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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
HEARING On March 8, 2018, the parties attended a special set hearing on a number of pending Motions, including Edwards' Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log. Because the trial was o
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
HEARING On March 8, 2018, the parties attended a special set hearing on a number of pending Motions, including Edwards' Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log. Because the trial was o
tein's illegal activities. Brad Edwards was never even formally interviewed by the authorities. Yet Epstein now claims that an e-mail string between Scott Rothstein and at least five other attorneys, including Brad Edwards, who were never implicated in and had no involvement whatsoever in Rothstein's Ponzi schem
5. In his Notice of Filing Appendix. Epstein, through counsel, includes privileged materials under a section titled "Edwards' Direct Involvement in Rothstein's Ponzi Scheme." If nothing but consistent, Epstein, through counsel, then sprinkles throughout the Motion for Court to Declare Relevance direct ac
er', and in support states as follows: I. Edwards incorporates by reference the timeline and arguments contained in his Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log, filed on March 5, 2018.
vely labeled: I) "Bradley Edwards.pdf' containing 8,507 pages of documents, 2) "Epstein Searches.pdf' containing 17,348 pages of documents, and 3) "Scott Rothstein.pdf' containing 1,687 pages of laturnalaigarElir EFTA00809603 Edwards adv. Epstein Case No. 502009CA040800XXXXMBAG Supplement to Motion to Strike Ep
XXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually,
DWARDS' PRIVILEGE LOG Counter-Plaintiff Edwards, by and through undersigned counsel, hereby files this Supplement to his Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log, and in support states a
Entities connected to both Scott Rothstein and Untimely Supplemental Exhibits

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
Scott J. Link
PERSON
Lauderdale
LOCATION
Jay Howell
PERSONNichole J. Segal
PERSON
Jacksonville
LOCATIONBurlington & Rockenbach
ORGANIZATION
Searcy
PERSON