Epstein Secrets

. (D.E. 4) Finally, the Court should enter an Order striking all portions of Plaintiff's response, including the affidavit of Plaintiff's counsel, Brad Edwards, which allege, argue and purport to show an "obstruction of justice" in prior litigation. Such matters are patently irrelevant to the threshold is

s, Plaintiff's counsel, submitted in the instant case. (See D.E. 15, && 14-22 and D.E. 15-1). As set forth below, these allegations, as well as Mr. Edwards' affidavit in support of same, a purported "message" to Mr. Epstein, and a Motion for an Order to Show Cause in another case (D.E. 15-1, D.E. 15-3

Case No. 9:10-cv-81111-WPD SERVICE LIST M.J. v. Epstein Case No. 9:10-cv-81111-WPD United States District Court, Southern District of Florida Bradley J. Edwards Farmer, Jaffe, Weissing, Edwards Fistos & Lehrman, PL Telephone: Facsimile: Attorneys for Plaintiff M.J. Served via CMIECF -14- EFTA00725489

"caretaker." 6. Plaintiff asserts that "Epstein concedes the materials were left at his "vacation home." (Id.) This assertion is misleading. Mr. Bamett's affidavit states only that the suit papers were discovered in the mailbox at 9 East 71g Street, New York, New York. (D.E. 7) 7. Paragraphs 14-22

at Epstein was "not home' before he accepted service for Epstein. See Marsigliano Dec. at Ii 5-7. 6. On October 13, 2010, Mr. Knight approached Mr. Edwards after a hearing to discuss this case on behalf of his client and Mr. Edwards informed Mr. Knight that someone at Epstein's residence in New York ha

Document 15 Entered on FLSD Docket 11/11/2010 Page 15 of 16 CASE NO: 0S-CV-80119-MARRAMOHNSON DATED: November 11, 2010 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS. FISTOS & LEHRMAN P.L. Telephon Facsimile Florida inali m E-mail: CERTIFICATE OF SERVICE

elivered to anyone at Mr. E[psJtein's house." Affidavit of Richard Barnett at ¶ 2-3 (emphasis rearranged) (DE_7-1). The affidavit also stated that Bamett had been duly sworn. Barnett signed the document before a New York Notary Public, although it should be noted that the Notary does not properly ind

ET as Trustee of the IRA SOCHET REVOCABLE INTER VIVOS TRUST, INVESTORS RISK ADVANTAGE, LP, SUSSCO, INC., EDWARD PALEY, FLORENCE PALEY, THE EDWARD AND FLORENCE PALEY FOUNDATION, STEVEN PALEY, LAURA PALEY, JANE ZARETSKY, STEVEN ZARETSKY as Trustee of the JANE ZARETSKY DYNASTY TRUST, LAWRENCE

Scott W. Rothstein, et at Complex Litigation Division - Case No.: 09-062943 (19) Third Amended Complaint 283. BFMC's explicit understanding from Bamett, Boden and Rothstein was that the putative defendant's settlement proceeds were pre-funded and being held in RRA's escrow trust account and could o

d Seigel into Rothstein's private office where the five of them participated in the meeting. 277. After brief introductions, Rothstein, Boden, and Bamett described to Florescue and Seigel an opportunity involving the lump-sum purchase of various pre-funded confidential settlements with structured pay