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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. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN
the falsity of Edwards' claim that he was hurt by Epstein's lawsuit and that Epstein had no reasonable basis to allege that Edwards was involved in Rothstein's Ponzi scheme using the tort claimants' cases. Finally, Epstein urges this Court to recognize that Edwards' moving to prevent Epstein from discuss
valuation of and challenges to the privileges asserted therein. TIG Ins. Cap. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001); Abbott Laboratories v. Alpha Therapeutic Corp., No. 97-C-1292, 2000 WL 1863543 (N.D. III. Dec. 14, 2000). Moreover, none of the general references for which Edwards would have Epstein sanctioned
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. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN
the falsity of Edwards' claim that he was hurt by Epstein's lawsuit and that Epstein had no reasonable basis to allege that Edwards was involved in Rothstein's Ponzi scheme using the tort claimants' cases. 'The May 23, 2018, hearing transcript is attached as Exhibit B. 5 EFTA00808662 Finally, Epstein
valuation of and challenges to the privileges asserted therein. TIG Ins. Cap. v. Johnson, 799 So. 2d 339 (Fla. 4th DCA 2001); Abbott Laboratories v. Alpha Therapeutic Corp., No. 97-C-1292, 2000 WL 1863543 (N.D. III. Dec. 14, 2000). Had the Court issued the expansive prohibition sought by Edwards, it would have effectiv
rect (56i) 472.6395 Fax lackermandpfowler-white.corn Robert B. Carney, Special Master 2281 Saratoga Lane West Palm Beach, FL 33409 Re: In re: Rothstein, Rosenfeldt Adler. U.S. Bankruptcy Court, Southern District of Florida, Fort Lauderdale Division; Case No. 09-34791-BKC-RBR Our File NO. 80743 De
h as 'letter re claim,' analysis of claim,' or report in anticipation of litigation' . . . will be insufficient." Id. (citing Abbott Laboratories v. Alpha Therapeutic Corp., 2000 U.S. Dist. LEXIS 20834, 2000 WL 1863543 fl III. Dec. 14, 2000). 4. In this Log, there is no identification whatsoever of the type of docume
Entities connected to both Scott Rothstein and Alpha Therapeutic Corp.

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJack Scarola
PERSONJane Doe
PERSON
George W. Bush
PERSON
Paul Cassell
PERSONPalm Beach Lakes Boulevard
LOCATION
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATIONMarc S. Nurik
PERSONGoldberger & Weiss
ORGANIZATION
Scarlett Johansson
PERSONthe Southern District
LOCATION
Lauderdale
LOCATION
Scott J. Link
PERSON
Jay Howell
PERSONNichole J. Segal
PERSON
Jacksonville
LOCATION
Searcy
PERSONBurlington & Rockenbach
ORGANIZATION