Epstein Secrets

The Palm Beach Post's (the "Post") Motion to Intervene and Petition for Access to certain court records in this case. It is our understanding that Bradley Edwards and William Berger of Rothstein Rosenfeldt Adler have filed a similar motion on behalf of a non-party known as =11 and that a motion is set for he

• •••••••• ••••••••••••••• • To: R. Alexander Acosta, Esq. Fax: Judith Stevenson Arco, Esq. Michael McAuliffe, Esq, Jack Alan Goldberger, Esq. Brad ley J. Edwards, Esq. William J. Berger, Esq. From: Deanna K. Shullman, Esq. Date: 06/01/2009 Re: State v. J. Epstein Pages: 6 Urgent U For review U I Pl

el for Plaintiff in Related Case No. 80811 Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las O

hael McAuliffe, Esq. Jack Alan Coldberger, Esq. Bradley J. Edwards, Esq. William J. Berger, Esq. From: »minne K. Shullm

of North America v. Gore, 116 S.Ct 1589 (1996)• Philip Morris USA v. Williams, 127 S.Ct. 1057 (2007)• State Farm v. Campbell, 123 S.Ct 1513 (2003); Engle v. Ligget Group, Inc., 945 So.2d 1246 (Fla. 2006). The Due Process Clause of the Fourteenth Amendment of the United States Constitution and Florida

ail: Paul G. Cassell, Esq. (Motion for Pro Hac Vice Admission Pending) 332 S. 1400 E. Salt Lake Ci Utah 84112 Tel.: Fax: E-Mail Counsel for Bradley James Edwards EFTA00728061 TABLE OF CONTENTS PRELIMINARY STATEMENT 1 FACTUAL AND PROCEDURAL BACKGROUND 3 I. EPSTEIN'S SEXUAL ABUSE OF MINOR GIRLS AND HIS

EPSTEIN ABOUT HIS SEXUAL MOLESTATION AND ITS DISCLOSURE OF THE CONTENTS OF RECORED CONVERSATION TO THIRD PARTIES 5 IV. EPSTEIN'S ACTION AGAINST EDWARDS AND EDWARDS' COUNTERCLAIM 7 V. FEDERAL COURT ORDER FOR PRODUCTION OF THE RECORDING ? VI. EPSTEIN'S INVOCATION OF THE FIFTH IN THE EDWARDS ACTIO

atutes 18 U.S.C. § 2255 4 CPLR 3102(e) passim N.Y. Civil Rights Law § 79-h(g) (McKinney 2010) 11, 14 iv EFTA00728065 PRELIMINARY STATEMENT Bradley Edwards seeks an order pursuant to CPLR 3102(e) for production of a tape recording of a conversation between a Daily News reporter and billionaire Jeffrey E

. 1990) Cooper Indus., Inc. v. Leatherman Tool Group, Inc., 532 U.S. 424 (2001) Doe No. 102 v. Epstein, No. 9:09-CV-80656-1CAM (S. D. Fla. 2009) Engle v. Liggett Group, Inc., 9 15 fn. 2 945 So.2d 1246 (Fla. 2006) 15 E.W. v. Epstein, Case No. 502008CA028XXXMBAB (Florida Circuit Court) 4 Gonz

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

4 So. 2d 1092, 1093 (Fla. 3d DCA 1998) (an argument in a footnote does not elevate the matter to a point on appeal."); R.J. Reynolds Tobacco Co. v. Engle, 672 So. 2d 39, 41 n.1 (Fla. 3d DCA 1996) (arguments which are not made as a point on appeal but are found only in a footnote are not properly pres

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 DEFEN

on for Summary Tonga Haddad. P.A. • 315 SE 7th Street, Fon Lauderdale, FL 33301. EFTA00808559 Judgment is batted 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

So. 2d 1092, 1093 (Fla. 3d DCA 1998) ("an argument in a footnote does not elevate the matter to a point on appeal."); R.J. Reynolds Tobacco Co. v. Engle, 672 So. 2d 39, 41 n.1 (Fla. 3d DCA 1996) (arguments which are not made as a point on appeal but are found only in a footnote are not properly prese

Case 9:08-cv-80893-KAM Document 38 Entered on FLSD Docket 04/17/2009 Page 17 of 18 Respectfully Submitted, Plaintiff, by One of Her Counsel, s/ Bradley J. Edwards Bradley J. Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33301 Telephone

Senator Kerry refers to the statutorily imposed damage amount as "penalties." Id. The cases of U.S. v. Siegel, supra (11th Cir. 1998), and U.S. v. Edwards, supra (3d Cir. 1998), also support Defendant's position that application of the current version of 18 U.S.C. §2255 would be in clear violation of

of North America v. Gore, 116 S.Ct 1589 (1996); Philip Morris USA v. Williams, 127 S.Ct. 1057 (2007); State Farm v. Campbell, 123 S.Ct 1513 (2003); Engle v. Liqoet Group, Inc., 945 So.2d 1246 (Fla. 2006). The Due Process Clause of the Fourteenth Amendment of the United States Constitution and Florida