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 MOTION FOR PROTECTIVE ORDER AND IN LIMINE OF UNRELATED

ments and amounts and for a finding that such are inadmissible evidence, and states: INTRODUCTION Defendant/Counter-Plaintiff Bradley J. Edwards ("Edwards") represented three plaintiffs who brought tort claims seeking money damages against Epstein. Edwards possesses the confidential settlement agreeme

is error if we were not permitted to talk about what Mr. Epstein's motive was for taking the extraordinary step of filing a baseless claim against Bradley Edwards. THE COURT: Well, until we get into, Palm Beach Reporting Service, Inc. 561-471-2995 EFTA00805183 5 1 2 3 4 5 6 7 8 9 10 11 12 13

by the danger of unfair prejudice, confusion of issues, misleading the jury, or needless presentation of cumulative evidence." § 90.403, Fla. Stat., Dailey v. Multicon Dev., Inc., 417 So. 2d 1106, 1107 (Fla. 4th DCA 1982). 'Unfair prejudice' has been described as 'an undue tendency to suggest decision

e commentary from Edwards, his counsel, or his witnesses, is impermissible. Any Reference to any Cases Against Epstein Which were not Prosecuted by Bradley J. Edwards. While it foreseeable that a limited amount of the information regarding Edwards's prosecution of the three cases against Epstein could potentially

Australian Ave. South, Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. 1 East Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Bradle . Edwards E . armer a e eissing wards Fistos Lehrman 425 N Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 1 Financial Plaza, Suite 2612 Fort Laude

danger of unfair prejudice, confusion of issues, misleading the jury, or needless presentation of cumulative evidence." § 90.403 FLA. STAT. (2013); Dailey v. Multicon Development, Inc., 417 So.2d 1106, 1107 (Fla. 4th DCA 1982). "'Unfair prejudice' has been described as 'an undue tendency to suggest de

evidence at trial, the mere mention of which would be prejudicial. Buy-Low Save Ctrs., Inc. v. Glinert, 547 So. 2d 1283, 1284 (Fla. 4th DCA 1999); Dailey v. Multicon Dev., Inc., 417 So. 2d 1106, 1107 (Fla. 4th DCA 1982). Accordingly, a motion in limine is proper to exclude any irrelevant and immateria

FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, JUDGE: DAVID CROW VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, MOTION IN LIMINE TO PRECLUDE AT TRIAL THE USE OF THE FOLLOWING ITEMS LISTED ON EDWARDS'S REVISED EXHI

y, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, MOTION IN LIMINE TO PRECLUDE AT TRIAL THE USE OF THE FOLLOWING ITEMS LISTED ON EDWARDS'S REVISED EXHIBIT LIST Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel moves for an Order in Limine

evidence at trial, the mere mention of which would be prejudicial. Buy-Low Save Ctrs., Inc. v. Glinert, 547 So. 2d 1283, 1284 (Fla. 4th DCA 1999); Dailey v. Multicon Dev., Inc., 417 So. 2d 1106, 1107 (Fla. 4th EFTA00598330 DCA 1982). Accordingly, a motion in limine is proper to exclude any irrelevan