Epstein Secrets

E. The Present Motion to Compel I0 ARGUMENT 11 I. EDWARDS MAY NOT RELY ON THE VACATED DISTRICT COURT ORDER FROM THE JANE DOE ACTION 12 II. EDWARDS FAILS TO MEET THE REQUIREMENTS FOR DISCOVERY OF A NON-PARTY UNDER CPLR 3101(a) 14 A. The Epstein Interview Does Not Have Heightened Relevance to

a deposition in one of the now-settled suits by implying that "he did not recognize" reporter Rush. Moving Br. at 17; see also Moving Affidavit of Bradley James Edwards, sworn to Sept. 14, 2010 ("Edwards Aft"), ¶ 22. Besides being farfetched and factually unsupported, Edwards' apparent desire to attack Epstein's cr

pstein sex abuse litigation, as even a quick Google search reveals. See. e.g., Heiress Quizzed in Sex Suits. M. POST, Oct. 12, 2009 ("Florida lawyer Brad Edwards. who represents three of the 'Jane Does' who are suing Epstein, told Page Six that Phislaine] Maxwell would be questioned over her knowledge of how

lawyers and others close to the case — including attorney Edwards — who could provide tips and information to assi

o. Nov. 12, 1992) 24, 26 People v. Royster, 43 .U1758, 842 ad 12 (1st Dep't 2007) 26 Pugh v. Avis Rent A 1997 WL 669876 ( Oct. 28, 1997) 27 Rollins Burdick Hunter of N. Y., Inc. v. Euroclassics Ltd., 502 So.2d 959 (Fla. Dist. Ct. App. 1983) 21 Russman v. Bd. of Ed., 260 F.3d 114 (2d Cir. 2001) 13 S&I Inve

S'S MOTION FOR FINAL SUMMARY JUDGMENT Defendant, Bradley J. Edwards, Esq., by and through his undersigned counsel and pursu

for all claims brought against him in Plaintiff Jeffrey Epstein's Complaint. Not only is there an absence of competent evidence to demonstrate that Edwards participated in any fraud against Epstein, the evidence uncontrovertibly demonstrates the propriety of every aspect of Edwards' involvement in the p

rt claims. The only cases not resolved are this case and two (2) cases in state court (all three Plaintiffs are represented by Plaintiff's counsel, Brad Edwards, Esq. and his firm). I 5. Plaintiffs in other filed cases were represented by various law firms as the court is aware. 6. With the additional disco

ction may not invoke the fifth amendment and refuse to comply with the defendant's discovery requests, thereby thwarting the defendant's defenses." Rollins Burdick Hunter of New York Inc. v. Euroclassic Limited, Inc., 502 So. 2d 959 (Fla. 3"I Dist. Court App. 1983). Here, Epstein is trying to do precisely what the "w

IRCUIT, 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 JEFFREY EPSTEIN'S MOTION FOR TEMPORARY ST

eme. Substantial discovery was taken by both parties. In 2012, Epstein voluntarily dismissed his complaint, and the sole remaining claim became Mr. Edwards' counterclaim for malicious prosecution. For the next five years, the parties litigated Mr. Edwards' claims in both the trial and appellate courts a

ent. 994 So. 2d at 478. Moreover, "[a] civil litigant's fifth amendment right to avoid self-incrimination may be used as a shield but not a sword." Rollins Burdick Hunter of New York, Inc. v. Euroclassics Ltd., Inc., 502 So. 2d 959, 962 (Fla. 3d DCA 1987). Thus, "where the party claiming a Fifth Amendment privilege i

to Amended to Assert Punitive Damages; Exhibit “E” — Transcript of Deposition of Jeffrey Epstein dated January 25, 2012; Exhibit “F’ — Deposition of Bradley Edwards dated March 23, 2010; Exhibit “G” - Deposition of Scott Rothstein dated June 14, 2012; Exhibit “H” — Order of HOUSE_OVERSIGHT_013305 --- PAGE BREAK

action may not invoke the fifth amendment and refuse to comply with the defendant’s discovery requests, thereby thwarting the defendant’s defenses.” Rollins Burdick Hunter of New York, Inc. v. Euroclassic Limited, Inc., 502 So. 2d 959 (Fla. 3d DCA 1983).. For the same reasons, Epstein should be precluded from advancing

dwards Affidavit”) (Exhibit 32. On June 13, 2008, attorney Edwards agreed to represent E.W.; on July 2, 2008, tomes