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RIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro.120 I Plaintiff, Case No. 50 2009CA040800XXXXMB AG v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. AMENDED AND SUPPLEMENTAL MOTION OF PLAINTIFF TO OVERRULE OBJECTIONS AND COMPEL DEFENDANT EDWAR
on Friday, April 1, at 9:00 a.m., the following: EPSTEIN'S AMENDED AND SUPPLEMENTAL MOTION OF PLAINTIFF TO OVERRULE OBJECTIONS AND COMPEL DEFENDANT EDWARDS TO ANSWER QUESTIONS AND APPEAR FOR FURTHER DEPOSITION The following procedures must be noted on all specially set hearing notices in Division AG:
show that the communication was not privileged. Leithauser v. Harrison, 168 So. 2d 95 (Fla. 2d DCA 1964); see also Nationwide Mut. Fire Ins. Co. v. Harmon, 580 So. 2d 192, 192-93 (Fla. 4th DCA 1991) ("[N]othing in the record indicates that any documents are protected by the attorney/client privilege.
ISION AG CASE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. / PLAINTIFF JEFFREY EPSTEIN'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS BY DEFENDANT BRADLEY EDWARDS
gh his undersigned counsel, hereby respectfully seeks the entry of an Order compelling Defendant Bradley Edwards to produce the documents listed in Edwards' privilege log, or, in the alternative, the entry of an Order compelling Edwards to serve a privilege log that fully complies with Fla. R. Civ. P. 2
vilege extends only to "materials in question [which]were prepared in anticipation of litigation with respondents." Nationwide Mut. Fire Ins. Co. v. Harmon, 580 So. 2d 192, (Fla. 4th DCA 1991). Forty years ago, the Florida Supreme Court, in Sof Drugs, Inc. v. Vermette, 236 So. 2d 108, 112 (Fla. 1970),
more in- formation before deciding whether to quash a plea agreement that put Palm Beach billionaire Jeffrey Epstein be- hind bars for 18 months. Brad Edwards, a Hollywood attor- ney representing three girls who claim they were sexually abused by Epstein, appeared before U.S. District Judge Kenneth Marra
ctims not consulted in plea negotiations From Page Al County Jail, includes an agreement that the federal government will not prosecute Epstein. Edwards said his clients were not con- sulted when the plea deal was negotiated. The girls, each identified public- ly as a "Jane Doe," were about to be na
ment-sale brokers, Douglas Harmon of Eastdil, Tuesday afternoon, before she got into a black Lincoln in front of 40 W. 57th St., the building where Harmon is headquartered. Paris burger ad not for kids? PARIS Hilton is too hot for Washington. Lawmakers are working behind the scenes to get her sizzling
Florida jail were like only from the reporting of a local newspaper." Florida Today correspondents attempted "to fill in gaps about what happened to Edwards while he was in Brevard County Sheriff's Office custody on Dec. 10, 2018. But the agency refused to publicly share the security camera footage of a
n. Irish Prime Minister Micheal Martin: "We cannot and will not allow our children and young people's futures to be another victim of this disease." Harmon added, "In Ireland, England, Germany, and France, students are in the classroom." Asian Economies Recovering Fastest From Coronavirus. The Wall St
lorida jail were like only from the reporting of a local newspaper." Florida Today correspondents attempted "to fill in gaps about what happened to Edwards while he was in Brevard County Sheriff's Office custody on Dec. 10, 2018. But the agency refused to publicly share the security camera footage of a
. Irish Prime Minister Micheal Martin: "We cannot and will not allow our children and young people's futures to be another victim of this disease." Harmon added, "In Ireland, England, Germany, and France, students are in the classroom." Asian Economies Recovering Fastest From Coronavirus. The Wall St
lorida jail were like only from the reporting of a local newspaper." Florida Today correspondents attempted "to fill in gaps about what happened to Edwards while he was in Brevard County Sheriff's Office custody on Dec. 10, 2018. But the agency refused to publicly share the security camera footage of a
. Irish Prime Minister Micheal Martin: "We cannot and will not allow our children and young people's futures to be another victim of this disease." Harmon added, "In Ireland, England, Germany, and France, students are in the classroom." Asian Economies Recovering Fastest From Coronavirus. The Wall St
Epstein has said. He also owns Little St. James. a 70-acre island in the U.S. Virgin Islands. where the main house is currently being renovated by Edward Tut- tle. a designer of the Amanresorts. There is also a 56.8 million house in Palm Beach, Florida. and a fleet of aircraft: a Gulfstrcam IV. a he
ment-sale brokers, Douglas Harmon of Eastdil, Tuesday afternoon, before she got into a black Lincoln in front of 40 W. 57th St., the building where Harmon is headquartered. Paris burger ad not for kids? PARIS Hilton is too hot for Washington. Lawmakers are working behind the scenes to get her sizzling
lorida jail were like only from the reporting of a local newspaper." Florida Today correspondents attempted "to fill in gaps about what happened to Edwards while he was in Brevard County Sheriff's Office custody on Dec. 10, 2018. But the agency refused to publicly share the security camera footage of a
658934 Prime Minister Micheal Martin: "We cannot and will not allow our children and young people's futures to be another victim of this disease." Harmon added, "In Ireland, England, Germany, and France, students are in the classroom." Asian Economies Recovering Fastest From Coronavirus. The Wall St
Article: Criminal Enforcement Redundancy: Oversight of Decisions Not to Prosecute
. £. Rev. 33, 53-56 (2012); Rachel A. Harmon, Promoting Civil Rights Through Proactive Policing Reform, 62 Stan. L. Rev. I, 20-51 (2009) [hereinafter Harmon, Policing Reform]. 2 Human Rights Watch, Shielded from Justice: Police Brutality and Accountability in the United States 77-84, nn.149-72 (1998), ht
Page: HOUSE_OVERSIGHT_016513 →vania and New York relied heavily on private prosecutors for criminal law enforcement before 1850. See Stewart v. Sonneborn, 98 U.S. 187, 198 (1879) (Bradley, J., dissenting) ("Every man in the community, if he has probable cause for prosecuting another, has a perfect right, by law, to institute such prose
Page: HOUSE_OVERSIGHT_016526 →Entities connected to both Bradley Edwards and Harmon

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSONMaria Farmer
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATION
Prince Andrew
PERSONLeon Black
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Department of Justice
ORGANIZATIONMartin Weinberg
PERSON
Alexander Acosta
PERSON
Bill Clinton
PERSON