Epstein Secrets

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 MOTION FOR PROTECTIVE ORDER AND IN LIMINE OF UNRELATED

ments and amounts and for a finding that such are inadmissible evidence, and states: INTRODUCTION Defendant/Counter-Plaintiff Bradley J. Edwards ("Edwards") represented three plaintiffs who brought tort claims seeking money damages against Epstein. Edwards possesses the confidential settlement agreeme

is error if we were not permitted to talk about what Mr. Epstein's motive was for taking the extraordinary step of filing a baseless claim against Bradley Edwards. THE COURT: Well, until we get into, Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00805183 5 1 2 3 4 5 6 7 8 9 10 11 12 13

m privacy, it was apparent to the Fourth District Court of Appeal that personal finances are among those private matters kept secret by most people. Woodward v. Berkery, 714 So. 2d 1027, 1035 (Fla. 4th DCA 1998); citing Winfield v. Division of Pari—Mutuel Wagering, 477 So. 2d 544 (Fla. 1985) (law in Flor

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 COUNTY, FLORIDA CASE NO.: 502009CA0408

ry responses responsive to Epstein's Requests. In support thereof, Epstein states: I Them are still outstanding damages discovery requests to which Edwards's Response is not due until after the Court's deadline date for the filing of this Motion. As such, an additional Motion may be required upon receip

ANSWER: Objection. Irrelevant, immaterial, not reasonably calculated to lead to the discovery of admissible evidence and an unwarranted invasion of Bradley Edwards' right to economic privacy. 15. State the amount of gross income that you received from the provision of goods or services other than while acting a

ily puts his personal financial information at issue, courts will compel production of personal financial information. Friedman, 863 So. 2d at 194; Woodward v. Berkey, 714 So. 2d 1027, 1036 (Fla. 4th DCA 1998). A party's finances, if relevant to the disputed issues of the underlying action, are not exce

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 COUNTY, FLORIDA CASE NO.: 502009CA0408

ry responses responsive to Epstein's Requests. In support thereof, Epstein states: I Them are still outstanding damages discovery requests to which Edwards's Response is not due until after the Court's deadline date for the filing of this Motion. As such, an additional Motion may be required upon receip

ANSWER: Objection. Irrelevant, immaterial, not reasonably calculated to lead to the discovery of admissible evidence and an unwarranted invasion of Bradley Edwards' right to economic privacy. 15. State the amount of gross income that you received from the provision of goods or services other than while acting a

ily puts his personal financial information at issue, courts will compel production of personal financial information. Friedman, 863 So. 2d at 194; Woodward v. Berkey, 714 So. 2d 1027, 1036 (Fla. 4th DCA 1998). A party's finances, if relevant to the disputed issues of the underlying action, are not exce

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 COUNTY, FLORIDA CASE NO.: 502009CA0408

ry responses responsive to Epstein's Requests. In support thereof, Epstein states: I Them are still outstanding damages discovery requests to which Edwards's Response is not due until after the Court's deadline date for the filing of this Motion. As such, an additional Motion may be required upon receip

ANSWER: Objection. Irrelevant, immaterial, not reasonably calculated to lead to the discovery of admissible evidence and an unwarranted invasion of Bradley Edwards' right to economic privacy. 15. State the amount of gross income that you received from the provision of goods or services other than while acting a

ily puts his personal financial information at issue, courts will compel production of personal financial information. Friedman, 863 So. 2d at 194; Woodward v. Berkey, 714 So. 2d 1027, 1036 (Fla. 4th DCA 1998). A party's finances, if relevant to the disputed issues of the underlying action, are not exce

n a December 2014 Florida court filing by Bradley Edwards and Paul G. Cassell meantigLigaugigaja the Crime

two Florida offenses. The judge left open what the possible remedy could be.1-1-.393 v. Epstein (2015) In a December 2014 Florida court filing by Bradley Edwards and Paul G. Cassell meantigLigaugigaja the Crime Victims (tights --Act la 't,' gni mg (then known as b, alleged in a sworn affidavit that at age

d soon be over.L46-A At the same time he acknowledged the opposite in a private conversation with Bob Woodward. In March 2020, Trump privately told Woodward that he was deliberately "playing it down" in public so as not to create panie.(469)[47o1 Initial response Trump was slow to address the spread of

. Bruce Reinhart, Esq. Bruce E. Reinhart, P.A. Brad Edwards, Esq. Rothstein Rosenfeldt Adler 40 l East Las

. Furney Charters, 212 F.R.D. at 590-91; see also Woodward v. Berkery, 714 So.2d I 027 (Fla. 4th DCA l 998)

London e . 0207-622 & 8738 (11) EFTA00191487 Edwards, Andrew & Tfti 9 ~ H uth 0 07-2354121 (h) p

138 Pavilion Road Eng of land tgerfund.com Woodall, Trinny 14 Thudoe Street , SW7 0207.581 8675 Woods Emil & Carrie 00001 (w) 001 fvil Woodward, Alexa alahl 1 323 356 3 88 (P) Woodward, Shaun & Camilla 70 Ladbroke Road London W11. 01608-659 617 (oxf.) 0207-233 2218 09unter 8 Tracey)

Newsnation (02/04, Whiteside), Washington Examiner (02/04, O'Keefe), New York Post (02/04, Oliveira), People (02/04, Raposas), WRC (NBC-4) (02/04, Edwards), WBBH (NBC-2) (02/04, Salas, Caudill), WTTG (FOX-5) (02/04, Barnard, Salamy), WBOC (CBS-16) (02/04, Video), Reuters (02/04, Shepardson), and the As

the Daily Beast (02/04, Archacki), Washington Times (02/04, Picket), Law 360 (02/04, Karp), New York Post (02/04, Christenson), Independent (02/04, Woodward), Newsweek (02/04, Whisnant, Sheth), BBC (02/04, Wendling), the New Republic (02/04, Rashid), Axios (02/04, Doherty), NBC News (02/04, Barnes, Dilan

row, Joseph. Fact and Fable in Psychology. Boston: Houghton, Mifflin, 1900. Kahn, David. The Codebreakers. New York: Simon & Schuster, 1967. Lucas, Edward. The Snowden Operation. Seattle: Amazon Digital Services, 2015. Morell, Michael J. The Great War of Our Time. New York: Twelve, 2015. Sebag-Montefi

itage /center_cryptologic_history/pearl_harbor_review/black_chamber.shtml. “Its far-seeking eyes”: Kahn, Codebreakers, 358. The NSA also organized: Woodward, Veil, 471-75. In 1980, President Ronald Reagan: David R. Shedd, “How Obama Unilaterally Chilled Surveillance,” Wall Street Journal, Nov. 30, 2015.

277—78 White House appointments and, 4, 36, 86-87, 89, 189, 285 Barra, Mary, 88 Barrack, Tom, 27-29, 33, 42, 85, 233, 240 Bartiromo, Maria, 205 Bass, Edward, 56 Bayrock Group, 100-102 Bedminster Golf Club, 165, 213-14, 216, 287-94, 297, 302, 307 Beinart, Peter, 297 Benghazi, 97 Berkowitz, Avi, 143 Berlusc

ncoln, USS, 182 Abramovich, Roman, 80 Adelson, Sheldon, 6, 141-43, 178, 289, 309 Afghanistan, 42, 263-68, 275-76 Agalarov, Aras, 254 Agenda, The (Woodward), 116 Ailes, Beth, 1, 4, 223-24 Ailes, Roger, 1-8, 11, 24, 26, 57, 59-60, 147, 164, 178-79, 195-98, 210, 212, 222-23 Alabama, 301-3 Al Shayrat air