Epstein Secrets

TATE OF FLORIDA FOURTH DISTRICT Appellate Case No.: 4D18-0762 LT Case No: 502009CA0408003C3C3CXMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants. MOTION TO STRIKE UNAUTHORIZED AND INAPPROPRIATE "JOINDER" FILED BY N

his case. Moreover, Epstein has been careful throughout the course of his litigation with Mr. Cassell's clients, as well as in this litigation with Rothstein and Edwards, to use initials and pseudonyms in order to maintain the identities of Mr. Cassell's 4 EFTA00805461 clients in confidence, including

at Improperly and Without Foundation Claims Misconduct by Counsel The now sealed exhibits have never been deemed "apparently stolen" by my court. (Joinder, p. 1.) And neither Epstein nor his counsel has taken the "position that he need not immediately comply because of this Court's recent stay." (Joind

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

er- Plaintiff Bradley J. Edwards' ("Edwards") April 3, 2018, Motion for Sanctions for Violation of Court Order', and the Intervenors' April 7, 2018, Joinder and states: INTRODUCTION In order to justify his Motion for Sanctions, Edwards concocts a patently absurd construction of this Court's verbal ruli

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

er- Plaintiff Bradley J. Edwards' ("Edwards") April 3, 2018, Motion for Sanctions for Violation of Court Order', and the Intervenors' April 7, 2018, Joinder and states: INTRODUCTION In order to justify his Motion for Sanctions, Edwards concocts a patently absurd construction of this Court's verbal ruli

tions at a Mar. 8, 2010, deposition, id. at 10 & Ex. D. 8. Annexed hereto as Exhibit E is a copy of pertinent pages of the Complaint in Epstein v. Rothstein, Edwards No. 50 2009 CAO 40800 (Cir. Ct., 15th Jud. Cir., Palm Beach Co., Dec. 7, 2009), as downloaded from http://www.scribd.com/doc/23947743/121

NTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, ilr DLEY J. EDWARDS, individually, and ., individually, Defendants. 50 2009 cAo 03 (JUI0X04B COMPLAINT COPY RECEIVED FOR FILING

ition, dated December 28, 2004, with exhibits; the Request for Judicial Notice submitted in Opposition by Mr. Williams, dated December 28, 2004; the Joinder by Encana defendants in McGraw-Hill's motion; the Declaration of Julie K Buxbaum in Support of the Joinder by Encana, dated December 22, 2004, with

tions at a Mar. 8, 2010, deposition, id. at 10 & Ex. D. 8. Annexed hereto as Exhibit E is a copy of pertinent pages of the Complaint in Epstein v. Rothstein, Edwards & L.M. No. 50 2009 CAO 40800 (Cir. Ct., 15th Jud. Cir., Palm Beach Co., Dec. 7, 2009), as downloaded from http://www.scribd.com/doc/2394774

NTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1.201 CASE NO. Plaintiff, v. SCOTT ROTHSTEIN, individually, ilr DLEY J. EDWARDS, individually, and ., individually, Defendants. 50 2009 cAo 03 (JUI0X04B COMPLAINT COPY RECEIVED FOR FILING

ition, dated December 28, 2004, with exhibits; the Request for Judicial Notice submitted in Opposition by Mr. Williams, dated December 28, 2004; the Joinder by Encana defendants in McGraw-Hill's motion; the Declaration of Julie K Buxbaum in Support of the Joinder by Encana, dated December 22, 2004, with

Trial Exhibits 7.50 0.00 03/03/18 SJL Work on Response to Motion to B. Edwards' Compel re Request for Admissions; strategize re default against S. Rothstein and options to proceed with trial or seek to strike trial setting; work on preparations for special set hearings; work on trial preparations 7.30

re same 03/17/18 SJL C( ) I Edwards' Response to ,r1 mus and Motion to 03/18/18 TLC W )esponse to our Pe s, Request for Oral '. Cassell's Joinder; fo work on it ital Appendix; work or 03/18/18 RJG R ' second round of edits tc ng 03/18/18 SJL W -sell's Joinder; work or 'o 'se to o

P • • to Petitoner's Motion 0.30 0.00 fo ld Costs 03/19/18 TLC C. • Edwards' Response 9.80 2,205.00 to mus, Request for O. P. Cassell's Joinder at rk on Motion for tinue working on cl. .very . oduction issues; work on 03/19/18 SJL W Zesponse to our 8.20 6,150.00 Pr Request for O

tice; work on preparations for UMC hearing on S. Rothstein's default; work on Response to Intervenors' Join

late to opposing counsel for review in advance of hearing; work on Response to Farmer Jaffe's Motion to Show Cause in bankruptcwork on Response to Joinder filed by Intervenors ., E.W. and Jane Doe 04/03/18 SJL Work on insurance demand to Fowler White; work on Motion for In Camera Review; review pro

e defense attorneys’. Moreover, because the first time Jane Doe #3 made these contemptible allegations against Prof. Dershowitz was in her Motion for Joinder in December 2014, those allegations are irrelevant as to the inquiry of whether Jane Doe #3’s rights under the CVRA were violated at the time the NPA

, agreed with this reading of the NPA in his Statement of Undisputed Fact during his own personal lawsuit against Jeffrey Epstein (Jeffrey Epstein v. Scott Rothstein and Bradley J. Edwards, lawsuit (Case no. 502009-CA- 040800)) in Palm Beach County Circuit Court. There, Edwards explained that these co- conspirator

against Jeffrey Epstein (Jeffrey Epstein v. Scott Rothstein and Bradley J. Edwards, lawsuit (Case no. 502009-