what he's going to testify. (3/8/18 Aft. Tr. 93:16-20.) Indeed, "[a]s indicated in Binger v. King Pest Control, 401 So. 2d 1310 (Fla. 1981), the exclusion of an unlisted witness' testimony is a drastic remedy which should pertain in only

T OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN. Plaintiff(s), vs. SCOTT ROTIISTEIN. individually, BRADLEY J. EDWARDS, individually, and EL, individually. Dcfendant(s). EXHIBIT b ORDER ON MOTION TO RECONFIRM EXISTING PRETRIAL D

s Motion to Amend Exhibit List. was not at issue as a result of Epstein's own dilatory conduct in failing to know what pleading was pending against Rothstein and failing to know whether a default had been entered. At the hearing on March 8, 2018, Epstein's trial counsel nonetheless repeatedly claimed tha

-over" so that, rather than appear as trial counsel on the eve of trial to actually try the case, they can reopen discovery and start from scratch. Binger, however, does not permit Epstein to do so. Epstein correctly notes that the Court should not permit Epstein to amend his exhibit list if the propo

OURT 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 individually, Defendant, RESPONSE IN OPPOSITION TO EPSTEIN'S RENEWED MOTION FOR LEAVE TO DI

Summary of Action' in the Complaint, which includes the following allegations: Attorney Scott Rothstein aided by other lawyers . . . at the firm of Rothstein, Rosenfeldt and Adler, 5., for personal greed and enrichment, in betrayal of the ethical, legal and fiduciary duties to their own clients and profe

s follows: &nicer Does Not Permit a Party to Ignore Trial Court Orders In this and other motions, Epstein relies on the Supreme Court's decision in Binger to argue that Epstein should be permitted to ignore this Court's pre-trial orders, as long as there is no prejudice to Edwards. This interpretation

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. / COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITIO

ntal to his case and question his credibility, not because they will cause any undue prejudice because of their alleged late disclosure." Page 10 "A. Rothstein, Rosenfeldt and Adler E-mails Epstein identified and disclosed a number of emails from the Rothstein, Rosenfeldt and Alder firm that directly contr

EARING After ruling that Epstein would not be allowed to use certain exhibits identified since March 2018 on his Clerk's Trial Exhibit List under a Binger' analysis, this Court raised the pending issue of the 47 e-mails that Edwards claims are privileged and Epstein's pending request for an in camera

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

days ago, and discussed perhaps within the last few 23 as part of a cannon interest privilege with an 23 weeks, then we would have essentially a Binger 24 express representation it was attorneys' eyes only, 24 issue to analyze. So Hiss Rockentoch, go ahead and 25 with an express representation

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

days ago, and discussed perhaps within the last few 23 as part of a cannon interest privilege with an 23 weeks, then we would have essentially a Binger 24 express representation it was attorneys' eyes only, 24 issue to analyze. So Hiss Rockentoch, go ahead and 25 with an express representation

nt prosecution agreement with Edwards' counsel, whereby both parties agreed to share information relative to their claims and/or defenses related to Scott Rothstein without waiving privilege as to their communications or documents shared." Edwards' Supp. Resp. to Epstein's Mot. to Declare Relevance, July 26, 201

in this action about his anxiety over being sued by Epstein They also directly relate to Edwards' interaction with Ponzi-schemer Scott Rothstein ("Rothstein") and the strengthAveakness of Edwards' clients' damage claims against Epstein, both which have become critical factual issues in this case. First

hibit 3.) During its in camera review, this Court must consider and determine: 1. The e-mails are directly relevant to the issues for trial and no Binger's "surprise in fact" exists regarding them; 2. If any work product protection existed, it was waived or excepted based on: a. Farmer Jaffe's exp

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. / COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITIO

- "In his Notice of Filing Appendix, Epstein, through counsel, includes privileged materials under a section titled 'Edwards' Direct Involvement in Rothstein's Ponzi Scheme.' If nothing but consistent, Epstein, through counsel, then sprinkles throughout the Motion for Court to Declare Relevance direct ac

EARING After ruling that Epstein would not be allowed to use certain exhibits identified since March 2018 on his Clerk's Trial Exhibit List under a Binger' analysis, this Court raised the pending issue of the 47 e-mails that Edwards claims are privileged and Epstein's pending request for an in camera

KR. LINK: I understand. Your Honor, may I respected coach and former coach of the Heat -- a have one ninute to confer with appellate counsel to Scott Rothstein wan sitting on thin stuff. That's 7 ado sure there's nothing I need to do to preserve i not what happened hero. That's the point that I'm • this

an agreement. And 19 THE COUR?: I nay have font you. ?he 74,000 in our agreement, your court order says no 20 pages wore self-generated from the Rothstein firm: additional exhibits unless the parties agree. In 21 MR. LINK: Yes. And delivered by the trustee the pretrial stip Kr. scarola and I agree

your paralegal' • by an unsuccessful notion in limlne. Furthernare, 5 /12. ROCWITEACH: Who obtained the three boxes. prejudice in the context of Binger refers to the 4 the three taxes free Fowler White, which contair. surprise in fact of the objecting party and is not 7 that CD which la at Issue

211 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 of the files during the operative period of Adler's and Rothstein's dealings, allegedly, as it relates to Adler, clearly as it relates to Rothstein by his own testimony as to appease these investors and to furthe

ow what, I wasn't involved with regard to that federal case that was filed. That had an electronic signature on it. It wasn't me. I didn't do it. Scott Rothstein did it. They would Palm Beach Reporting Service, Inc. EFTA00788340 230 1 2 3 4 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 2

we get an answer on the record as to whether that is going to happen so I know whether this is discovery that I need to proceed with. THE COURT: Binger has long held, essentially, that there's really no difference from the discovery standpoint between rebuttal witnesses or rebuttal evidence and d