Epstein Secrets

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,

t via E-Serve to all Counsel on the attached list, this 6ih day of February, 2018. /s/ David P. Titath Jr. JACK SCAROLA Florida Bar No.: 169440 DAVID P. VITALE JR. Florida Bar No.: 115179 Attorne E-Mail(s): and Primary E-Mail: Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Boulevard West

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

sent via E-Serve to all Counsel on the attached list, this at; day of July, 2018. JACK SCAROLA Florida Bar No.: KAREN E. TERRY Florida Bar No.: DAVID P. VITALE JR. Florida Bar No.: Attorney E-Mails: and Primary E-Mail: Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Boulevard West Palm Be

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

e to all all Counsel on the attached list, this an day of July, 2018. c JACK SCAROLA Florida Bar No.: 169440 KAREN E. TERRY Florida Bar No.: DAVID P. VITALE JR. Florida Bar No.: Attome E-Mails: •••••••• ;and Primary E-Mail: Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Boulevard Wes

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,

py of the foregoing was sent via E-Serve to all Counsel on the attached list, this 9 0-11--d:y of July, 2018. JACK SCAROLA Florida Bar No.: 169 DAVID P. VITALE JR. Florida Bar No.: Attorne E-Mail s : and Primary E-Mail: Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Boulevard West Palm B

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

the foregoing was sent via E-Serve 0 to all all Counsel on the attached list, this t t day of 2: 8. JAC' - • 'OLA Florida Bar No.: 16944 DAVID P. VITALE JR. Florida Bar No.: Attorney E-Mail Primary E-Mail: Searcy Denney Scarola Barnhart & Shipley, 2139 Palm Beach Lakes Boulevard West Palm Beach, Fl