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

, 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, confusion of the i

ward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman 42

tein"), by and through his undersigned counsel, hereby files his Memorandum of Law in Opposition to Defendant/Counter-Plaintiff Bradley Edwards's ("Edwards") legally and factually deficient Motion for Protective Order. In support thereof, Epstein states: INTRODUCTION On or about January 9, 2013, Edwar

ird, Edwards asserts that a protective order is warranted because the production requested "is unnecessarily intrusive into the financial privacy of BRADLEY EDWARDS'." See Exhibit B. However, because Edwards has put his financial status at issue by his assertion of damages, his Motion must be denied. When a party

he onus of supplying the information or documents is inordinate." Topp Telecom, Inc. v. Atkins, 763 So. 2d 1197, 1199 (Fla. 4th DCA 2000). See also Allstate Ins. Co. v. Boecher, 733 So. 2d 993, 994 (Fla.1999) (noting the lack of "affidavits, depositions or other sworn testimony in the record to support Allstate's

IN THE DISTRICT COURT OF APPEAL OF FLORIDA FOURTH DISTRICT CASE NO. 4D14-2282 BRADLEY J. EDWARDS, Appellant, v. JEFFREY EPSTEIN, Appellee. MOTION FOR LEAVE TO FILE SUPPLEMENTAL ARGUMENT The appellee, Jeffrey Epstein, respectfully moves for

28 So. 3d 67 (Fla. 3d DCA 2013) (holding that the litigation privilege applies to causes of action for malicious prosecution and abuse of process). Edwards appealed and is challenging the final judgment solely as to the malicious prosecution claim. 2. After the parties' briefs were filed, this Court is

rds, Rothstein was deposed. At the morning session of deposition on December 12, 2011, Rothstein was asked the following about Bradley Edwards: Q: Brad Edwards, would he have reported illegal activity? A: I don't know. Q: Would he have reported trust account defalcations? 22 R. 816, citing letter dated Ju

d." Dade Cnty. Sch. Bd. v. Radio Station WQBA, 731 So. 2d 638, 644 (Fla.1999). "This rule applies in cases of summary judgments as well." Landis v. Allstate Ins. Co., 546 So. 2d 1051, 1053 (Fla. 1989); see also Rivernider, supra (holding that although trial judge erred in granting summary judgment based upon the

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408007OOOCMBAG

-Plaintiff Bradley Edwards's ("Edwards") Complaint, Abuse of Process and Malicious Prosecution, and entered Final Judgment in accordance therewith. Edwards timely appealed this Court's ruling as to his Malicious Prosecution count to the Fourth District Court of Appeal. The issue was fully briefed, and o

A 250 Australian Ave. South, Suite 1400 West Palm Beach, FL 33401 Marc Ntwil Es Es . 1 East Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Bradle J. Edwards Es . anner a e eissing wards Fistos Lehrman 425 N Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad Es . Fre Ha a , PA 1 Financi

r the circuit courts not to interfere with the jurisdiction of the courts of appeal when issues are then pending before them." Id. at 983. See also Allstate Ins. Co. v. Titusville Total Health Care, 848 So. 2d 1166, 1167 (Fla. 5th DCA 2003) ("Courts have often held that it is appropriate for one court to stay an

ward Blvd., Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. [email protected] Fanner Jaffe Weissing Ed

-Plaintiff Bradley Edwards's ("Edwards") Complaint, Abuse of Process and Malicious Prosecution, and entered Final Judgment in accordance therewith. Edwards timely appealed this Court's ruling as to his Malicious Prosecution count to the Fourth District Court of Appeal. The issue was fully briefed, and o

r the circuit courts not to interfere with the jurisdiction of the courts of appeal when issues are then pending before them." Id. at 983. See also Allstate Ins. Co. v. Titusville Total Health Care, 848 So. 2d 1166, 1167 (Fla. 5th DCA 2003) ("Courts have often held that it is appropriate for one court to stay an

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

, 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 prejudice, confusion of the

, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN. Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF'S MOTION TO OUASH SUBPOENA AND FOR PROTECTIVE ORDER TO PREVENT DEPOSITION OF ALFRED SECKEL Plaintiff Jeffrey

commanding non-party Alfred Seckel to appear for deposition in Los Angeles, California on May 23, 2011 which subpoena Defendant Bradley J. Edwards ("Edwards") has noticed over the Plaintiffs objection. The grounds for this Motion are: I. On or about April 7, 2011, counsel to Edwards noticed the deposit

are reasonably calculated to lead to the discovery of admissible evidence in the case in which the discovery is sought. Fla. R. Civ. P. 1.280(b)(1); Allstate Ins. Co. v. Langston, 655 So. 2d 91, 94 (Fla. 1995). 10. "Pretrial discovery was implemented to simplify the issues in a case, to eliminate the element of