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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 RESPONSE IN OPPOSITION TO DEFENDANT/COUNTER-PLAINT
tion for Leave to Propound Limited Requests for Admission dated December 1, 2017 [D.E. 1098] filed by Defendant/Counter-Plaintiff, Bradley Edwards ("Edwards"). BACKGROUND Discovery is over. By Court Order dated July 20, 2017, this Court special set the trial of this matter for December 5, 2017. [D.E. 9
ington & Rockenbach, Courthouse Commons, Suite 350 444 West Railroad Avenue West Palm Beach, FL 33401 Co-Counsel for Defendant/Counter-Plaintiff Bradley 2 Edwards Bradley J. Edwards Edwards Pottinger LLC 425 N. Andrews Avenue, Suite 2 Ft. Lauderdale, FL 33301-3268 Co-Counsel for Defendant/Counter-Plaintiff
r Admission dated December 1, 2017 [D.E. 1098] filed by Defendant/Counter-Plaintiff, Bradley Edwards ("Edwards"). BACKGROUND Discovery is over. By Court Order dated July 20, 2017, this Court special set the trial of this matter for December 5, 2017. [D.E. 938.] In doing so, the Court ordered that the deadl
During this time period, Villafana and the case agents interacted with several victims and their attorneys, and Villafana contacted victims’ attorney Bradley Edwards to encourage him to attend the state court plea hearing, but she did not inform victims or Edwards of the NPA or the resolution of the federal invest
and Villafana contacted victims’ attorney Bradley Edwards to encourage him to attend the state court plea hearing, but she did not inform victims or Edwards of the NPA or the resolution of the federal investigation. As described in Part One of this chapter, after the NPA was signed, the FBI case agent and
ated in her 2017 declaration that she “never told Attorney Edwards that the state charges involved ‘other victims,’
apias is issued pursuanfto an,informatiori<liled by the.State Attorney,sFifteenth'Judicial.Circuit, Palm Beach County,* Flonda APPEARANCE BOND set by Court Order per bondjschedule’ - ^WITNESS my hand and the seal oMhls Court on this v ■ of 199_ I? : ARREST WARRANT BAIL ENDORSEMENT ' /. The defendant is to be a
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. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO DEFENDANT/COUNTER-PLAINT
tion for Leave to Propound Limited Requests for Admission dated December 1, 2017 [D.E. 1098] filed by Defendant/Counter-Plaintiff, Bradley Edwards ("Edwards"). BACKGROUND Discovery is over. By Court Order dated July 20, 2017, this Court special set the trial of this matter for December 5, 2017. [D.E. 9
r Admission dated December 1, 2017 [D.E. 1098] filed by Defendant/Counter-Plaintiff, Bradley Edwards ("Edwards"). BACKGROUND Discovery is over. By Court Order dated July 20, 2017, this Court special set the trial of this matter for December 5, 2017. [D.E. 938.] In doing so, the Court ordered that the deadl
on, Esq. were present on behalf of Jeffrey Epstein. Ms. (; :si Shullman, Esc was present on behalf of the Palm Beach Post, Mr. Berger, Esq. and Mr. Edwards, Esq. were present on behalf of Mr. Kuvin, Esq. was present on behalf of_ Assistant State Attorney Barbara Bums was present on behalf of the State
Westnifideach, FL 33401 William 3. Berger, Esq. Bradley J. Edwards, Esq. Rothstein Rosenfeldt Adler 401 East las Olas Bo
as is issued pursuant to an information filed by the Stale Attorney, Fifteenth Jud cial Circuit, Palm Beath Colnly. Florida. APPEARANCE BOND set by Court Order per bond schedule. WITNESS my hand and the seal of this Court on this day of 199 (SEAL) DOROTHY H. WILKEN, CLERK OF COURT BY: Deputy Cler
da 500 S. Australian Ave, Ste 400 West Palm Beach, FL 33401 (561) 820-8711 Facsimile: (561) 820-8777 July 19, 2013 DELIVERY BY FEDERAL EXPRESS Brad Edwards, Esq., Fanner Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale, FL 33301-3268 Re: Jane Doe #1 and Jane Doe #21. Uni
July 19, 2013 DELIVERY BY FEDERAL EXPRESS Brad Edwards, Esq., Fanner Jaffe Weissing Edwards Fistos Lehr
fs counsel was served with the Motion. Asa result, notice of the relief sought by Jane Doe's Mother is fatally defective. 3. Jane Doe's Father, by Court Order, was awarded full custody of the Minor Plaintiff, and is thus her sole natural guardian. Jane Doe's Mother is not Jane Doe's natural guardian under
ensive disposition of the litigation, or serve as a means of controlling the district court's docket. See American Manufacturers Mutual Ins. Co. v. Edward,. Stone Jr. & Assoc., 743 F.2d 1519 (11th Cir. 1984). For example, a stay may be considered in a case where there is another pending lawsuit or admi
s counsel was served with the Motion. As a result, notice of the relief sought by Jane Doe's Mother is fatally defective. 3. Jane Doe's Father, by Court Order, was awarded full custody of the Minor Plaintiff, and is thus her sole natural guardian. Jane Doe's Mother is not Jane Doe's natural guardian under
Entities connected to both Bradley Edwards and Court Order

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
Ghislaine Maxwell
PERSON
United States
LOCATIONRobert D. Critton
PERSONLeon Black
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION
Alexander Acosta
PERSON
Adam D. Horowitz
PERSON
Lesley Groff
PERSONSpencer Kuvin
PERSON