Epstein Secrets

ORDER GRANTING MOTION TO PERMIT BRADLEY J. EDWARDS TO TAKE THE LIMITED DEPOSITION OF JEFFREY EPSTEIN THIS CAUSE having come to be considered upon Bradley J. Edwards' ("Edwards") Motion to Permit Bradley J. Edwards to Take the Limited Deposition of Jeffrey Epstein, and the Court, having reviewed the file, conside

N TO PERMIT BRADLEY J. EDWARDS TO TAKE THE LIMITED DEPOSITION OF JEFFREY EPSTEIN THIS CAUSE having come to be considered upon Bradley J. Edwards' ("Edwards") Motion to Permit Bradley J. Edwards to Take the Limited Deposition of Jeffrey Epstein, and the Court, having reviewed the file, considered the ar

. Searcy Denney Scarola Barnhart & Shipley PA 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Phone: Fax: Attorneys for Plaintiff(s) Bradle Edwards, i Es 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: Fax: dai Attorneys for Jeffrey Epstein Jack A. Goldber er, Es uire Atterb

er, Es uire Atterbury Goldberger & Weiss, 250 Australian Avenue S, Suite 1400 West Palm B FL 33401 Phone: Fax: Attorneys for Jeffrey Epstein Nichole J. Se al, Es uire • Burlington & Rockenbach, 444 W Railroad Avenue, Suite 350 West Palm Beach, FL 33401 Phone: Fax: Attorneys for Jeffrey Epstein EFTA

CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and ■l., individually, Defendants. RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION FOR COURT TO DECLARE RELEVANCE AND NON-PRIVILEGED NA

eference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log, filed on March 5, 2018. 2. In addition to those arguments, Edwards states as follows: I For brevity, Edwards shall refer to Epstein's motion as the "Motion for Court to Declare Relevance." EFTA00808645 Edwards ad

enterprise, which included access to every email on the RRA server. No one (aside from Jeffrey Epstein) ever suggested, implied, or insinuated that Brad Edwards had any involvement or knew anything about Rothstein's illegal activities. Brad Edwards was never even formally interviewed by the authorities. Yet

dber er, Esquire ig Atterbury Goldberger & 250 Australian Avenue S, Suite 1400 WPst Palm Rnarh FT 3401 Pho Fax: Attorneys for Jeffrey Epstein Nichole J. Se al, Es Esquire • Burlington & Rockenbach, 444 W Railroad Avenue, Suite 350 West Palm Beach. FL 33401 Phone: Attorneys for Bradley J. Edwards Bra

CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS. individually, and individually, Defendants. RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION TO REMOVE CASE FROM TRIAL DOCKET IN ORDER TO COMPLY WITH

ein's Motion to Remove Case from Trial Docket in Order to Comply with the Mandate Set Forth in Rule 1.440, and in support states as follows: 1. As Edwards has argued for months, Epstein has no intention of ever trying this malicious prosecution case. At the eve of every trial date, Epstein files a host

ther institute or continue the underlying proceeding against Edwards. But Epstein will not admit his wrongdoing and is once again attempting to drag Brad Edwards' name and reputation through the mud, and this time wants to drag many others in as well. 16. Epstein and his counsel, however, benefit (so far) fr

er, Esquire Atterbury Goldberger & Weiss, 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Pho Fax: Attorneys for Jeffrey Epstein Nichole J. Se al, Es Esquire • Burlington & Rockenbach, 444 W Railroad Avenue, Suite 350 West Palm Beac FL 33401 Phone: Attorneys for Bradley J. Edwards Bra .

/2018 05:46:22 PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG BRADLEY J. EDWARDS, Plaintiff(s), vs. JEFFREY EPSTEIN, Defendant(s). NOTICE OF HEARING YOU ARE HEREBY NOTIFIED that the undersigned has called up for hearing the

rt & Shipley, P.A. 2139 Palm Beach Lakes Boulevard West Palm Beach Florida 33409 Phone: Fax: Attorneys for BRADLEY J. EDWARDS 2 EFTA00806675 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Hearing COUNSEL LIST Bradle J. Edwards, Es Esquire 425 N Andrews Avenue, Suite 2 Fort

0800XXXXMBAG Notice of Hearing COUNSEL LIST Bradle J. Edwards, Es Esquire 425 N Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phony Fax: Nichole J. Se al, Es uire • Phili Burlin on, Es Esquire Burlington & Rockenbach, P.A. 444 W Railroad Avenue, Suite 350 West Palm Beach, FL 33401 Phone: Attorne

CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M., individually, Defendant, REOUESTS FOR ADMISSION TO COUNTER-DEFENDANT JEFFREY EPSTEIN Counter-Plaintiff, Bradley J. Edwards

VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M., individually, Defendant,

Es.uire Atterbury Goldberger & Weiss, M. 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Pho Fax: Attorneys for Jeffrey Epstein Nichole J. Se al, Es.uire • Burlington & Rockenbach, 444 W Railroad Avenue, Suite 350 West Palm Beach, FL 33401 Phone: (561)-721-0400 Fax: Attorneys for Jeffre

CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and individually, Defendants. RESPONSE IN OPPOSITION TO DEFENDANT JEFFREY EPSTEIN'S MOTION TO COMPEL COUNTER-PLAINTIFF BRADLEY J.

