Epstein Secrets

Expedite Delivery JACK SCAROLA JS/mep Enc. ce: Bradley J. Edwards, Esq. Joseph L. Ackerman, Esq. Christopher Knight, Esq.

pstein Case Anthony P RRA CLIENT Attorneys at RRA Barry Stone Attorney RRA Bert Patton Legal Assistant to Robert Josefsberg Beth Williamson Paralegal RRA Bradley Edwards Attorney RRA Cara Holmes Attorney RRA Carl Linder Attorney RRA Carla Martinez Law Clerk at RRA Carolyn (Legal Asst. to Jay Howell, Co-Counsel) Caroly

se) Attorney RRA | Scott Goldstein Attorney RRA Scott Rothstein Attorney RRA Seth Lehrman Attorney RRA Shawn Gilbert Prior Legal Assistant to Brad Edwards Sid Garcia Counsel for other Epstein Victims Counsel for other Epstein Victims Attorney RRA Counsel for other Epstein Victims Steven Jaffe Stuart

itz Litigation Team RRA attorneys and staff Marc Nurik Attorney RRA Margaret Berk Legal Assistant to Spencer Kuvin Maribel Matiska RRA Paralegal Mark Fistos Attorney RRA Mercedes Estrada Katherine Ezell’s Assistant MG Client (Epstein Case) Michael Wheeler Attorney RRA Mike Fisten Investigators RRA N.

CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and ■l., individually, Defendants. RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION FOR COURT TO DECLARE RELEVANCE AND NON-PRIVILEGED NA

eference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log, filed on March 5, 2018. 2. In addition to those arguments, Edwards states as follows: I For brevity, Edwards shall refer to Epstein's motion as the "Motion for Court to Declare Relevance." EFTA00808645 Edwards ad

enterprise, which included access to every email on the RRA server. No one (aside from Jeffrey Epstein) ever suggested, implied, or insinuated that Brad Edwards had any involvement or knew anything about Rothstein's illegal activities. Brad Edwards was never even formally interviewed by the authorities. Yet

or over 5 years!; 7. Is Epstein accusing Matt Weissing, Esq. of being directly involved in Rothstein's Ponzi scheme? Steven Jaffe, Esq.? How about Mark Fistos, Esq.? Were they all secret co- conspirators who have managed to avoid justice for the past nine years? Justice that only Jeffrey Epstein and his co

IN THE DISTRICT COURT OF APPEAL OF FLORIDA FOURTH DISTRICT CASE NO. 4D14-2282 BRADLEY J. EDWARDS, Appellant, v. JEFFREY EPSTEIN, Appellee. MOTION FOR LEAVE TO FILE SUPPLEMENTAL ARGUMENT The appellee, Jeffrey Epstein, respectfully moves for

28 So. 3d 67 (Fla. 3d DCA 2013) (holding that the litigation privilege applies to causes of action for malicious prosecution and abuse of process). Edwards appealed and is challenging the final judgment solely as to the malicious prosecution claim. 2. After the parties' briefs were filed, this Court is

rds, Rothstein was deposed. At the morning session of deposition on December 12, 2011, Rothstein was asked the following about Bradley Edwards: Q: Brad Edwards, would he have reported illegal activity? A: I don't know. Q: Would he have reported trust account defalcations? 22 R. 816, citing letter dated Ju

sponse to the same line of questioning when asked about all of the other attorneys with whom Edwards worked, such as Gary Fanner, Seth Lehrman, and Mark Fistos was, unequivocally, "yes", that they would have reported illegal activity." In the afternoon session of his deposition on that same day, Rothstein

pedite Delivery JACK SCAROLA JS/mep Enc. CC: Bradley J. Edwards, Esq. Joseph L. Ackerman, Esq. Christopher Knight, Es

Christopher Knight, Esq. WWW.SEARCYLAW.COM EFTA00314200 MASTER CONTACT LIST REGARDING Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman CONTACT NAME IDENTITY Adam Horowitz Counsel for other Epstein Victims Adam Steinberg Attorney RRA Alan Garten Donald Trump'

dler Attorney RRA Scott Goldstein Attorney RRA Scott Rothstein Attorney RRA Seth Lehrman Attorney RRA Shawn Gilbert Prior Legal Assistant to Brad Edwards Sid Garcia Counsel for other Epstein Victims Spencer Kuvin Counsel for other Epstein Victims Steven Jaffe Attorney RRA Stuart Mermelstein Cou

