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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 L.M., individually, Defendant, RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION TO REOPEN DISCOVE
XXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually,
rds adv. Epstein Case No.: 502009CA040800XXXXMBAG Response in Opposition to Epstein's Motion to Reopen Discovery Page 3 of 8 throughout Epstein's Initial Complaint. Any suggestion that L.M.'s deposition is needed "solely" as a result of the Court's December 5, 2017 ruling is therefore absurd. 4. Jane Doe is a
[PROVIDE CITATION FROM NYT ARTICLE, WSJ ARTICLE, SUN-SENTICAL ARTICLE AND EPSTEIN AFFIDAVIT]; Amended Complaint in Razorback Funding, LLC, et aL v. Scott W. Rothstein, et aL, Case No. 09- 062943(19); see Deposition Transcript of Bradley Edwards dated March 23, 2010; Deposition Transcripts of Scott W. Rothstein in
and equipment in order to enrich the personal wealth of persons employed by and associated with the RRA Enterprise. See Information Charging Scott W. Rothstein in United States of America v. Scott W. Rothstein, 09-60331-CR-COHN. Scott Rothstein, Edwards's partner at RRA, admitted to and was convicted for th
ne Doe v. Jeffrey Epstein, 08-80893-CIV Marra/Johnson; copies of subpoenas; Deposition Transcript of Jeffrey Epstein, p. 23; line 4-p. 38; line 22; Initial Complaint filed by Epstein dated December 9, 2009, pages 13-20; Razorback Amended Complaint; pp. 16-17; ¶1148, 49. The litigation practices giving rise to pr
URT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800)OOOCMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, RESPONSE IN OPPOSITION TO PLAINTIFF/COUNTER-DEFENDANT JEFFRE
OOCMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually,
ial complaint, Epstein emphatically stated that "[t]his lawsuit is filed and will be vigorously pursued against all these defendants." See Epstein's Initial Complaint at `Summary'. (Emphasis added). In accordance with this representation to the Court, Epstein made no attempt to stay his newly-filed civil case pen
L v. Scott W. Rothstein, et at, Case No. 09-062943(19); see Deposition Transcript of Bradley Edwards dated March 23, 2010; Deposition Transcripts of Scott W. Rothstein in In re: Rothstein Rosenfeldt Adler, PA; 09-34791-RBR and Razorback Funding, LLC, et aL v. Scott W. Rothstein, et aL, Case No. 09-062943(19); Depos
aim; Deposition Transcripts of Scott W. Rothstein in In re: Rothstein Rosenfeldt Adler, PA; 09-34791-RBR and Razorback Funding, LLC, et at v. Scott W. Rothstein, et aL, Case No. 09-062943(19). On December 1, 2009, the Federal Government filed a 36 page Information against Rothstein charging that RRA was a r
ane Doe v. Jefrey Epstein, 08-80893-C1V Marra/Johnson; copies of subpoenas; Deposition Transcript of Jeffrey Epstein, p. 23; line 4-p. 38; line 22; Initial Complaint filed by Epstein dated December 9, 2009, pages 13-20; Razorback Amended Complaint; pp. 16-17; ¶¶ 48, 49. In addition, on July 24, 2009, while he wa
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
any actions allegedly taken by Epstein. In fact, this litigation with Epstein catapulted Edwards from an unknown solo practitioner to a partner at Rothstein, Rosenfeldt, Adler. Moreover, Edwards still utilizes his litigious association with Mr. Epstein at his new firm Farmer, Jaffe, Weissing, Edwards, Fi
Epstein admits that some of the claims initially filed by him against Edwards are delineated in Paragraph 11 and its subparts, but submits that the Initial Complaint speaks for itself and that to the extent that Edwards has inaccurately summarized or interpreted any provision thereof in Paragraph II of his Count
Entities connected to both Scott Rothstein and Initial Complaint

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJack Scarola
PERSONJane Doe
PERSON
George W. Bush
PERSONMaria Farmer
PERSONPalm Beach Lakes Boulevard
LOCATION
Kenneth Marra
PERSONMarc S. Nurik
PERSON
Weissing
PERSONTonja Haddad Coleman
PERSONAtterbury
ORGANIZATION
Bill Clinton
PERSONJaffe
PERSON
Scarlett Johansson
PERSONPalm Beach Lakes Blvd
LOCATION
Lauderdale
LOCATION
Adler
PERSONSearcy Denney Scarola
PERSON