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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
improperly to the jury's emotions.'" Wright v. State, 19 So. 3d 277 (Ha. 2009); Byrd v. BT Foods, Inc., 26 So. 3d 600 (Fla. 4th DCA 2009). See also Canales v. Compania de Vapores Realma, S.A., 564 So. 2d 1212 (Fla. 3d DCA 1990). This Court has made it clear that Edwards may try to prove the elements of
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
improperly to the jury's emotions."' Wright v. State, 19 So. 3d 277 (Fla. 2009); Byrd v. BT Foods, Inc., 26 So. 2d 600 (Fla. 4th DCA 2009). See also Canales v. Compania De Vapores Realma, S.A., 564 So. 2d 1212 (Fla. 3d DCA 1990) (Any probative value of testimony about marriage proposal plaintiff purport
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
, P.A. • 315 SE 7'h Street, Fort Lauderdale, FL 33301 EFTA00585432 (Fla. 2009); Byrd v. BT Foods, Inc., 26 So. 2d 600 (Fla. 4th DCA 2009). See also Canales v. Compania De Vapores ReaIma, S.A., 564 So. 2d 1212 (Fla. 3d DCA 1990) (Any probative value of testimony about marriage proposal plaintiff purport
Entities connected to both Bradley Edwards and Canales

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSON
Alan Dershowitz
PERSONMaria Farmer
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
Ghislaine Maxwell
PERSON
Prince Andrew
PERSONthe Southern District
LOCATION
Donald Trump
PERSONFBI
ORGANIZATION
Alfredo Rodriguez
PERSON
Prince Charles
PERSON
Jean-Luc Brunel
PERSONTonja Haddad Coleman
PERSON
Barry Diller
PERSON
Woody Allen
PERSONLarry Visoski
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