Epstein Secrets

3432 7 8 ROTHSTEIN, ROSENFELDT & ADLER 9 BY: BRADLEY J. EDWARDS, ESQ., 401 East Las Olas Boulevard 10 Suite 1650 Fo

hat are involved 6 here, so we can get started. 7 Mr. Berger, go right ahead. 8 MR. BERGER: Good morning, Your Honor. 9 William J. Berger and Brad Edwards for the 10 moving parties, and that's who's the 11 Plaintiff in one case today, and then there's 12 III., who's a Plaintiff in another case th

rd to the 13 non-prosecution agreement and what happened. 14 If the Court will also recall, the NPA is 15 under, basically, a freeze order. Mr. Edwards, 16 on behalf of two of his Jane Does, tried to get 17 that order so it would become public. Judge 18 Marra said, no, and they keep trying and

76, and that was a decision of the Fifth District Court of Appeal, and I will quote headnote 3, "had the Petitioners brought their lawsuit against Ruzzo and the Board Room only under Section 769.09, evidence of Petitioner's past prostitution 8 including with the Board Room and their earnings 9 r

ourt they sit, is going to be entitled to a fair shake and a fair trial and entitled to the EFTA00776411 47 1 2 3 4 5 6 7 the Ballast vs. Ruzzo case. For the record, the citation is 703 So.2d. 1076, and that was a decision of the Fifth District Court of Appeal, and I will quote headnote 3,

Counsel for Plaintiffs In related Cases Nos. 08-80069, 08-80119, 08-80232, 08-80380, 08-80381, 08-80993, 08-80994 Richard Horace Willits, Esq. Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 Phone: 954-522-3456 Fax: 954-527-8663 bedwar

lanation for why victim exhibited behavioral manifestations of sexually abused child.). 14. In further support of Defendant's motion, See Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998), as it is on point to the discovery issues in this action, and the rele

ery in hopes that C.M.A. will be able to prevent Epstein from putting on any evidence in defense of his case. The remaining Plaintiffs 3 Attorney, Brad Edwards, in case number 08-CIV-080893, agreed to such a procedure. Counsel for Jane Does 2-7, Stuart Mermelstein, refuses to agree to such a procedure and,

08-cv-80119-KAM Document 104 Entered on FLSD Docket 05/19/2009 Page 9 of 13 Page9 States v. Bear Stops. 997 F.2d 451 (8th Cir. 1993); Balas v. Ruzzo, 703 So.2d 1076 (Fla. 5th DCA 1997), rev. denied, 719 So.2d 286 (Fla. 1998). The information sought in 4(e) is relevant and discoverable even if no