Epstein Secrets

IFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, PlaintifVCounter-Defendant, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. MOTION TO CONTINUE HEARING SCHEDULED FOR OCTOBER 3, 2017 AND/O

West Palm Beach, FL 33401 (561) 659-8300 filAtaleCkAA. gel )111rEglt IG ER, ESQ. Florida Bar No: 262013 EFTA00613443 SERVICE LIST Epstein v. Rothstein/Edwards Case No. 502009CA040800XXXXMB Jack Scarola, Esq. Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Ma

n related quasi-criminal proceedings. In support thereof Plaintiff/Counter-Defendant, JEFFREY EPSTEIN states as follows: 1. Undersigned counsel for the Plaintiff/Counter-Defendant, JEFFREY EPSTEIN, has been Mr. Epstein's primary defense counsel for ten years. 2. Pending in the United States District Court for the Southern Dis

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

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J, EDWARDS, individu

aintiff/Counter- Defendant, hereby certifies that this Motion is made in good faith. The undersigned counsel further certifies that the affidavit of the Plaintiff/Counter-Defendant is likewise in good faith, and is based upon his well-founded fear that he cannot receive a fair hearing or trial from Judge Hafele. WE HEREBY CER

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

rey Epstein as to Bradley Edwards through intemet searches. 27. Provide an explanation for your belief that law enforcement is still investigating the Plaintiff/Counter-Defendant Jeffrey Epstein. Identify contacts with govemment/law enforcement, media, other attorneys, or anyone else from which you claim to form this belief,

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

rey Epstein as to Bradley Edwards through intemet searches. 27. Provide an explanation for your belief that law enforcement is still investigating the Plaintiff/Counter-Defendant Jeffrey Epstein. Identify contacts with govemment/law enforcement, media, other attorneys, or anyone else from which you claim to form this belief,

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

rey Epstein as to Bradley Edwards through intemet searches. 27. Provide an explanation for your belief that law enforcement is still investigating the Plaintiff/Counter-Defendant Jeffrey Epstein. Identify contacts with govemment/law enforcement, media, other attorneys, or anyone else from which you claim to form this belief,