Epstein Secrets

es Blvd. Suite 930 W • • • • 7 01 Jeffrey Epstein 6100 Red Hook Quarter, B3 St. Thomas, USV 00802 CLIENT: 0002 - Jeffrey Epstein Re: 0001 Bradley Edwards Date Services 05/01/18 TLC Work on Motion to Compel B. Edwards to Identify Witnesses who will be called at trial to incorporate D. Indyke's sug

CLIENT: 0002 - Jeffrey Epstein Re: 0001 Bradley Edwards Date Services 05/01/18 TLC Work on Motion to

whether a denial of writ petition without prejudice to appeal from final order Is a favorable disposition 05/09/18 KBR Conduct legal research re B. Edwards' citation to two cases as basis for conditional fee entitlement in certiorari proceeding; key cite cases and broaden search re 9.400 fee entitlemen

, 2018, dismissing mandamus petition as moot and denying both parties' fees); work on Response to B. Edwards' Motion for Hearing and Order denying B. Edwards' conditional entitlement to appellate fees; telephone conference with D. Indyke re Response, discussion re 9.400, discretion of appellate court, go

. 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

e page/line damage summary re B. Edwards deposition 1.10 434.50 testimony dated March 23, 2010 395.00/hr AMM Prepare page/line damage summary re B. Edwards' deposition 0.80 316.00 testimony dated May 15, 2013 395.00/hr 11/8/2017 TLC Continue working on preparations for B. Edwards' deposition; work

BACH9 PA April 10, 2018 Via Email jeevacationegmaitcom Jeffrey Epstein 6100 Red Hook Quarter, 83 St. Thomas, USVI 00802 Re: Jeffrey Epstein v. Bradley J. Edwards File No.: 2.0001 Dear Jeffrey: 1555 Palm Beach Lakes Blvd., Suite 301 West Palm Beach, FL 33401 TEL (561) 727-3600 I FAX (561) 727-3601 Attache

Addressing the Admissibility of Edwards' Exhibit 132; (12) Epstein's Motion in Limine re Sex Offender Registry; (13) Epstein's Motion in Limine on Edwards' Newly Disclosed Exhibits; (14) Epstein's Request for Judicial Notice; and (15) Objections to Deposition Designations; assemble hearing notebooks

th opposing counsel re hearing and production of audio; work on chronology; begin reviewing new public records 03/01/18 KBR Prepare objections to B. Edwards' deposition designations and consider counter-designations; attend trial team strategy meeting; prepare/revise motion to redact names and alter tri

& APPELLATE LAW LINK& ROCKENBACH, PA August 14, 2018 Jeffrey Epstein 6100 Red Hook Quarter, B3 St. Thomas, USVI 00802 Re: Jeffrey Epstein v. Bradley J. Edwards File No.: 2.0001 Dear Jeffrey: 1555 Palm Beach Lakes, Blvd., Suite 930 West Palm Beach, FL 33401 TEL: (561) 847-4408 I FAX: (561) 855.2891 Atta

s to what the evidence will show into two subsections: (a) that J. Epstein did not violate the November 30, 2010 Order; and (b) that Farmer Jaffe, Edwards, and Intervenors have sustained no actual, compensatory losses, encompassing 07/25/18 SJL Work on preparation for two-day hearing In front of Jud

to J. Epstein's Request for Judicial Notice for purposes other than authenticity (e-served 7/26/18) 07/26/18 DMS Preliminarily review and analyze B. Edwards' Supplemental Response to J. Epstein's Motion for Court to Declare Relevance and Non-Privileged Nature of Documents, and Request for Additional Li

. Nurick was there and Scarola. Nurick and Scarola were powwowing after the hearing. It's an important ruling for us to be able to tell the jury in Edwards that we still have a pending case against Rothstein. I suggest we set Rothstein for deposition. His deposition was very ineffectively taken before.

Palm Beach Lakes Blvd. Suite 930 MIS Jeffrey Epstein 6100 Red Hook Quarter, B3 St. Thomas, USV 00802 CLIENT: 0002 - Jeffrey Epstein Re: 0001 Bradley Edwards August 7,2018 Invoice #1034 Date Services Hours Amount 07/02/18 TLC Follow up with D. Indyke re status of drafting; working on hearing folde

to J. Epstein's Request for Judicial Notice for purposes other than authenticity (e-served 7/26/18) 07/26/18 DMS Preliminarily review and analyze B. Edwards' Supplemental Response to J. Epstein's Motion for Court to Declare Relevance and Non-Privileged Nature of Documents, and Request for Additional Li

A JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1201 Plaintiff, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' M

FREY EPSTEIN ("Epstein"), by and through his undersigned counsel, hereby offers the following response in opposition to Defendant/Counter- Plaintiff EDWARDS' ("Edwards") Motion for Leave to Assert a Claim for Punitive Damages ("motion")" and states: SUMMARY OF ARGUMENT Edwards' latest kitchen-sink moti

plaint. Until Epstein files a new complaint, there is simply no predicate for seeking punitive damages based upon Epstein's abuse of process claim. B. Edwards' Proffer Lacks the Requisite "Reasonable Basis" for Punitive Damages - 7 - EFTA00582886 Epstein v. Rothstein, Edwards CASE NO. 50 2009 CA 040800