Epstein Secrets

FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FL JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No. 50 2009 CA 040800XXXXMBAG v. BRADLEY J. EDWARDS, et al., Defendants/Counter-Plaintiff. JUDGE: HAFELE JEFFREY EPSTEIN'S RESPONSE TO BRADLEY EDWARDS'S MOTION IN LIMINE TO STRIKE THE JUNE 30.2017

ion for Summary Judgment, and to "exclude evidence as to which discovery was withheld under claims of privilege." As demonstrated more fully below, Edwards's Motion is deficient on its face, and in direct contravention to the facts. As such, Edwards's Motion should be denied. INTRODUCTION Epstein file

that there were other media, local media. I've been told that the -- his investigator was sent to California to harass people representing his -- Brad Edwards' investigator -- representing fictitiously, fraudulently that he was a FBI agent to try to gather information for Mr. Edwards' claims. See Depositi

sitting over their computer looking at their bank accounts. So, unfortunately, I would have to say, no, sir. Q. Have you ever personally witnessed Bradley Edwards engaged in money laundering? MR. PIKE: Form. THE WITNESS: Again, sir, the U.S. Attorney's Complaint of the Rothstein firm alleges money laundering

king of Epstein's affidavit is warranted. Edwards does not contend that Epstein failed to comply with a court order as contemplated by Rule 1.380 of the Florida Rules of Civil Procedure; nor does Edwards assert that Epstein's affidavit contains material that should be stricken from a pleading as delineated in Rule 1.140 o

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408003OOOCMBAG

502009CA0408003OOOCMBAG JUDGE: HAFELE Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S UPDATED RESPONSES TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S NET WORTH INTERROGATORIES TO JEFFREY EPSTEIN Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pu

v. United States, 341 U.S. 479, 486 (1951); Ohio v Reiner, 532 U.S. 17 (2001). My concern is in part derived from the continued efforts utilized by Edwards in the case of Doe v United States ("the CVRA case"). I cannot provide answers/responses to questions relating to my financial history and condition

ES TO JEFFREY EPSTEIN Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure hereby files his amended responses to Defendant/Counter-Plaintiff Bradley Edward's Net Worth Interrogatories to Jeffrey Epstein: I. Wha

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408003OOOCMBAG

: 502009CA0408003OOOCMBAG JUDGE: CROW Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S UPDATED RESPONSES TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S NET WORTH INTERROGATORIES TO JEFFREY EPSTEIN Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pu

. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. IN THE CIRCUIT COURT OF THE FIF

ES TO JEFFREY EPSTEIN Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure hereby files his amended responses to Defendant/Counter-Plaintiff Bradley Edward's Net Worth Interrogatories to Jeffrey Epstein: I. Wha

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408003OOOCMBAG

502009CA0408003OOOCMBAG JUDGE: HAFELE Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S UPDATED RESPONSES TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S NET WORTH INTERROGATORIES TO JEFFREY EPSTEIN Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pu

v. United States, 341 U.S. 479, 486 (1951); Ohio v Reiner, 532 U.S. 17 (2001). My concern is in part derived from the continued efforts utilized by Edwards in the case of Doe v United States ("the CVRA case"). I cannot provide answers/responses to questions relating to my financial history and condition

ES TO JEFFREY EPSTEIN Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.350 of the Florida Rules of Civil Procedure hereby files his amended responses to Defendant/Counter-Plaintiff Bradley Edward's Net Worth Interrogatories to Jeffrey Epstein: I. Wha

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408

ry responses responsive to Epstein's Requests. In support thereof, Epstein states: I Them are still outstanding damages discovery requests to which Edwards's Response is not due until after the Court's deadline date for the filing of this Motion. As such, an additional Motion may be required upon receip

ANSWER: Objection. Irrelevant, immaterial, not reasonably calculated to lead to the discovery of admissible evidence and an unwarranted invasion of Bradley Edwards' right to economic privacy. 15. State the amount of gross income that you received from the provision of goods or services other than while acting a

e work product privilege. This contention fails for two reasons: First, Edwards failed to properly assert the privilege as mandated by Rule 1.280 of the Florida Rules of Civil Procedure and prevailing case law, see TIG Insurance Corp. of America v. Johnson, 799 So. 2d 7 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauder

