Epstein Secrets

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

ivision AG (TIG) v. Johnson, 799 So.2d 339 (Fla. 4'h DCA 2001). Consequently, Epstein would like to set a motion directed toward the sufficiency of the Privilege Log. 6. Epstein wishes to proceed with discovery of Edwards' alleged damages, but the Motion to Dismiss the Amended Counterclaim is pending, and Epste

SERVICE LIST Jane Does 1 and 2'. United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman Paul G. Cassell S.J. I uinne olle e of Law at the Attorneys for Jane Doe # 1 and Jane Doe #

istrict Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehr

ned Assistant United States Attorney, hereby gives notice of its filing of its Privilege Log, which is attached hereto. The documents referenced in the Privilege Log are being delivered today to the Chambers of U.S. District Judge Kenneth A. Marra for ex pane in camera review, pursuant to the Court's Omnibus Ord

istrict Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehr

ERVICE LIST Jane Does 1 and 2 v. United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale, FL 33301-3268 [email protected] 954-524-2820

ned Assistant United States Attorney, hereby gives notice of its filing of its Privilege Log, which is attached hereto. The documents referenced in the Privilege Log are being delivered today to the Chambers of U.S. District Judge Kenneth A. Marra for ex pane in camera review, pursuant to the Court's Omnibus Ord

SERVICE LIST Jane Does 1 and 2'. United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale FL 33301-3268 Paul G. Cassell S.J. Quinney College o

istrict Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehr

ned Assistant United States Attorney, hereby gives notice of its filing of its Privilege Log, which is attached hereto. The documents referenced in the Privilege Log are being delivered today to the Chambers of U.S. District Judge Kenneth A. Mama for ex pane in camera review, pursuant to the Court's Omnibus Orde

SERVICE LIST Jane Does 1 and 2 United States, Case No. 08-80736-CIV-MARRA/MATTHEWMAN United States District Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Ave Ste 2 Fort Lauderdale FL 33301-3268 Paul G. Cassell S.J. Quinney College o

istrict Court, Southern District of Florida Brad Edwards, Esq., Farmer Jaffe Weissing Edwards Fistos Lehr

ned Assistant United States Attorney, hereby gives notice of its filing of its Privilege Log, which is attached hereto. The documents referenced in the Privilege Log are being delivered today to the Chambers of U.S. District Judge Kenneth A. Marra for ex pane in camera review, pursuant to the Court's Omnibus Ord

already entered a binding non-prosecution agreement with Jeffrey Epstein. The government is without 6 EFTA00191204 knowledge of precisely when "Bradley J. Edwards was working on a letter to the U.S. Attorney's Office concerning the need to federally prosecute Epstein for sex offenses committed against Jane Do

rally prosecute Epstein for sex offenses committed against Jane Doe #1 and Jane Doe #2," and, accordingly, the government denies the assertion that Edwards worked on that letter on July 3, 2008. Except as otherwise admitted above, the government denies Request No. 12. 13. (a) The government admits that

s Nos. P-008891 thru P-009103; Documents bearing Bates Nos. P-009114 thru P-009115; Documents bearing Bates Nos. P-009712 thru P-009819; A copy of the Privilege Log that was filed with the Court; and A copy of the Responses to your Requests for Admissions that were filed with the Court. Please let me know if y

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

s Nos. P-008891 thru P-009103; Documents bearing Bates Nos. P-009114 that P-009115; Documents bearing Bates Nos. P-009712 thru P-009819; A copy of the Privilege Log that was filed with the Court; and A copy of the Responses to your Requests for Admissions that were filed with the Court. Please let me know if y

er counsel on the phone for permitting us to appear 19 by phone. 20 THE COURT: All right. Anyone else have anything they 21 want to add? 22 MR. EDWARDS: Brad Edwards on behalf of Jane Doe. 23 I only had one issue here, and when I read your motion 24 that you wanted to hear on the narrow issue of j

l on the phone for permitting us to appear 19 by phone. 20 THE COURT: All right. Anyone else have anything they 21 want to add? 22 MR. EDWARDS: Brad Edwards on behalf of Jane Doe. 23 I only had one issue here, and when I read your motion 24 that you wanted to hear on the narrow issue of just defense in

ned Assistant United States Attorney, hereby gives notice of its filing of its Privilege Log, which is attached hereto. The documents referenced in the Privilege Log are being delivered today to the Chambers of U.S. District Judge Kenneth A. Marra for ex parse in camera review, pursuant to the Court's Omnibus Or

19, 22-23; Exhibit 99; Exhibit 101. 124 Exhibit 26; Exhibit 27; Exhibit 62; Exhibit 63 at 4.6, 18-19, 22-23; Exhibit 99; Exhibit 101; Declaration of Brad Edwards (Exhibit 102). 35 EFTA00185492 Case 9:08-cv-80736-KAM Document 361 Entered on FLSD Docket 02/10/2016 Page 36 of 57 109. Had they known that the

isonment. P-014977 thru P-014978 6/19/2008 email forwardin: 6/19/2008 email from to E. and (NB: Asserting privilege only for email. Attorney Edwards presumably has cop of his email to Attorney-Client Privilege Investigative Privilege P-014979 thru P-014980 6/23/2008 emails between . and (

ned Assistant United States Attorney, hereby gives notice of its filing of its Privilege Log, which is attached hereto. The documents referenced in the Privilege Log are being delivered today to the Chambers of U.S. District Judge Kenneth A. Marra for ex parte in camera review, pursuant to the Court's Omnibus Or

ISION 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 JEFFREY EPSTEIN'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS BY DEFENDANT BRADLEY EDWARDS

gh his undersigned counsel, hereby respectfully seeks the entry of an Order compelling Defendant Bradley Edwards to produce the documents listed in Edwards' privilege log, or, in the alternative, the entry of an Order compelling Edwards to serve a privilege log that fully complies with Fla. R. Civ. P. 2

rior to that time, although Epstein does not hereby waive the right to an in camera review with respect to any of the other materials referenced in the Privilege Log. Finally, the actual prejudice to and impact on Epstein by Edwards' willful and continued non-compliance is palpable. Epstein has been prejudiced