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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 (e.g., victims of) Rothstein Rosenfeldt & Adler's Ponzi scheme, in the Razorback litigation. These investors were unquestionably adverse to both Rothstein and Edwards' law firm of which he was a partner. Despite this, Edwards voluntarily produced documents that he now claims are privileged to Mr. Scher
ilege where that disclosure is inconsistent with maintaining secrecy from the disclosing party's adversary." Tumelaire v. Naples Estates Homeowners Ass'n, Inc., 137 So. 3d 596, 599 (Fla. 2d DCA 2014). In Tumelaire, the plaintiff was accused of conspiring with a mobile home park's owner in litigation agains
deposition to begin on December 12, 2011, granting a stay to the government. Epstein sought leave of the Bankruptcy Court to take the deposition of Scott Rothstein on December 1, 2011. At that time, Judge Ray denied the Motion without prejudice, because there was no time in the schedule to depose Mr. Rothstein.
y Edwards. The Statement of Undisputed Facts is identical to the one used for Edwards' first Motion for Summary Judgment. EFTA00808026 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Div. AG Epstein's Response in Opposition to Edwards' MSJ to obtain summary judgment. Third, Edwards has
icated documentary evidence may not be relied on or considered in support of a motion for summary judgment. See, e.g., Hollywood Towers Condominium Ass'n, Inc. v. Hampton, 993 So. 2d 174, 175-176 (Fla. 4th DCA 2008) (unauthenticated photocopies of check, letter and bank statement attached to motion for sum
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
ing is an essential part of justice; and an overspeaking judge is no well tuned cymbal." Great Am. Ins. Co. of New York v. 2000 Island Blvd. Condo. Ass'n, Inc., 153 So. 3d 384, 390 (Fla. 3d DCA 2014) (citations omitted). Florida law mandates recusal of a judge when a litigant establishes a reasonable, well
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
expert should not be allowed to testify concerning questions of law." Edward J. Seibert, Architect & Planner, P.A. v. Bayport Beach & Tennis Club Ass'n, Inc., 573 So. 2d 889, 892 (Fla. 2d DCA 1990) citing Devin v. City of Hollywood, 351 So. 2d 1022, 1022 (Fla. 4th DCA 1976). Thus, Smith's purported opinio
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
ion of legal services to the client. 2. Those reasonably necessary for the transmission of the communication. Las Olas River House Condo. Ass'n, Inc. v. Lorh, LLC, 181 So. 3d 556, 557-58 (Fla. 4th DCA 2015); § 90.502(1Xc), Fla. Stat. (2017); Witte v. Witte, 126 So. 3d 1076 (Fla. 4th DCA 2012)(sec
Entities connected to both Scott Rothstein and Ass'n, Inc.

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJack Scarola
PERSONJane Doe
PERSON
George W. Bush
PERSONMaria Farmer
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSON
Kenneth Marra
PERSON
Donald Trump
PERSON
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATIONMarc S. Nurik
PERSONAtterbury
ORGANIZATION
United States
LOCATIONLeon Black
PERSON
Bill Clinton
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
Adler
PERSON