Epstein Secrets

Florida Rule of Civil Procedure 1.470, files this Notice of Proposed Jury Instructions and Verdict Form. Epstein adopts Defendant/Counter-Plaintiff Bradley J. Edwards' ("Edwards") November 9, 2017, proposed Standard (Civil) Jury Instructions Nos. 201.3, 202.2, 202.3, 202.4, 301.1, 301.2, 301.3, 301.4, 301.5, 406.1

Procedure 1.470, files this Notice of Proposed Jury Instructions and Verdict Form. Epstein adopts Defendant/Counter-Plaintiff Bradley J. Edwards' ("Edwards") November 9, 2017, proposed Standard (Civil) Jury Instructions Nos. 201.3, 202.2, 202.3, 202.4, 301.1, 301.2, 301.3, 301.4, 301.5, 406.1, 406.3, 4

JURY INSTRUCTION NO. 33 !BIFURCATED ISSUE! 503.2 PUNITIVE DAMAGES' There is an additional claim in this case that you must decide. If you find for Bradley Edwards and against Jeffrey Epstein, you must decide whether, in addition to compensatory damages, punitive damages are warranted as punishment to Jeffrey E

re as follows: Plaintiff Jeffrey Epstein claims that Defendant Scott Rothstein conspired with other lawyers and employees at the firm of Rothstein, Rosenfeld and Adler, for personal greed and enrichment, and engaged in a pattern of racketeering that involved, among other things, marketing of non-existent

stand. 13 order that he entered. And I'll quote fron it. I) Good afternoon. Jack Goldberger on behalf of la This is Order on Counter-plaintiff Bradley Edwards' la Mr. Epstein. 14 Motion to Deternine Status of Punitive Damage IS Your Honor, as a general statement of the lax, Is Discovery and Applicabi

Y EDWARDS, individually, , going to hoar? boranciants/countor -Plaintiffs. 10 THE COURT: Yes. My understanding as I left / 11 Was going to be Edwards' Second Supplement to TRANSCRIPT OF PROCEEDINGS 12 Motion in Lunine Addressing Scope of Admissible I) Evidence, and of course in that same vein

uct privileged 14 bearing the expense to turn these docunents over to is materials. So Judge Carney was appointed a special IS Earner Jaffe and Bred Edwards for purposes of it master to make a determination as to what should 16 preparing a privilege log. 17 and could be turned over and report back t

implosion of the Rothstein, 20 it docunonts, chat wore sent co us not covering all of the 724. And obviously, your Honor knows from the 2s , 31 Rosenfeld[, Adler urn a trustee was appointed by the bankruptcy court to take control of the firm, 22 materials that you have reviewed much attention was =

stand. 13 order that he entered. And I'll quote fron it. I) Good afternoon. Jack Goldberger on behalf of la This is Order on Counter-plaintiff Bradley Edwards' la Mr. Epstein. 14 Motion to Deternine Status of Punitive Damage IS Your Honor, as a general statement of the lax, Is Discovery and Applicabi

last wok just 4 and Any Reference to Docunenta Containing 4 So my suggestion to your Honor is that wo deal 5 Privileged Materials, Listed on Edwards' Privilege o first with the procedural issue because, as I said, 4 Log. 4 that will narrow issue. significantly. And then / MR. SCAROER: Yes,

uct privileged 14 bearing the expense to turn these docunents over to is materials. So Judge Carney was appointed a special IS Earner Jaffe and Bred Edwards for purposes of it master to make a determination as to what should 16 preparing a privilege log. 17 and could be turned over and report back t

implosion of the Rothstein, 20 it docunonts, chat wore sent co us not covering all of the 724. And obviously, your Honor knows from the 2s , 31 Rosenfeld[, Adler urn a trustee was appointed by the bankruptcy court to take control of the firm, 22 materials that you have reviewed much attention was =

amination by Mr. Lick SS Vs. 7 Redirect Examination by Mr. Scarola 131 SCOTT 0.0TNSTBIN, individually; 0 Rocones-Exaninatien by Mr. Lick 138 BRADLEY EDWARDS, Individually, 9 Further Redirect Examination by Mr. Scarola 160 Defendants/Counter-Plaintiff. 10 Certificate of Oath 170 / 11 Certificate

