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privileged and not privileged, potentially responsive to a subpoena issued in the Palm Beach State Court case of Jeffrey Epstein v. Scott Rothstein, Bradley J. Edwards, and L.M., Fifteenth Judicial Circuit, in and for Palm Beach County, Florida Case No. 50-2009 CA 040800XXXX MB AG (hereinafter "the Epstein lawsuit"
arent violation of the Court's order was uncovered on the eve of trial of the Epstein lawsuit, which concerns a malicious prosecution claim filed by Edwards against Epstein, and which was previously set for trial on March 13, 2018.' Specifically, on March 2, 2018, Epstein, through his trial counsel Link
counsel and numerous pleadings were filed on these late-disclosed, privileged, and improperly retained communications, including but not limited to Edwards' Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Contained Privileged Materials Listed on Edwards' Privileg
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
o list as exhibits the week before the parties' March 13, 2018 trial date. Those documents are identified in the chart below, which was included in Edwards' Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privile
ION OF COURT ORDER AND THE INTERVENORS' JOINDER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") responds in opposition to Counter- Plaintiff Bradley J. Edwards' ("Edwards") April 3, 2018, Motion for Sanctions for Violation of Court Order', and the Intervenors' April 7, 2018, Joinder and states: INTRODUCTION
and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO EDWARDS' MOTION FOR SANCTIONS FOR VIOLATION OF COURT ORDER AND THE INTERVENORS' JOINDER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") responds in
0808676 THE COURT'S MARCH 8. 2018. HEARING On March 8, 2018, the parties attended a special set hearing on a number of pending Motions, including Edwards' Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privile
ION OF COURT ORDER AND THE INTERVENORS' JOINDER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") responds in opposition to Counter- Plaintiff Bradley J. Edwards' ("Edwards") April 3, 2018, Motion for Sanctions for Violation of Court Order', and the Intervenors' April 7, 2018, Joinder and states: INTRODUCTION
and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO EDWARDS' MOTION FOR SANCTIONS FOR VIOLATION OF COURT ORDER AND THE INTERVENORS' JOINDER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") responds in
nctions. THE COURT'S MARCH 8, 2018. HEARING On March 8, 2018, the parties attended a special set hearing on a number of pending Motions, including Edwards' Motion to Strike Epstein's Untimely Supplemental Exhibits and to Strike all Exhibits and Any Reference to Documents Containing Privileged Materials Listed on Edwards' Privile
Entities connected to both Bradley Edwards and Edwards' Motion to Strike Epstein's

Jeffrey Epstein
PERSONJane Doe
PERSON
Paul Cassell
PERSONJack Goldberger
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
Salt Lake City
LOCATION
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATIONPalm Beach Lakes Boulevard
LOCATION
Jay Howell
PERSONGoldberger & Weiss
ORGANIZATIONMarc S. Nurik
PERSON
Jacksonville
LOCATION
Lauderdale
LOCATION
Scott J. Link
PERSON
Fowler
PERSON
Searcy
PERSON