Epstein Secrets

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

of Edwards' "facts" detail in graphic terms alleged misconduct by Epstein wholly unrelated to the allegations in the instant litigation. Pursuant to Fla. R. Evid. §90.404(1), evidence of other crimes, wrongs or acts is inadmissible when the evidence is introduced solely to prove bad character, or that the pe

D FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1201 Plaintiff, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. / DRAFT 4/26/11 PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTE

, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually

e," as he has done. (See Exhibit 10). By using the epithet in open court, it becomes part of the public record and fodder for the media. Pursuant to Fla. R. Evid. 404, Mr. Scarola could not use such an epithet during the trial or introduce evidence to support the disparaging characterizations 24. The extra

D FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1201 Plaintiff, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, ead-laiadividually3 Defendants. DRAFT 4/26/11 PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S

, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individu

e," as he has done. (See Exhibit 10). By using the epithet in open court, it becomes part of the public record and fodder for the media. Pursuant to Fla. R. Evid. 404, Mr. Scarola could not use such an epithet during the trial or introduce evidence to support the disparaging characterizations 24. The extra