Litigation Team RRA attorneys and staff Marc Nurik Attorney RRA Margaret Berk Legal Assistant to Spencer Kuvin Maribel Matiska RRA Paralegal Mark Fistos Attorney RRA Mercedes Estrada Katherine Ezell's Assistant MG Client (Epstein Case) Michael Wheeler Attorney RRA Mike Fisten Investigators RR

pedite Delivery JACK SCAROLA JS/mep Enc. cc: Bradley J. Edwards, Esq. Joseph L. Ackerman, Esq. Christopher Knight, Es

istopher Knight, Esq. asa WWW.SEARCYLAW.COM EFTA00314210 MASTER CONTACT LIST REGARDING Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman CONTACT NAME IDENTITY Adam Horowitz Counsel for other Epstein Victims Adam Steinberg Attorney RRA Alan Garten Donald Trump'

dler Attorney RRA Scott Goldstein Attorney RRA Scott Rothstein Attorney RRA Seth Lehrman Attorney RRA Shawn Gilbert Prior Legal Assistant to Brad Edwards Sid Garcia Counsel for other Epstein Victims Spencer Kuvin Counsel for other Epstein Victims Steven Jaffe Attorney RRA Stuart Mermelstein Cou

Litigation Team RRA attorneys and staff Marc Nurik Attorney RRA Margaret Berk Legal Assistant to Spencer Kuvin Maribel Matiska RRA Paralegal Mark Fistos Attorney RRA Mercedes Estrada Katherine Ezell's Assistant Client (Epstein Case) Michael Wheeler Attorney RRA Mike Fisten Investigators RRA C

reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02045-02046 09/04/2009 Attorneys at RRA Bradley J. Edwards E.W., Doe v. Epstein — Letter from Bob Critton Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the di

Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE 11Q FROM DESCRIPTION OBJECTION not reasonably calculated to lead to the discovery of admissible evidence; prote

d not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01973-01974 07/23/2009 Mike Fisten Bradley J. Edwards CMA vs. Epstein — new investigator info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the

and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 08454 10/23/2010 Attorneys at RRA Mark Fistos Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; pr

reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 02045.02046 09/04/2009 Attorneys at RRA Bradley J. Edwards E.W., L.M. Doe v. Epstein — Letter from Bob Critton Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to th

Privilege Log — Dated 2-23-2011 Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION 03550-03574 09/09/2009 Attorneys at RRA Paul Cassell Litigation Strategy W/P;

d not reasonably calculated to lead to the discovery of the admissible evidence; protected by privacy rights 01973-01974 07/23/2009 Mike Fisten Bradley J. Edwards CMA vs. Epstein — new investigator info Work product; attorney/client privilege; irrelevant and not reasonably calculated to lead to the

and not reasonably calculated to lead to the discovery of admissible evidence; protected by privacy rights 08454 10/23/2010 Attorneys at RRA Mark Fistos Litigation Strategy W/P; Attorney Client Privilege; Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence; pr

Lippman Andrew Barnett Robert Buschel FROM LEON BRAUSER DEPO Michael Szafranski Jim McCay Larry Yogel Alan Weinstein, investment broker FROM BRADLEY EDWARDS DEPO Maria Kelljian Beth Williamson Michael Fisten Dean Howell Paul Cassell Ken Jenne Bill Berger Richard Fandry Jane Muskrat Michelle Dary

s Tommy Mottola Officer Recarey Interviewed by Michael Fisten Investigator FBI Agent FBI Agent US Attorney Rothstein's right arm (Deposed by Edwards) Claims he had list of names and addresses of females who may have come to Mr. Epstein's house along with phone numbers. Billionaire Worked for F

chet Mark Melvin Jack Samoney Lawrence King Steve Jackel Michael Legamaro Kevin Draber David Boden Andrew Barnett Alan Sakowitz Mark Nurik Mark Fistos Tommy Mottola Officer Recarey Interviewed by Michael Fisten Investigator FBI Agent FBI Agent US Attorney Rothstein's right arm (Deposed by E