Epstein Secrets

FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FL JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No. 50 2009 CA 040800XXXXMBAG v. BRADLEY J. EDWARDS, et al., Defendants/Counter-Plaintiff. JUDGE: HAFELE JEFFREY EPSTEIN'S RESPONSE TO BRADLEY EDWARDS'S MOTION IN LIMINE TO STRIKE THE JUNE 30.2017

ion for Summary Judgment, and to "exclude evidence as to which discovery was withheld under claims of privilege." As demonstrated more fully below, Edwards's Motion is deficient on its face, and in direct contravention to the facts. As such, Edwards's Motion should be denied. INTRODUCTION Epstein file

that there were other media, local media. I've been told that the -- his investigator was sent to California to harass people representing his -- Brad Edwards' investigator -- representing fictitiously, fraudulently that he was a FBI agent to try to gather information for Mr. Edwards' claims. See Depositi

sitting over their computer looking at their bank accounts. So, unfortunately, I would have to say, no, sir. Q. Have you ever personally witnessed Bradley Edwards engaged in money laundering? MR. PIKE: Form. THE WITNESS: Again, sir, the U.S. Attorney's Complaint of the Rothstein firm alleges money laundering

l case. In re EFTA00582836 Carp, 340 F.3d 15, 23 (1st Cir. 2003); Baxter v. Pabnigiano, 425 U.S. 308 (1976). See also Doe ex rel. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1264 (9th Cir. 2000) ("The Baxter holding is not a blanket rule that allows adverse inferences to be drawn from invocations of the p

This Improver Motion Practice And Have No Demonstrable Need For More Several depositions have occurred over the last 4 weeks wherein it appears Mr. Edwards already has the information he seeks responsive to these requests, which is likely the reason Mr. Edwards has not filed any affidavits supporting t

ached to the NPA is a list which delineates alleged victims. Once the NPA was made public, Judge Colbath, with the agreement of the Palm Beach Post, Brad Edwards, Esq. and Spencer Kuvin, Esq. agreed that the "list" would remain private. As such, Request for Production Numbers 7, 9 and 10 seeks information th

ts is considered testimonial and is protected by the Fifth Amendment. See In re Grand Jury Subpoena, 1 F.3d 87, 93 (2nd Cir. 1993); Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9th Cir. 2000Xthe "privilege" against self-incrimination does not depend upon the likelihood, but upon the possibility of pros

lbath, with the agreement of the Palm Beach Post, Brad Edwards, Esq. and Spencer Kuvin, Esq. agreed that the "l

This Improper Motion Practice And Have No Demonstrable Need For More Several depositions have occurred over the last 4 weeks wherein it appears Mr. Edwards already has the information he seeks responsive to these requests, which is likely the reason Mr. Edwards has not filed any affidavits supporting t

ts is considered testimonial and is protected by the Fifth Amendment. See In re Grand Jury Subpoena, 1 F.3d 87, 93 (2nd Cir. 1993); Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9th Cir. 2000)(the "privilege" against self-incrimination does not depend upon the likelihood, but upon the possibility of pro

lsouth.net Counsel for Defendant Jeffrey Estein Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos &

3401-5012 561-659-8300 Fax: 561-835-8691 i [email protected] Counsel for Defendant Jeffrey Estein Brad Edwards, Esq. Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue Suite 2 Fort Lauderdale, FL 33301 Phone: 954-524-2820 Fax: 954-524-2822 [email protected] Co

s is considered testimonial and is protected by the Fifth Amendment. See In re Grand Jury Subpoena, 1 F.3d 87, 93 (2nd Cir. 1993); Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9 th Cir. 2000)(the "privilege" against self-incrimination does not depend upon the likelihood, but upon the possibility of p

nfra, the federal government provided Epstein with the NPA and the list attached thereto. The NPA is now a public document and the list, pursuant to Brad Edward's Agreement with Judge I. Colbath, remains confidential. 2 FRE 410(4) is particularly directed to communications in matters which, like Epstein's, di

y transmit passenger and crew manifest information for all flights arriving into and/or departing out of the United States. As this court knows, Mr. Edwards has conducted extensive discovery, has questioned individuals as to whether Epstein owns private aircraft and has obtained certain flight manifests

nts is considered testimonial and is protected by the Fifth Amendment. ao in re Grand Jury Subpoena, 1 F.3d 87, 93 (2nd Cir. 1993); Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9th Cir. 2000Xthe "privilege" against self-incrimination does not depend upon the likelihood, but upon the possibility of pro

Esq. Searcy Denney Scarola Barnhart & Shipley, Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las O

uired to produce and/or testify. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9th Cir. 2000)(the "privile

elief in this regard should be denied. (ii) Mr. Edwards Already Has the Information He Seeks Pursuant to

by the Constitution." DE 480 See Rudy- Glanzer v. Glanzer, 232 F.3d at 1263 (the "privilege" against self-i

ein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Adam D. Horowitz, Esq. Mermelstein & Horowitz, P.A. 18205 Biscayne Boulevard Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Case 9:08-cv-80119-KAM Document 342 Entered on FLSD Docket 10/06/20

d testimony and information that may, directly or indirectly, furnish Plaintiff a clue or link in the chain of evidence used to prosecute him. Rudy- Glanzer v. Glanzer, 232 F.3d at 1263(the "privilege" against self-incrimination does not depend upon the likelihood, but upon the possibility of prosecution

the NP A is a list which delineates alleged victims. Once the NP A was made public, Judge Colbath, with the agreement of the Palm Beach Post, Brad Edwards, Esq. and Spencer Kuvin, Esq. agreed that the "list" would remain private. As such, Request for Production Number IO seeks information that may vio

s is considered testimonial and is protected by the Fifth Amendment. See In re Grand Jury Subpoena, 1 F.3d 87, 93 (2nd Cir. 1993); Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9th Cir. 2000)(the "privilege" against self-incrimination does not depend upon the likelihood, but upon the possibility of pr

th Avenue North Suite 404 Lake Worth, FL 33461 Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las O

quired to produce and/or testify. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1263 (9th Cir. 2000)(the "privil