Epstein Secrets

A JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1201 Plaintiff, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendants. / DRAFT 4/26/11 PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S AMENDED MOTION FOR A PROTECTI

, Esq., counsel for the Defendant/Counter-Plaintiff, Bradley J. Edwards, was quoted as stating: I) "The sole motivation for these claims against Mr. Edwards is an attempt to intimidate him so as to abandon the justified prosecution of his claims against Mr. Epstein"; and 2) "This constitutes a very subs

led "Claim: Epstein Filed Lawsuit to `Intimidate' Attorney Edwards Prosecuting Sex Abuse Cases," Jack Scarola, Esq.

e," as he has done. (See Exhibit 10). By using the epithet in open court, it becomes part of the public record and fodder for the media. Pursuant to Fla. R. Evid. 404, Mr. Scarola could not use such an epithet during the trial or introduce evidence to support the disparaging characterizations 24. The extra

EFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1201 Plaintiff, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, ead-laiadividually3 Defendants. DRAFT 4/26/11 PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S AMENDED MOTION FOR A PROTECTIVE ORDER

, Esq., counsel for the Defendant/Counter-Plaintiff, Bradley J. Edwards, was quoted as stating: I) "The sole motivation for these claims against Mr. Edwards is an attempt to intimidate him so as to abandon the justified prosecution of his claims against Mr. Epstein"; and 2) "This constitutes a very subs

led "Claim: Epstein Filed Lawsuit to `Intimidate' Attorney Edwards Prosecuting Sex Abuse Cases," Jack Scarola, Esq.

e," as he has done. (See Exhibit 10). By using the epithet in open court, it becomes part of the public record and fodder for the media. Pursuant to Fla. R. Evid. 404, Mr. Scarola could not use such an epithet during the trial or introduce evidence to support the disparaging characterizations 24. The extra

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

of Edwards' "facts" detail in graphic terms alleged misconduct by Epstein wholly unrelated to the allegations in the instant litigation. Pursuant to Fla. R. Evid. §90.404(1), evidence of other crimes, wrongs or acts is inadmissible when the evidence is introduced solely to prove bad character, or that the pe