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408

ry responses responsive to Epstein's Requests. In support thereof, Epstein states: I Them are still outstanding damages discovery requests to which Edwards's Response is not due until after the Court's deadline date for the filing of this Motion. As such, an additional Motion may be required upon receip

ANSWER: Objection. Irrelevant, immaterial, not reasonably calculated to lead to the discovery of admissible evidence and an unwarranted invasion of Bradley Edwards' right to economic privacy. 15. State the amount of gross income that you received from the provision of goods or services other than while acting a

e work product privilege. This contention fails for two reasons: First, Edwards failed to properly assert the privilege as mandated by Rule 1.280 of the Florida Rules of Civil Procedure and prevailing case law, see TIG Insurance Corp. of America v. Johnson, 799 So. 2d 7 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauder

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408

ry responses responsive to Epstein's Requests. In support thereof, Epstein states: I Them are still outstanding damages discovery requests to which Edwards's Response is not due until after the Court's deadline date for the filing of this Motion. As such, an additional Motion may be required upon receip

ANSWER: Objection. Irrelevant, immaterial, not reasonably calculated to lead to the discovery of admissible evidence and an unwarranted invasion of Bradley Edwards' right to economic privacy. 15. State the amount of gross income that you received from the provision of goods or services other than while acting a

e work product privilege. This contention fails for two reasons: First, Edwards failed to properly assert the privilege as mandated by Rule 1.280 of the Florida Rules of Civil Procedure and prevailing case law, see TIG Insurance Corp. of America v. Johnson, 799 So. 2d 7 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauder

. CML TRIAL & APPELLATE LAW December 1, 2017 Via Email Jeffrey Epstein 6100 Red Hook Quarter, B3 St. Thomas, USVI 00802 Re: Jeffrey Epstein v. Bradley J. Edwards File No.: 100.001 1555 Palm Beach Lakes Blvd , Suite 301 West Palm Beach, Fronde 33401 T 561.727 3600 F 561.727 3601 Dear Jeffrey: Attached pl

are summary of Judge's ruling from the October 3, 2017 hearing 1.90 750.50 re J. Epstein's Motion to Overrule Objections and Compel B. 395.00/hr Edwards to answer questions in preparation of B. Edwards' upcoming deposition KBR Review executed Order Specially Setting Hearing from Judge Donald 0.10

mended Exhibit and Witness Lists AMM Analyze case law in support of our Supplemental Motion for 1.10 434.50 Continuance pursuant to Rule 1.460 of the Florida Rules of Civil 395.00/hr Procedure AMM Conduct research re how do we authenticate website articles and 2.10 829.50 website postings 395.00/hr AMM Prepare me

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408

) of the Florida Rules of Civil Procedure, hereby moves this Court for entry of an order directing Defendant/Counter-Plaintiff Bradley J. Edwards ("Edwards") to respond to questions asked of him at his deposition taken on March 23, 2010, and again on May 15, 2013, and to such follow up questions as are

ter of these objections were speaking objections by Edwards's counsel that went beyond the scope of what is permitted in a deposition as provided in the Florida Rules of Civil Procedure and relevant case law. As this analysis demonstrates, Edwards neither complied with the spirit of Rule 1.130(c) of the Florida Rules of

OR PALM BEACH COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, VS. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter- Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR FEES AND COSTS AND INCORPORATED MEMORANDUM

is Motion requesting that the Court enter an Order of entitlement to costs and attorneys' fees against Defendant/Counter-Plaintiff Bradley Edwards ("Edwards"). In support of thereof, Epstein states as follows: INTRODUCTION On August 25, 2011, Epstein served an Offer of Judgment on Edwards in the amount

ust 25, 2011, Epstein served an Offer of Judgment on Edwards in the amount of three hundred thousand dollars ($300,000.00) pursuant to Rule 1.442 of the Florida Rules of Civil Procedure and §768.79 of the Florida Statutes (the "Offer"). A true and correct copy of same is attached hereto as "Exhibit A." Edwards failed to a