Epstein Secrets

E. The Present Motion to Compel I0 ARGUMENT 11 I. EDWARDS MAY NOT RELY ON THE VACATED DISTRICT COURT ORDER FROM THE JANE DOE ACTION 12 II. EDWARDS FAILS TO MEET THE REQUIREMENTS FOR DISCOVERY OF A NON-PARTY UNDER CPLR 3101(a) 14 A. The Epstein Interview Does Not Have Heightened Relevance to

a deposition in one of the now-settled suits by implying that "he did not recognize" reporter Rush. Moving Br. at 17; see also Moving Affidavit of Bradley James Edwards, sworn to Sept. 14, 2010 ("Edwards Aft"), ¶ 22. Besides being farfetched and factually unsupported, Edwards' apparent desire to attack Epstein's cr

pstein sex abuse litigation, as even a quick Google search reveals. See. e.g., Heiress Quizzed in Sex Suits. M. POST, Oct. 12, 2009 ("Florida lawyer Brad Edwards. who represents three of the 'Jane Does' who are suing Epstein, told Page Six that Phislaine] Maxwell would be questioned over her knowledge of how

lawyers and others close to the case — including attorney Edwards — who could provide tips and information to assi

,25 29 28,29 In re Zallie, 2009 WL 2844429 (Sup. Ct. M. Co. Aug. 13, 2009) 12, 15, 21 Johnson Law Group v. limadebt USA, LLC, 2010 WL 2035284 (M. Fla. May 24, 2010) 18 Kirkland & Ellis v. Chadl e & Parke LLP, 176 Misc.2d 73, 670 .2d 753 (Sup. Ct. Co. 1998) 12 Kooper v. Kooper, 74 El3d 6, 901

than 27,000 pages of e-mails, thousands of which have been produced to Epstein and only 47 e-mails which Epstein identified as trial exhibits that Edwards claim are privileged. Indisputably, no court has deemed the documents on the disc or the 47 e-mails to be attorney-client privileged, or even addres

SERVICE LIST Jack Scarola Searcy, Denny, Scarola, Barnhart & Shipley, . 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Counsel for Bradley J. Edwards Bradley J. Edwards Brittany N. Henderson Edwards Pottinger LLC 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 Counsel for Farmer

l states in controversy. See D.E. 6432; see also, e.g., Reaves v. Wayne Automatic Fire Sprinklers, Inc., No. 2:11-cv-00049-CEH-SPC, 2011 WL 4837253 (M. Fla. Oct. 12, 2011). As such, Rule 35 entitles Epstein to the Intervenors' independent mental examinations. The Intervenors suggest that Rule 35 does no

Appellate Case No. 4D18-0787 LT Case No. 502009CA040800XXXXMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants.1 REPLY TO RESPONSE TO PETITION FOR WRIT OF CERTIORARI On Review of a Non-Final Order of the Circuit Court of

E.W. and Jane Doe have sought to intervene below on a limited and unrelated issue. As such, they are not parties in this certiorari proceeding, and Edwards has improperly captioned them as such on his Response. EFTA00808455 INTRODUCTION Disappointingly, Bradley Edwards ("Edwards") has used his Respo

2d 733, 737 (Fla. 3d DCA 1981) (emphasis added). See also Estate of Carrillo v. Fed. Deposit Ins. Corp., No. 11-22668-CIV, 2012 WL 13013081, at *1 (M. Fla. Apr. 25, 2012) ("Bifurcation is the exception, not the rule, and the party seeking bifurcation shoulders the heavy burden of establishing that bifu