Epstein Secrets

1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: We are here on Epstein versus Rothstein and Edwards. The two applicable parties being dealt with -- have a seat, please. Thank you. -- being Mr. Epstein and Mr. Edwards, and the counterclaim brough

Mr. Edwards. THE COURT: Did he bring it against Rothstein's firm? I only have Rothstein individually -- MR. SCAROLA: Rothstein, individually and Bradley Edwards, individually. MR. LINK: My apologies. THE COURT: That statement is retracked. It's Rothstein individually and Edwards, individually. Mr. Scarola

file claims that were false. We are not taking about malice yet. Independent of any evidence that relates to malice, we get to prove the truth of Brad Edwards' underlying claims on behalf of L.M., E.W. and Jane Doe. So that then brings us -- THE COURT: I think I have already essentially ruled on that from

oof with regard to every element. It is also our position that the issue as to whether the underlying claim was bona fiably terminated in favor of Bradley Edwards is an issue of law for the Court. There are no disputed -- Mr. Edwards is present, yes. There are no disputed issues of fact with regard to what

T PROOFREAD EFTA00792856 47 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Fourth DCA decision called Frazier versus Security and Investments, 1993. What does Frazier tell us? Not only do we build off the US Supreme Court and say you have to have independ

cts were needed. On August 14, 2008, a hearing was held, during which a stipulated set of facts was discussed: THE COURT: So if I can hear from Mr. Edwards or Mr. Cassell first what the Plaintiffs' position [is] as far as where we stand on the record in terms of whether I need additional facts, evidenc

eed additional facts, evidence, or there's going to be a stipulation submitted to me upon which I can rely. MR. EDWARDS: Sure. Your Honor, this is Brad Edwards. I believe that you do have a sufficient record, in that I don't think that -- I think that we're in agreement that additional evidence does not ne

EFTA00208033 Case 9:08-cv-80736-KAM Document 75 Entered on FLSD Docket 05)02'2011 Page 11 of 12 DATED: May 2. 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice Attorneys for Jane Doe #1 and Jan

in and Groff that had nothing to do with the inner workings of the grand jury. There is abundant caselaw to that effect. See, e.g., United States.. Frazier, 944 F.2d 820, 825 (11th Cir. 1991) (even a witness who testifies before a grand jury is not required to keep his testimony secret); Blalock'. Unite

uld choose the more expansive interpretation. Not only is the CVRA "remedial legislation" that should be broadly construed to achieve its purposes, Edwards v. Kia Motors of America, Inc., 554 F.3d 943, 948 (11th Cir 2008), but the sponsors of the CVRA stated that the right to confer was "intended to be

an appropriate briefing schedule and hold a hearing on the appropriate remedy for those violations. DATED: May 2, 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, 27 EFTA00178083 Case 9:08-cv-80736-KAM Document 77 Entered on FLSD Docket 05/02/2011 Page 28 of 29

eed additional facts, evidence, or there's going to be a stipulation submitted to me upon which I can rely. MR. EDWARDS: Sure. Your Honor, this is Brad Edwards. I believe that you do have a sufficient record, in that I don't think that -- I think that we're in agreement that additional evidence does not ne

n and Groff that had nothing to do with the inner workings of the grand jury. There is abundant caselaw to that effect. See, e.g., United States v. Frazier, 944 F.2d 820, 825 (11th Cir. 1991) (even a witness who testifies before a grand jury is not required to keep his testimony secret); Blalock v. Unit