5 5 Berger in the matter of Jeffrey 5 APPEARANCES: 6 For Plaintiff: 4 Epstein versus Scott Rothstein and Bradley 7 LINK 4 ROCKENBACH, . Edwards. 1555 Palm Beach Lakes Boulevard, Suite 301 0 9 West Palm Beach, FL 33401 By SCOTT J. LINK, ESQUIRE , This deposition is being hold 2255 Glad

would moan -- for example, 1 when you aay -- it wasn't during the time of the 2 Mr. Scarola's firm represented a client against 2 Rothstein -- Brad Edward➢ wasn't working for the ) Mr. Epstein, right? ) Rothstein firm, I don't believe, when this happened. 4 A Correct. 4 Q When he settled? 5 Q

r election Improprieties? A Yee. 9 MR. LINK: I change the question as I 1 Q How about your really good friend 10 go. I can do that. 10 Mr. Rosenfeld? 11 BY HR. LINK: II A Sams thing. 12 0 So, Mr. Borger -- 12 0 Same thing. 13 MR. SCAROLA: So as long as the record 13 So these are peopl

EFTA00299866 Settlement Agreements (Located on the floor next to file cabinet #1) and Dismissals -Video Depositions and DVD that could be used in Brad Edwards Case (SENT THE DVD TO JAY LEFKOWITZ ON OCT. 14, 2010) (Signed Settlement) . (Signed Settlement, Stipulation of Dismissal, Final Order of Dismissal) (S

eo Depositions and DVD that could be used in Brad Edwards Case (SENT THE DVD TO JAY LEFKOWITZ ON OCT. 14,

-Video Depositions and DVD that could be used in Brad Edwards Case (SENT THE DVD TO JAY LEFKOWITZ ON OCT. 14,

BINET ONE GR.M#004 740697 CMA vs. JEE and Correspondence Summons and Complaint JEE Summons and Complaint Motion, Notice and Order of Dismissal Rosenfeld( vs. Rothstein Doe 1 Case #6596 Doe II Case # 20614 Document Production Doe II Case # 20614 Jane Doe 8 Case # 80802 Jane Doe 102 Case # 80656 C

ntial Profes.f Criminal Law Telephone: [email protected] September 29, 2011 Re: Follow-up on Jeffrey Epstein Dear Mr. Ferrer: As you know, Brad Edwards and I represent Jane Doe #1 and Jane Doe #2 in their efforts to protect their rights under the Crime Victims' Rights Act. You were nice enough to m

Boulevard Miami, FL 33160 16 For Jane Doe 17 BRADLEY J. EDWARDS, ESQ. Rothstein Rosenfeldt Adler 18 401 East Las Ola

l state their appearances? 4 MR. HOROWITZ: Adam Horowitz, counsel for plaintiffs 5 Jane 2 through Jane Doe 7. 6 THE COURT: Good morning. 7 MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane 8 Doe. 9 THE COURT: Good morning. 10 MR. GARCIA: Good morning, Your Honor. Sid Garcia for 11 Jane Doe

3 4220 43:14 44:8 rights 13:5 25:16 32:7 isk 9:6 10:6,7 18:25 38:6 40:10 41:6,11 risks 21:5 Robert 2:1,8 4:2 6:3 role 25:13 37:7 Room 2:23 Rosenfeld* 1:17 rose-colored 11:16 Rothstein 1:17 RPR-CM-RMR-F- 44:21 RPR-RMR-FCRR-. 2:21 rule 39:9 42:13 ules 22:3 25:1 3424 40:15 42:13 ruling 8:25

Worn, Tallahassee hi, EFTA00616223 MAR-15-2011 TUE 05:39 PM FAX NO. P. 03/07 JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. IN THE CIRCUIT COURT OF THE 15711 JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. Ca

. Florida 33301 lallansit• EFTA00616225 MAR-15-2011 TUE 05:39 PM FAX NO. P. 05/07 SERVICE LIST Jeffrey Epstein v. Scott Rothstein, Bradley 3. Edwards and L.M. Caso No. 50 2009CA040800XXXXMB AG Mr. Robert D. Critton, Jr., Esq. Burman Critton Luttier & Coleman 303 Banyan Boulevard Suite 400 Wes

1. First, jurisdiction over RRA rests in the United States Bankruptcy Court for the Southern District of Florida in the case of In Re: Rothstein, Rosenfeld and Adler, Case No. 09- 34791-BKC-RER. This Court has effectively recognized as much in a prior subpoena issued upon Mr. Stettin, RBA's Trustee. Mor