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ALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RENEWED MOTION FOR LEAVE TO DISCLOSE EXPERT WITNESS Pl
disclose an expert witness, and states: INTRODUCTION This case is currently not set for trial and, therefore, Counter-Plaintiff Bradley Edwards ("Edwards") will not be prejudiced by Epstein's renewed request to disclose his expert witness to opine on matters of legal ethics and responsibility, probabl
expert which is otherwise qualified to testify to what he's going to testify. (3/8/18 Aft. Tr. 93:16-20.) Indeed, "[a]s indicated in Binger v. King Pest Control, 401 So. 2d 1310 (Fla. 1981), the exclusion of an unlisted witness' testimony is a drastic remedy which should pertain in only the most compelling
EPSTEIN'S MOTION FOR IN CAMERA INSPECTION OF 30 E-MAILS Counter-Defendant Jeffrey Epstein ("Epstein") responds in opposition to Counter-Plaintiff Bradley J. Edwards' ("Edwards") November 13, 2018, Motion to Strike Epstein's Motion for in Camera Inspection of 30 E-Mails and states: INTRODUCTION Edwards knows onl
ividually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO EDWARDS' MOTION TO STRIKE EPSTEIN'S MOTION FOR IN CAMERA INSPECTION OF 30 E-MAILS Counter-Defendant Jeffrey Epstein ("Epstein") responds in opposition to C
l by way of memorandum, and that will be done under seal and will continue to be under seal, and will be filed under seal in case of Ringer v. King Pest Control, 401 So. 2d 1310 (Fla. 1981). 2 EFTA00808705 a need for appellate review. So that is going to be the direction of the Court, that the motion be
PALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR AN IN CAMERA INSPECTION OF 30 E-MAILS Counter-De
es to them. Following this Court's in camera review, Epstein seeks a ruling from this Court that these 30 e-mails, which were improperly withheld by Edwards, an officer of the court, on the false bases of irrelevancy, attorney-client privilege and inapplicable basis of work product3, should be unsealed,
Link & Rockenbach, PA discovered documents that were voluntarily produced years ago by Edwards to his potential adversaries at the 6Binger v. King Pest Control, 401 So. 2d 1310 (Fla. 1981). 3 EFTA00794279 time — the Razorback plaintiffs. These e-mails directly contradict Edwards' sworn testimony and pos
EPSTEIN'S MOTION FOR IN CAMERA INSPECTION OF 30 E-MAILS Counter-Defendant Jeffrey Epstein ("Epstein") responds in opposition to Counter-Plaintiff Bradley J. Edwards' ("Edwards") November 13, 2018, Motion to Strike Epstein's Motion for in Camera Inspection of 30 E-Mails and states: INTRODUCTION Edwards knows onl
ividually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO EDWARDS' MOTION TO STRIKE EPSTEIN'S MOTION FOR IN CAMERA INSPECTION OF 30 E-MAILS Counter-Defendant Jeffrey Epstein ("Epstein") responds in opposition to C
that any substantive discussion of those emails will be done under seal by way of memorandum, and that will be done under seal and 'Binger v. King Pest Control, 401 So. 2d 1310 (Fla. 1981). 2Excerpts of the November 2, 2018, Hearing Transcript are attached as Exhibit A. 2 EFTA00794299 will continue to b
Entities connected to both Bradley Edwards and Pest Control

Jeffrey Epstein
PERSONJane Doe
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSONMaria Farmer
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
Ghislaine Maxwell
PERSONSouthern District
LOCATION
United States
LOCATION
Prince Andrew
PERSONLeon Black
PERSONthe Southern District
LOCATION
Donald Trump
PERSON
Salt Lake City
LOCATION
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSON
Marc Rich
PERSON