Epstein Secrets

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

Epstein ("Epstein"), responds in opposition to the Motion for Protective Order [D.E. 1026] filed by Defendant/Counter-Plaintiff, Bradley Edwards ("Edwards"), relating to the deposition of M. 1 [D.E. 1027], and moves to compel her to answer questions relating to the Crimes Victims' Rights Act ("CVRA") a

side the NPA through the CVRA action: 10 And we intend to prove that Jeffrey 11 Epstein's motive in filing these knowingly 12 false claims against Brad Edwards - his 13 motive was to extort Bradley Edwards into 14 abandoning or cheaply compromising the 15 rights of his clients, and abandoning his 16 effo

d the NPA and there was no legitimate purpose for them to make the agreement public. Furthermore, the CVRA court had recently (February 2009) denied Edwards' Motion to Unseal the NPA in that action. (Jane Doe v. U.S., Case No. 08-CV-80736, D.E. 36.) Edwards wants the Court to believe, however, that Epstein's mo

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

cutoff date" and Edwards objected "to any effort to expand existing deadlines." Id. On November 27, 2017, the Court agreed with Edwards and granted Edwards' Motion finding that, "to the extent that wholesale additional discovery will not be permitted but individual discovery requests may be allowed on a matter

CUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and ■., individually, Defendant(s). ORDER SPECIALLY SETTING HEARING THIS CAUSE having come to be considered upon the ORDER SPECIAL

vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and ■., individually, Defendant(

e • Burlington & Rockenbach, 444 W Railroad Avenue, Suite 350 West Palm Beach, FL 33401 Phone: (561)-721-0400 Attorneys for Bradley J. Edwards Bradle J. Edwards Es uire Farmer Jaffe Weissing Edwards Fistos & Lehrman, ■. 425 N Andrews Avenue, Suite 2 3 EFTA00595675 EDWARDS ADV. EPSTEIN Case No.: S02009CA04

V. EPSTEIN Case No.: S02009CA040800XXXXMBAG Order Specially Setting Hearing Response in Opposition to Jeffrey Epstein's Omnibus Motion in Limine; Edwards' Motion in Limine to Strike the June 30, 2017 Affidavit of Jeffrey Epstein and to Exclude Evidence as to which Discovery was withheld under Claims of Privil

VISION AG CASE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR CLARIFICATION REGARDING DISCOVERY Plaintif

adings needed to be addressed and directed Epstein to file an Amended Complaint. 2. On July 13, 2011 at the hearing on Defendant Bradley Edwards' ("Edwards") Motion to Dismiss the Amended Complaint, this Court stated that it "want[ed] to get a complaint out there that withstands the motion to dismiss b

very issues. EFTA00613622 Epstein v. Rothstein and Edwards Case No. 502009CA040800XXXXMB/Division AG 3. At the hearing on September 28, 2011 on Edwards' Motion to Dismiss the Second Amended Complaint, this Court reiterated that it wanted to get the issues in the pleadings resolved before addressing discove

ION OF COURT ORDER AND THE INTERVENORS' JOINDER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") responds in opposition to Counter- Plaintiff Bradley J. Edwards' ("Edwards") April 3, 2018, Motion for Sanctions for Violation of Court Order', and the Intervenors' April 7, 2018, Joinder and states: INTRODUCTION

and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO EDWARDS' MOTION FOR SANCTIONS FOR VIOLATION OF COURT ORDER AND THE INTERVENORS' JOINDER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") responds in

Fourth District Court of Appeal. Obviously, however, Epstein's general references to documents could not possibly have violated the Court's ruling. Edwards' Motion is just another attempt to derail an in camera review of 'A written Order has not been issued on the Court's March 8, 2018, rulings. EFTA00808672

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

aint. Significant to this case and Epstein having probable cause to continue with this suit against Edwards was Judge Crow's finding when he denied Edwards' Motion to Dismiss Epstein's Second Amended Complaint. Edwards' Motion to Dismiss asserted the litigation privilege as an absolute bar to Epstein's cause of

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

t to avoid the Florida Evidence Code by propounding the tardy discovery requests should be rejected. CONCLUSION Epstein respectfully requests that Edwards' Motion be denied. Edwards asked for confirmation of the pretrial deadlines and must be held to that request. There was no court ruling "on motions current

plaintiff/counter-defendant below, challenges the circuit court's Order entered March 8, 2018' by the Honorable Donald Hafele, granting Respondent Bradley J. Edwards' Motion for Separate Trials.'' By separate motion, Petitioner moves to consolidate this petition with his pending Emergency Petition for Writ of Man

admittedly running a $1.2 billion Ponzi scheme by convincing investors he had negotiated multi-million settlements in high-profile cases. Three of Edwards' clients at the time alleged tort claims against Epstein, which Epstein ultimately settled. Based on publicly available information about 3 All bac

nday, March 5, 2018, Epstein filed his to motion to remove the case from trial docket in order to comply with the mandate of Rule 1.440 and opposed Edwards' Motion for Pursuant to the clear language of the rule, if the action involves a main claim or counterclaim which has neither been answered nor defaulted,