Epstein Secrets

cedures. I don't remember saying anything different in this case. I did not see any FBI letters in this case prior to collecting the FBI letters to Brad Edwards' clients in connection with the Jane Doe I United States litigation. I did not instruct the FBI to include the language about the case being under in

y Circuit Court (Exhibit B-41). I responded, acknowledging his representation (Exhibit B-42). On June 18, 2008, I liv received a call from attorney Brad ards, who told me that he represented Individual #43, who is also Jane Doe #1 in the Jane Doe United States lawsuit. Mr. Edwards expressed an interest

a call from attorney Brad ards, who told me that he represented Individual #43, who is also Jane Doe #1 in the Jane Doe United States lawsuit. Mr. Edwards expressed an interest in assisting with the case. We were still waiting to hear about whether we would be moving " On the State side, Lefkowitz has

rida Bar rules against solicitation. He had filed complaints against myself and against Robert Josefsberg — the attorney-representative selected by the Special Master. On September 18, 2008, I wrote to the Florida Bar asking for an Ethics opinion (Exhibit B-93). I did not feel that I could send out any additional

D MOTION FOR SUMMARY JUDGMENT Plaintiff, Jeffrey Epstein ("Plaintiff" or "Epstein"), hereby files the following Response in Opposition to Defendant Bradley J. Edwards' ("Edwards") Renewed Motion for Summary Judgment ("Motion") and states as follows:' SUMMARY OF ARGUMENT Edwards' Renewed Motion for Summary Judgmen

OTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT EDWARDS' RENEWED MOTION FOR SUMMARY JUDGMENT Plaintiff, Jeffrey Epstein ("Plaintiff" or "Epstein"), hereby files the following Response in Opposition to De

resently works, and to prepare a privilege log. The Plaintiff, without objection, agreed and was ordered to pay the legal fees and costs incurred by the Special Master in the preparation of this log (A :5). Prior to the hearing, two motions in opposition were filed by Farmer Jaffee (A: 3 and 4). Subsequently, on

t Production Protocol, as established by D.E. #672 (D.B. #807); (ii) Motion for Protective Order filed by Interested Party Fanner, Jaffe, Weissing, Edwards, Fistos and Lefunzan, P.L. ("Painter, Jaffe") (D.E. #81 8) and its related amendment (D.E. #819). The Court heard argument of all counsel present at

Qtask data for purposes of determining the applicability of the attorney/client and work product privileges that may inure to the benefit of L.M., Brad Edwards, and other current or former clients of Fanner, Jaffe; (ii) segregate any such privileged documents; and (iii) prepare a privilege log in accordanc

counsel for Fanner, Jaffe and counsel for the Trustee to hear their respective positions concerning these matters. Upon completion of the review by the Special Master, the Special Muster shall prepare and file a privilege log with the Court. No documents or ESI shall be released to anyone until such time as the S

t Production Protocol, as established by D.E. #672 (D.B. #807); (ii) Motion for Protective Order filed by Interested Party Fanner, Jaffe, Weissing, Edwards, Fistos and Lefunzan, P.L. ("Painter, Jaffe") (D.E. #81 8) and its related amendment (D.E. #819). The Court heard argument of all counsel present at

Qtask data for purposes of determining the applicability of the attorney/client and work product privileges that may inure to the benefit of L.M., Brad Edwards, and other current or former clients of Fanner, Jaffe; (ii) segregate any such privileged documents; and (iii) prepare a privilege log in accordanc

counsel for Fanner, Jaffe and counsel for the Trustee to hear their respective positions concerning these matters. Upon completion of the review by the Special Master, the Special Muster shall prepare and file a privilege log with the Court. No documents or ESI shall be released to anyone until such time as the S

United States litigation, asserting that his clients wanted to 4 1 few days after Jeffrey Epstein entered his guilty plea in state court, attorney Brad Edwards filed suit on behalf of one of the victims identified in the federal investigation (later expanded to include I second victim who had been identifie

ng aside the NPA would not benefit his clients, and he sued Epstein on behalf of I number of victims under the NPA. I did what I could to assist Mr. Edwards, other attorneys, including Mr. Josefsberg, the attorney selected by the Special Master, and the Court, to locate victims, provide signed copies of

rida Bar rules against solicitation. He had filed complaints against myself and against Robert Josefsberg — the attorney-representative selected by the Special Master. On September 18, 2008, I wrote to the Florida Bar asking for an Ethics opinion (Exhibit B-93). I did not feel that I could send out any additional

t Production Protocol, as established by D.E. #672 (D.B. #807); (ii) Motion for Protective Order filed by Interested Party Fanner, Jaffe, Weissing, Edwards, Fistos and Lefunzan, P.L. ("Painter, Jaffe") (D.E. #81 8) and its related amendment (D.E. #819). The Court heard argument of all counsel present at

Qtask data for purposes of determining the applicability of the attorney/client and work product privileges that may inure to the benefit of L.M., Brad Edwards, and other current or former clients of Fanner, Jaffe; (ii) segregate any such privileged documents; and (iii) prepare a privilege log in accordanc

counsel for Fanner, Jaffe and counsel for the Trustee to hear their respective positions concerning these matters. Upon completion of the review by the Special Master, the Special Muster shall prepare and file a privilege log with the Court. No documents or ESI shall be released to anyone until such time as the S