ENDANT JEFFREY EPSTEIN'S MOTION TO COMPEL COUNTER-PLAINTIFF BRADLEY J. EDWARDS TO IDENTIFY BATES NUMBERS OF DOCUMENTS PRODUCED Bradley J Edwards ("Edwards"), by and through undersigned counsel, hereby files this Response in Opposition to Defendant Jeffrey Epstein's Motion to Compel Edwards to Identify

. Goldbe er, uire After ury oldberger & 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Phon Fax: Attorneys for Jeffrey Epstein Nichole J. Se al, Es uire • Burlington & Rockenbach, 444 W Railroad Avenue, Suite 350 West Palm Beach, FL 33401 Phone: (561)-721-0400 Attorneys for Bradley J. E

c.it JUDGE DONALD HAFELE Circuit Judge Copies furnished to: F F F F F F F F F F F F F F F F F F F F F Andrew A. Harris (~~) Bradley James Edwards (ffillia Fred Haddad an) John Scarola irsETPH \CKERMAN JR Maria Kelchian ~la) Matthew D Weissing II~M) Pi 4IMP M RUM INC- roN service@jurytri

ENDANT JEFFREY EPSTEIN'S MOTION TO ALLOW AMENDMENT TO EXHIBIT LIST AND SUPPLEMENT TO MOTION TO ALLOW AMENDMENT TO EXHIBIT LIST Bradley J Edwards ("Edwards"), by and through undersigned counsel, hereby files this Response in Opposition to Defendant Jeffrey Epstein's Motion to Allow Amendment to Exhibit

r, Es uire Atterbury Goldberger & Weiss, 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Phon Fax: Attorneys for Jeffrey Epstein Nichole J. Se al, Esquire Burlington & Rockenbach, 444 W Railroad Avenue, Suite 350 West Palm Beach, FL 33401 Phone: Attorneys for Bradley J. Edwards Bradle J.

CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and individually, Defendant, RESPONSE IN OPPOSITION TO EPSTEIN'S RENEWED MOTION FOR LEAVE TO DISCLOSE EXPERT WITNESS Plaintiff, B

e Court's decision in Binger to argue that Epstein should be permitted to ignore this Court's pre-trial orders, as long as there is no prejudice to Edwards. This interpretation of Binger is wrong and is an affront to the authority of a trial court to control its docket. Epstein has already tried, once,

uire jg Atterbury Goldberger & Weiss, . 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Pho Fax: Attorneys for Jeffrey Epstein Nichole J. Se al, Es uire • Burlington & Rockenbach, 444 W Railroad Avenue, Suite 350 West Pa 3401 Phone: Attorneys for Bradley J. Edwards Link & Rockenbach,

CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and El., individually, Defendant, RESPONSE IN OPPOSITION TO DEFENDANT JEFFREY EPSTEIN'S MOTION TO COMPEL BRADLEY EDWARDS TO IDENTI

[U]nless Edwards' listed witnesses have personal knowledge of the matter at issue and can speak to what Epstein believed when he filed suit against Edwards, the witnesses' testimony would be irrelevant and collateral, and thus, inadmissible, even for purposes of impeachment. Mot. at p. 14 (emphasis add

r, Esquire Atterbury Goldberger & Weiss, 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Phon Fax: Attorneys for Jeffrey Epstein Nichole J. Se al, Es uire • Burlington & Rockenbach, 444 W Railroad Avenue, Suite 350 West Palm Beach, FL 33401 Phone: Attorneys for Bradley J. Edwards Scott J

CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, MOTION TO PERMIT BRADLEY J. EDWARDS TO TAKE THE LIMITED DEPOSITION OF JEFFREY EPSTEIN Bradley

Epstein designated 700+ new trial exhibits in this case. Included in that disclosure were at least 49 e-mail communications that had been listed on Edwards' privilege log since 2011 and which had never been produced in this case. The e-mails were derived from a disc possessed by Epstein's former counse

s. uire Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Pho Fax: Attorneys for Jeffrey Epstein Nichole J. Se al, Es. uire Burlington & Rockenbach, P.A. 444 W Railroad Avenue, Suite 350 West Palm Beach FL 33401 Phone: Attorneys for Bradley J. Edwards Kara