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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
rs & Co. Inc., 48 So. 3d 976 (Fla. 3d DCA 2010) (probative value outweighed by prejudicial effect when evidence improperly becomes focus of trial); Maldonado v. Allstate Ins. Co., 789 So. 2d 464 (Ha. 2d DCA 2001) (probative value of bicyclist's status as an illegal alien was outweighed by unfair prejudice
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
m & Co., Inc., 48 So. 3d 976 (Fla. 3d DCA 2010) (probative value outweighed by prejudicial effect when evidence improperly becomes focus of trial); Maldonado v. Allstate Ins. Co., 789 So. 2d 464 (Fla. 2d DCA 2001) (probative value of bicyclist's status as an illegal alien was outweighed by unfair prejudi
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
rs & Co., Inc., 48 So. 3d 976 (Fla. 3d DCA 2010) (probative value outweighed by prejudicial effect when evidence improperly becomes focus of trial); Maldonado v. Allstate Ins. 19 Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauderdale, FL 33301 EFTA00585438 Co., 789 So. 2d 464 (Fla. 2d DCA 2001) (probat
Entities connected to both Bradley Edwards and Maldonado

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
PERSONLeon Black
PERSON
Donald Trump
PERSON
Department of Justice
ORGANIZATION
Virginia Giuffre
PERSONDarren Indyke
PERSON
Marc Rich
PERSONFBI
ORGANIZATION
Alfredo Rodriguez
PERSON
Jay Lefkowitz
PERSON
New York
LOCATION