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

aw is settled that the privilege not to reveal the name of a confidential informant is "uniquely available to the government." See, e.g., Holman v. Cayce, 873 F.2d 944, 946 (6ih Cir. 1989) (and cases cited). Other than the cases which speak to the First Amendment privilege of reporters to protect thei

sed in the Crime Victims' Rights Act. DATED this 7th day of July, 2008. Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS & ASSOCIATES, LLC Brad Edwards, Esquire Attorney for Petitioner Florida Bar #542075 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: 954-414-8033 Facsimil

Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS & ASSOCIATES, LLC Brad Edwards, Esquire Attorn

lab • and O.s Dos for Maeda° PEE OEF PTF DEF Courts( This Stale 3 I 3 I Incorporated or Princspal Place 1 4 1 01 of B mei. I. Elm S me Cayce of Another State 3 : 111101199•144 Pratipal Place 1 S 3 S of Busmen la Another Stale Comm or Stherci of. Pomp Coma) 1 Raman Nation € C

Epstein has said. He also owns Little St. James. a 70-acre island in the U.S. Virgin Islands. where the main house is currently being renovated by Edward Tut- tle, a designer of the Amanresorts. There is also a S6.8 million house in Palm Beach, Florida, and a fleet of aircraft: a Gulftutain IV, a he

relationship with Bear Steams. Q: Pardon? A: Other than Bear Steams. no. Q: Have you been a participant in any type of business venture with Mr. Cayce? A: No. co" Do you have any expectation of participat- ing nippy business venture with Mr. Cayne? A: Nd. Q Have you had any business participatio