Epstein Secrets

on this 4th day of November, 2011 to: Jack Scarola, Esq., Searcy Denney Scarola et al., 2139 Palm Beach Lakes Boulevard, West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401-5012; and Marc S. Nurik, Esq., Law O

s Boulevard, West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, P.A., 250

very issues. EFTA00613622 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Division AG 3. At the hearing on September 28, 2011 on Edwards' Motion to Dismiss the Second Amended Complaint, this Court reiterated that it wanted to get the issues in the pleadings resolved before addressing discove

Law Offices of Marc S. Nurik o- ounse or e en an ounter- 01 1 1 ard, Suite 700 ounse or e en ant Scott Rothstein Plaintiff Bradley J. Edwards Jack A. Goldberger WA HAND DELIVERY Atterbu , Goldber er & Weiss, P.A. The Honorable Donald W. Hafele uite 1400 Palm Beach County Courthouse 1 205 N. Dixie Highw

Rothstein Plaintiff Bradley J. Edwards Jack A. Goldberger WA HAND DELIVERY Atterbu , Goldber er & Weiss,

nday, March 5, 2018, Epstein filed his to motion to remove the case from trial docket in order to comply with the mandate of Rule 1.440 and opposed Edwards' Motion for Pursuant to the clear language of the rule, if the action involves a main claim or counterclaim which has neither been answered nor defaulted,

ant/Counter-Plaintiff Bradley I Edwards Jack A. Goldberger Atterbury, Goldberger & Weiss, .. 250 Australia

aint. Significant to this case and Epstein having probable cause to continue with this suit against Edwards was Judge Crow's finding when he denied Edwards' Motion to Dismiss Epstein's Second Amended Complaint. Edwards' Motion to Dismiss asserted the litigation privilege as an absolute bar to Epstein's cause of

s Counsel for Defendant Scott Rothstein Jack A. Goldberger Atterbury, Goldberger & Weiss, .. 250 Australia

Fourth District Court of Appeal. Obviously, however, Epstein's general references to documents could not possibly have violated the Court's ruling. Edwards' Motion is just another attempt to derail an in camera review of 'A written Order has not been issued on the Court's March 8, 2018, rulings. EFTA00808672

LA: Excuse me, III going to 7 interrupt for just a moment. Do you have other 8 questions relating to the Crime Victims' Rights Act 9 case? 10 MR. GOLDBERGER: I do. 11 MR. SCAROLA: Okay. I am going to object to 12 your examination of [III.] on issues relating to 13 another case. Those matters don't have

d the NPA and there was no legitimate purpose for them to make the agreement public. Furthermore, the CVRA court had recently (February 2009) denied Edwards' Motion to Unseal the NPA in that action. (Jane Doe v. U.S., Case No. 08-CV-80736, D.E. 36.) Edwards wants the Court to believe, however, that Epstein's mo

nt/Counter-Plaintiff Bradley J. Edwards Jack A. Goldberger Atterbury, Goldberger & Weiss, M. 250 Australia

t to avoid the Florida Evidence Code by propounding the tardy discovery requests should be rejected. CONCLUSION Epstein respectfully requests that Edwards' Motion be denied. Edwards asked for confirmation of the pretrial deadlines and must be held to that request. There was no court ruling "on motions current

nt/Counter-Plaintiff Bradley J. Edwards Jack A. Goldberger Atterbury, Goldberger & Weiss, M. 250 Australia

cutoff date" and Edwards objected "to any effort to expand existing deadlines." Id. On November 27, 2017, the Court agreed with Edwards and granted Edwards' Motion finding that, "to the extent that wholesale additional discovery will not be permitted but individual discovery requests may be allowed on a matter

ey Epstein Jack A. Goldber er Es uire Atterbury Goldberger & Weiss, . 250 Australian Avenue S, Suite 1400

V. EPSTEIN Case No.: S02009CA040800XXXXMBAG Order Specially Setting Hearing Response in Opposition to Jeffrey Epstein's Omnibus Motion in Limine; Edwards' Motion in Limine to Strike the June 30, 2017 Affidavit of Jeffrey Epstein and to Exclude Evidence as to which Discovery was withheld under Claims of Privil