Epstein Secrets

a E-Mail Joseph lanno, Jr. Carlton Fields 525 Okeechobee Blvd. Suite 1200 West Palm Beach, FL 33401 Re: Jeffrey Epstein v. Scott Rothstein and Bradley J. Edwards 15'h Judicial Circuit Case No. 50-2009-CA-040800XXXXMBAG In re Rothstein Rosenfeldt Adler, P.A. U.S. Bankruptcy Court, Southern District of Florid

ter, however, felt comfortable asserting privilege claims on behalf of Bradley Edwards' clients and the task was assigned to Farmer Jaffe (where Mr. Edwards was a partner). In order to conduct the review, Farmer Jaffe wanted the 27,000 pages printed and Bates stamped so it could segregate out alleged pr

ained images or copies of the subject documents on its computer or otherwise, the Court retains jurisdiction to award sanctions in favor of Fanner, Brad Edwards or his client [L.M.j. As has been documented, during our review of Fowler White's files in January 2018, we found a disc labeled "Epstein Bate Sta

res, Inc. v. Berlowitz, 211 So. 3d 259, 263 (Fla. 4th DCA 2017). Even when a release pertains to claims the parties ever had, now have or can have, the Third District found it would only encompass claims that had matured at the time of signing the release. SoUile v. Gaines Const. Co., 281 So. 558, 560-61 (Ha. 3d D

N THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. BRADLEY J. EDWARDS, et al., Defendant/Counter-Plaintiffs. No. 50-2009-CA-040800XXXXMBAG JUDGE HAFELE PLAINTIFF/COUNTER-DEFENDANT'S RESPONSE IN OPPOSITION TO: DEFE

t this Court's consideration of the probable cause issue raised in Epstein's motion for summary judgment is barred by the law of the case doctrine. Edwards argues that the probable cause issue was raised by Epstein as a point on appeal in Edwards v. Epstein, 178 So. 3d 942 (Fla. 4th DCA 2015), and that

Gabor & Co., Inc., 599 So. 2d 737 (Fla. 3d DCA 1992) "is directly on point." Motion to Strike at 5. Gabor is clearly distinguishable. In that case, the Third District held that, based upon law of the case, "it was error for the trial court to enter summary judgment on a point previously determined [on appeal] not

3301 54)467-1223 Attorneys for Jeffrey Epstein Bradley J. Edwards, Esq. FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHR

f/Counter-Defendant's Motion for Fees and Costs, and as grounds therefor would state: INTRODUCTION This case arises from Epstein's lawsuit against Edwards, when Epstein sued Edwards merely for his legal representation of people accusing Epstein of misconduct. Edwards counter- sued Epstein for, inter al

e, even though Epstein is a non-lawyer. This Court dismissed Edwards' lawsuit, concluding it was bound under case precedent from a single case from the Third District to apply the litigation privilege. Epstein seeks attorneys' fees pursuant to his Proposal for Settlement served in 2011. Over Edwards objection, I

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:

did not have to respond to questioning regarding the initial conversation that took place between Diaz and him. On petition for writ of certiorari, the Third District concluded that the trial court had departed from the essential requirements of the law by directing that Rabin need not respond to questions about w

IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 EDWARDS, et al., Plaintiffs / Counterclaim Defendants, v. DERSHOWITZ, Defendant / Counterclaim Plaintiff. DEFENDANT / COUNTERCLAIM PLAINTIFF ALAN DERSHO

king and who would prefer to avoid public attention.' Nothing could be further from the truth. This case began when Jane Doe No. 3 and her lawyers, Bradley J. Edwards ("Edwards") and Paul G. Cassell ("Cassell"), made a deliberate decision to file a pleading in a federal lawsuit accusing Dershowitz of committing a

tain information that had no "possible relevance" to the issues in dispute. For example, in Calvo v. Calvo, 489 So. 2d 833, 834 (Fla. 3d DCA 1986), the Third District held that an ex-wife's financial records had no "possible relevance" to her post-judgment action seeking to compel payments that the ex-husband owed

IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 EDWARDS, et al., Plaintiffs / Counterclaim Defendants, v. DERSHOWITZ, Defendant / Counterclaim Plaintiff. DEFENDANT / COUNTERCLAIM PLAINTIFF ALAN DERSHO

king and who would prefer to avoid public attention.' Nothing could be further from the truth. This case began when Jane Doe No. 3 and her lawyers, Bradley J. Edwards ("Edwards") and Paul G. Cassell ("Cassell"), made a deliberate decision to file a pleading in a federal lawsuit accusing Dershowitz of committing a

tain information that had no "possible relevance" to the issues in dispute. For example, in Calvo v. Calvo, 489 So. 2d 833, 834 (Fla. 3d DCA 1986), the Third District held that an ex-wife's financial records had no "possible relevance" to her post-judgment action seeking to compel payments that the ex-husband owed