Epstein Secrets

ESQUIRE Burman, rr4tfnn or al. 1 1 1 1 14 15 1 17 18 19 20 21 22 23 2 2 On behalf of Third Party E.W. WILLIAM J. BERGER, ESQUIRE BRADLEY J. EDWARDS, ESQUIRE Rothstein Rosenfeldt Adler On behalf of Third Party, The Post DEANNA SHULLMAN, ESQUIRE Thomas, LoCiero & EFTA00233769 Proceedings Jun

Ms. Shullman, good morning. Mr. Borger, gOOd morning. And Hr. Berger, your client is E -- HR. BERGER: E.W., yes. THE COURT: Anybody else here? MR. EDWARDS: Brad Edward■ on behalf of E.N. as well, Judge. Thanks. EFTA00233748 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 2

man, good morning. Mr. Borger, gOOd morning. And Hr. Berger, your client is E -- HR. BERGER: E.W., yes. THE COURT: Anybody else here? MR. EDWARDS: Brad Edward■ on behalf of E.N. as well, Judge. Thanks. EFTA00233748 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

fense was confirmed when she was interviewed by 'Attorney Edwards filed his Motion on behalf of "Jane Doe," without

e majority resolved the issue by granting a narrow role to privacy based on considerations re- lating to the legitimate expectations of privacy. In the Florida Supreme Court's well-developed pri- vacy jurisprudence, the fundamental basis of the right of privacy is a legitimate expectation of pri- vacy. Not every fact in ev

ividually, Defendants/Counter-Plaintiff. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY J. EDWARDS' SECOND SUPPLEMENT TO MOTION IN LIMINE ADDRESSING SCOPE OF ADMISSIBLE EVIDENCE Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), opposes Defe

ING SCOPE OF ADMISSIBLE EVIDENCE Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), opposes Defendant/Counter- Plaintiff Bradley J. Edwards' ("Edwards") December 11, 2017, Second Supplement to Motion in Limine Addressing Scope of Admissible Evidence (D.E. 1113) and states: INTRODUCTION Edwards se

e Crow ruling that Epstein's Second Amended Complaint properly stated a cause of action for abuse of process. It would be a tortured application of the Florida Supreme Court's Levin decision to allow Edwards to bar Epstein from presenting his defense and constitutes reversible error. CONCLUSION Epstein respectfully reque

AL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants. TRANSCRIPT OF HEARING PROCEEDINGS DATE TAKEN: Monday, January 27, 2014 TIME: 3:00 p.m. - 4:23 p.m. PLACE: Palm Bea

had no knowledge whatsoever 4 that a separate and independent action had been 5 brought by Mr. Epstein against the Rothstein 6 entities and Mr. Edwards. So to that extent, I 7 just to want let you know, as you probably already 8 did already know, that I handled those cases I 9 believe to their

e Olson case, respectfully, that 11 can gather here. So based on the Third District 12 Court's decisions in Wolfe quoting in large part 13 from the Florida Supreme Court's decision in 14 Echevarria, whereas here all of the allegations 15 made in both the abuse of process claim and the 16 malicious prosecution clai

t Lauderdale, FL 33301 ttorneys or e rey pstein Bradley J. Edwards, Esq. FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHR

rclaim and Supporting Memorandum of Law, based on the law of the case doctrine. RELEVANT PROCEDURAL BACKGROUND In the Fourth Amended Counterclaim, Edwards raised two claims against Epstein: 1) abuse of process and 2) malicious prosecution. As to the malicious prosecution claim, Edwards alleged that th

Olson case, respectfully, that I 11 can gather here. So based on the Third District 12 Court's decisions in Wolfe quoting in large part 13 from the Florida Supreme Court's decision in 14 Echevarria, whereas here all of the allegations 15 made in both the abuse of process claim and the 16 malicious prosecution clai

Critton, et al. 515 N. Flagler Drive, Ste. 400 West Palm Beach, FL 33401-4349 On behalf of Third Partylill. WILLIAM J. BERGER, 1 1 1 ESQUIRE BRADLEY J. EDWARDS, ESQUIRE Rothstein Rosenfeldt Adler 1 401 E. Las Olas Blvd., Suite 1650 Fort Lauderdale, FL 33394 14 15 1 On behalf of Third Party, The Post

Me. Shullman, good morning. Hr. Berger, good morning. And Mr. Borger, your client is E -- NR. BERGER: ., yes. THE COURT: Anybody else here? Nit. EDWARDS: Bred Edwards on behalf of as well, Judge. Thanks, EFTA00183597 1 2 3 4 5 6 7 8 9 10 11 12. 13 14 15 16 17 18 19 20 21 22

e majority resolved the issue by granting a narrow role to privacy based on considerations re- lating to the legitimate expectations of privacy. In the Florida Supreme Court's well-developed pri- vacy jurisprudence, the fundamental basis of the right of privacy is a legitimate expectation of pri- vacy. Not every fact in ev

ed 12/11/2015 05:54:44 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA Case No.: CACE 15-000072 EDWARDS, et at, Plaintiffs / Counterclaim Defendants, vs. DERSHOWITZ, Defendant / Counterclaim Plaintiff. DEFENDANT ALAN M. DERSHOWITZ'S OPPOSITION TO

access to all records of the judicial branch of government, except as provided below." Fla. R. Jud. Admin. 2.420(a). This rule is a codification of the Florida Supreme Court's admonition that "a strong presumption of openness exists for all court proceedings. A trial is a public event, and the filed records of court proce

ed 12/11/2015 05:54:44 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA Case No.: CACE 15-000072 EDWARDS, et at, Plaintiffs / Counterclaim Defendants, vs. DERSHOWITZ, Defendant / Counterclaim Plaintiff. DEFENDANT ALAN M. DERSHOWITZ'S OPPOSITION TO

access to all records of the judicial branch of government, except as provided below." Fla. R. Jud. Admin. 2.420(a). This rule is a codification of the Florida Supreme Court's admonition that "a strong presumption of openness exists for all court proceedings. A trial is a public event, and the filed records of court proce