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. COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO UNSEAL DISC AND PROPOSED TRIAL EXHIBITS FOR USE AT BAN

the Bankruptcy Court's show cause proceedings and depositions, and in support thereof, states: INTRODUCTION Counter-Plaintiff Bradley J. Edwards ("Edwards"), along with Fanner Jaffe and Intervenors L.M., E.W. and Jane Doe (collectively, the "Bankruptcy Movants") have moved the Bankruptcy Court for an

endant Jeffrey Epstein ("Epstein") moves to unseal the disc labeled "Epstein Bate Stamp" and the 47 documents identified on Epstein's March 5, 2018, Clerk's Trial Exhibit List for the limited purpose of the Bankruptcy Court's show cause proceedings and depositions, and in support thereof, states: INTRO

ION OF COURT ORDER AND THE INTERVENORS' JOINDER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") responds in opposition to Counter- Plaintiff Bradley J. Edwards' ("Edwards") April 3, 2018, Motion for Sanctions for Violation of Court Order', and the Intervenors' April 7, 2018, Joinder and states: INTRODUCTION

and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO EDWARDS' MOTION FOR SANCTIONS FOR VIOLATION OF COURT ORDER AND THE INTERVENORS' JOINDER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") responds in

nd March 2, 2018. Epstein then individually identified each of those exhibits according to the Clerk's pre-marking guidelines on his March 5, 2018, Clerk's Trial Exhibit List. 6 EFTA00808677 THE COURT: Well, the only thing that obviously has to be taken into consideration is the appellate rights of

ION OF COURT ORDER AND THE INTERVENORS' JOINDER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") responds in opposition to Counter- Plaintiff Bradley J. Edwards' ("Edwards") April 3, 2018, Motion for Sanctions for Violation of Court Order', and the Intervenors' April 7, 2018, Joinder and states: INTRODUCTION

and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO EDWARDS' MOTION FOR SANCTIONS FOR VIOLATION OF COURT ORDER AND THE INTERVENORS' JOINDER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") responds in

nd March 2, 2018. Epstein then individually identified each of those exhibits according to the Clerk's pre-marking guidelines on his March 5, 2018, Clerk's Trial Exhibit List. 6 EFTA00808663 (3/8/18 Aft. Tr. 54:9-20) (emphasis added). This Court's rulings were focused on not allowing Epstein to use

es Blvd. Suite 930 W • • • • 7 01 Jeffrey Epstein 6100 Red Hook Quarter, B3 St. Thomas, USV 00802 CLIENT: 0002 - Jeffrey Epstein Re: 0001 Bradley Edwards Date Services 05/01/18 TLC Work on Motion to Compel B. Edwards to Identify Witnesses who will be called at trial to incorporate D. Indyke's sug

CLIENT: 0002 - Jeffrey Epstein Re: 0001 Bradley Edwards Date Services 05/01/18 TLC Work on Motion to

nse to Motion for Sanctions 05/02/18 PVD [No Charge] Proof Motion to Compel B. Edwards to Identify Witnesses prior to filing; continue review of Clerk's Trial Exhibits for compliance; work on Amended Exhibit List cross referencing exhibits previously marked 05/02/18 TLC Work on scheduling J. Epste

N BACH, PA May 22, 2018 Via Emai► -frevacationegmaitcom Jeffrey Epstein 6100 Red Hook Quarter, B3 St Thomas, USVI 00802 Re: Jeffrey Epstein v. Bradley J. Edwards File No.: 2.0001 Dear Jeffrey: 1555 Palm Beach Lakes, Blvd., Suite 930 West Palm Beach, FL 33401 TEL: (561) 847-4408 I FAX: (561) 855-2891 Atta

entioned in the Motion, and outline Response in Opposition 04/03/18 PVD [No Charge] Work on hearing binder re Farmer l e 's Motion to Show Cause, Edwards' Joinder, , E.W. and Jane Doe's Joinder and Motion to ervene 04/03/18 PVD [No Charge] Work on exhibit of comparison of privilege log for in came

for default, etc.; work on documents re same; multiple communications with J. Scarola re production issues; follow up with client re same; work on Clerk's Trial Exhibit List 03/19/18 KBR Finalize Reply in support of Petition for Writ of Mandamus 03/23/18 TMB [No Charge] Work on exhibits and finaliz

BACH9 PA April 10, 2018 Via Email jeevacationegmaitcom Jeffrey Epstein 6100 Red Hook Quarter, 83 St. Thomas, USVI 00802 Re: Jeffrey Epstein v. Bradley J. Edwards File No.: 2.0001 Dear Jeffrey: 1555 Palm Beach Lakes Blvd., Suite 301 West Palm Beach, FL 33401 TEL (561) 727-3600 I FAX (561) 727-3601 Attache

Addressing the Admissibility of Edwards' Exhibit 132; (12) Epstein's Motion in Limine re Sex Offender Registry; (13) Epstein's Motion in Limine on Edwards' Newly Disclosed Exhibits; (14) Epstein's Request for Judicial Notice; and (15) Objections to Deposition Designations; assemble hearing notebooks

ssing Scope of Admissible Evidence; work on hearing needs; follow up on V. Roberts' audio tape; prepare Notice of Cancellation of Hearing; work on Clerk's Trial Exhibit List to identify each item individually 03/02/18 SJL Continue working on Notice of Filing Appendix in 12.80 9,600.00 Support of R