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eries13 that specifically targeted news articles from the case that addressed the defaming statements (e.g., Jeffrey Epstein v. Scott Rothstein and Bradley 2 Edwards lawsuit) to retrieve a set of articles that directly related to the defaming statements". I employed a modified snowball technique1s, starting with
N 1. I have been retained by the law firm of Searcy Denney Scarola Barnhart & Shipley, PA. to provide expert analysis and opinion on behalf of Mr. Bradley J. Edwards in the case originally styled Jeffrey Epstein, Plaintiff, vs. Scott Rothstein, individually, Mr. Bradley J. Edwards, individually, and'. M., indivi
ion, I have been asked to respond to the following question: 9. What is the level of dissemination of defaming statements associating Mr. Bradley J Edwards with the illegal activities of Mr. Scott Rothstein as a result of Mr. Jef•ey Epstein's lawsuit against Mr. Edwards? 3 EFTA00601579 10. For brev
f such material results in any significant change or addition to my opinion. 22 EFTA00601598 Respectfully submitted, DATED: 20 October 2017 Dr. Bernard J. Jansen Adjunct Professor College of Information Sciences and Technology The Pennsylvania State University Universit Park, PA, 16802 Phone: Email: jjan
nt, Jeffrey Epstein ("Epstein"), moves to strike the expert witness and to exclude the admission of any testimony from Defendant/Counter-Plaintiff, Bradley J. Edwards' ("Edwards") expert Dr. Bernard Jansen because his testimony does not assist the trier of fact, and states: INTRODUCTION Edwards is Attempting to R
Epstein"), moves to strike the expert witness and to exclude the admission of any testimony from Defendant/Counter-Plaintiff, Bradley J. Edwards' ("Edwards") expert Dr. Bernard Jansen because his testimony does not assist the trier of fact, and states: INTRODUCTION Edwards is Attempting to Recover Dam
his Counterclaim, Edwards disclosed Dr. Jansen for the first time on his Sixth Amended Witness List with no explanation, as follows: EXPERT: 159. Bernard J. Jansen, Ph.D. (D.E. 1010.) The Court's July 20, 2017, Order Specially Setting Jury Trial required the following information at the time of listing the exp
IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, -VS- SCOTT individually, EDWARDS, L.M., E.W., Intervenors. ROTHSTEIN, BRADLEY J. individually, and and JANE DOE, Respondents CASE NO. 4D18-0762 APPENDIX TO RESPONSE TO PETI
derdale, FL 33301 Attorneys for Scott Rothstein Bradley J. Edwards, Esq. EDWARDS POTT1NGER LLC 425 N. Andrews Avenue, St
es or articles with a combined 9,669,542 potential daily visitors since the lawsuit was filed to the date that I filed this report, inclusive. Dr. Bernard J. Jansen, October 20, 2017, Report, 9115. Because of this late disclosure and change in position regarding the relevance of printed or published media conne
Entities connected to both Bradley Edwards and Bernard J. Jansen

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
United States
LOCATION
Weissing
PERSON
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATIONPalm Beach Lakes Boulevard
LOCATIONMarc S. Nurik
PERSON
South Florida
LOCATION
Searcy
PERSONNichole J. Segal
PERSONDenny
PERSONLINK & ROCKENBACH
ORGANIZATIONJansen
ORGANIZATION