Epstein Secrets

6th day of August, 2013. /s/ Bradley J. Edw rds BRADLEY J. EDWARDS, ESQ. Attachments: 1. October 3, 2011, request for pr

nt to 28 U.S.C. § 1746, that the foregoing is true and correct to the best of my knowledge and belief. Executed this 16th day of August, 2013. /s/ Bradley J. Edw rds BRADLEY J. EDWARDS, ESQ. Attachments: 1. October 3, 2011, request for production; 2. June 24, 2013, supplemental request for production; and 3.

fication obligations, the USAO altered the language that was ultimately contained in the July 9, 2008 notification letter to Jane Doe #1 in care of Bradley Edwards. Except as otherwise admitted above, the government denies Request No. 2(d). (e) At least in part as a result of the negotiations, Jane Doe #1 and

ys to reduce any such burden. DATED: October 3. 2011 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Flori

). Communications Facilitating Crime-Fraud-Misconduct Not Covered - Any privilege would be subject to a crime-fraud-misconduct exception. See In re Sealed Case, 754 F.2d 395, 399 (D.C. Cir. 1985) (applying exception to attorney-client privilege); Cox v. Administrator U.S. Steel & Carnie, 17 F.3d 1386, 1422

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 NOTICE OF SUPPLEMENTAL AUTHORITY IN SUPPORT OF HIS SUPPLEMEN

ubmits the attached Opinion in the case of Jane Doe No. 1 v. United States, 749 F.3d 999 (11th Cir. 2014), attached to this Notice as Exhibit A, and Edwards' clients' Appellee Brief filed in that case, attached to this Notice as Exhibit B. In Jane Doe No. 1, the United States Court of Appeals for the El

to class counsel during settlement negotiated waived work product when tape sought by government as part of criminal 3 EFTA00806655 case); In re Sealed Case, 676 F.2d 793, 824-25 (D.C. Cir. 1982) (production of documents during settlement discussions with the SEC waived work product protection as to gra

ntained, inter alia, in the attached affidavit of Bradley J. Edwards, Esq. The victims have also concurrently filed itemize

ocket 08/16/2013 Page 9 of 10 DATED: August 16, 2013 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-2820 Facsimile (954) 524-2822 Flori

). Communications Facilitating Crime-Fraud-Misconduct Not Covered — Any privilege would be subject to a crime-fraud-misconduct exception. See In re Sealed Case, 754 F.2d 395, 399 (D.C. Cir. 1985) (applying exception to attorney-client privilege); Cox v. Administrator U.S. Steel & Carnie, 17 F.3d 1386, 1422

hen have 10 days to file a reply. A proposed order to that effect is attached to this pleading. DATED: August 1, 2013 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards and Paul G. Cassell Pro Hac Vice I0 EFTA00208765 Case 9:08-cv-80736-KAM Document 218 Entered on FLSD Docket 08/01/2013 Pag

1, 2013 Respectfully Submitted, /s/ Bradley J. Edwards Bradley J. Edwards and Paul G. Cassell Pro Ha

lating to alleged indiscretion within the department). • Any attorney-client privilege is subject to a crime-fraud-misconduct exception. See In re Sealed Case, 754 F.2d 395, 399 (D.C. Cir. 1985). The victims intend to argue that the crime-fraud-misconduct exception applies on the facts of this case.' • A

D: June 28, 2013 14 EFTA00209613 Case 9:08-cv-80736-KAM Document 198 Entered on FLSD Docket 06/28/2013 Page 15 of 16 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at th

nt 198 Entered on FLSD Docket 06/28/2013 Page 15 of 16 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. and Paul G. Cassell Pro Hac Vice S.J. Quinney College of Law at the University of Utah Attorneys for Jane Doe #1 and Ja

tside the reach of the Perlman doctrine. Perlman applies to someone who holds a privilege, not someone who is arguing for a new privilege. See In re Sealed Case, -- -F.3d---, 2013 WL 2120157 at *5 (D.C. Cir. 2013) ("Typically, Perlman permits a privilege- holder to appeal a disclosure order directed at a disi

rsons have an interest in the outcome of this case: 1. Marra, The Honorable Kenneth 2. Acosta, R. Alexander 3. Black, Roy 4. Cassell, Paul G. 5. Edwards, Bradley J. 6. Epstein, Jeffrey 7. Ferrer, Wifredo A. 8. Howell, Jay 9. 10 11 12 13 14 15 11 Page C-1 of 2 EFTA00209658 Case: 13-12923

1987) 53 In re MTSG, Inc., 675 F.3d 1337 (Fed. Cir. 2012) 32, 33 In re RDM Sports Group, Inc., 277 B.R. 415 (N.D. Ga. 2002) 34, 40 In re Sealed Case, 716 F.3d 603 (D.C.Cir. 2013) 54 In re Six Grand Jury Witnesses, 979 F.2d 939 (2d Cir. 1992), cert. denied sub nom. XYZ Corp. v. United States,