Epstein Secrets

IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, -VS- SCOTT individually, Intervenors.' ROTHSTEIN, BRADLEY J. individually, and and JANE DOE, Respondents CASE NO. 4D18-0762 RESPONSE TO EMERGENCY PETITION FOR WRIT OF MANDAMUS SEARCY DENNY S

ember 7, 2009, while Edwards was pursuing the cases noted above on behalf of his clients, Epstein filed the original Complaint here against Edwards, Scott Rothstein ("Rothstein"), and one of Edwards' clients, designated as ".." (App. 1). The gravamen of the Complaint was that after Edwards had filed those cases

s Fargo Bank, N.A. 1 204 So.3d 476 (Fla. 4th DCA 2016) Gawker Media, LLC v. Bollea 20, 21, 22 170 So.3d 125 (Fla. 2d DCA 2015) Grossman v. Fla. Power & Light Co., 14 570 So.2d 992 (Fla. 2d DCA 1990) Haft v. Adams, 1 238 So.2d 843 (Fla.1970) HSBC Bank USA, N.A. v. Serban, 14, 18, 19, 20 148 So.3d 1287 (

ALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. / PLAINTIFF JEFFREY EPSTEIN'S MOTION TO COMPEL PRODUCTION OF

eral orders entered by Judge Raymond Ray in the Bankruptcy Court, filed a one hundred and fifty-nine (159) page privilege EFTA00582857 Epstein v. Rothstein and Edwards DRAFT 2/3/12 4:26 PM Case No. 502009CA040800XXXXMB/Div. AG log, claiming that over two thousand (2000) documents are privileged.' Th

Engineering, Inc. v. Small, 861 So. 2d 1248, 1250 (Fla. 1st DCA 2003). The latter is subject to nearly absolute immunity. See, e.g., Smith v. Fla. Power & Light Co., 632 So. 2d 696 (Fla. 3d DCA 1994). A trial court is instructed "to make particularized findings in support of its determination of which of the do

14 PM IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN. Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF'S MOTION TO OUASH SUBPOENA AND FOR PROTECTIVE ORDER TO PREVENT DEPOSITI

F. Crow JEFFREY EPSTEIN. Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individual

other things, this Court may enter an order that the requested discovery not be had at all. Rule 1.280(c)(1), Ha. R. Civ. P.; compare Medero v. Fla. Power & Light Co., 658 So. 2d 566, 568 (Fla. 3d DCA 1995)(reversing trial court order denying deposition of material witness).\* 16. The Rule has been successfully

ENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, vs. Plaintiff/Counter-Defendant, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OMNI

EFTA00585430 142. All pleadings filed by Epstein in the Rothstein Bankruptcy Proceeding. 143. All submissions by Epstein in connection with the Rothstein deposition. 144. All Settlement Agreements between Epstein and victims of his sexual molestations. 145. Phone journal taken from Epstein's home a

e seeks to prohibit any reference to evidence at trial by first having its inadmissibility determined outside the presence of the jury. Rosa v. Fla. Power & Light Co., 636 So. 2d 60, 61 (Fla. 2d DCA 1994). The purpose of this motion in limine is to prevent Edwards from offering improper evidence at trial, the mer