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CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and ■l., individually, Defendants. RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION FOR COURT TO DECLARE RELEVANCE AND NON-PRIVILEGED NA
eference to Documents Containing Privileged Materials Listed on Edwards' Privilege Log, filed on March 5, 2018. 2. In addition to those arguments, Edwards states as follows: I For brevity, Edwards shall refer to Epstein's motion as the "Motion for Court to Declare Relevance." EFTA00808645 Edwards ad
enterprise, which included access to every email on the RRA server. No one (aside from Jeffrey Epstein) ever suggested, implied, or insinuated that Brad Edwards had any involvement or knew anything about Rothstein's illegal activities. Brad Edwards was never even formally interviewed by the authorities. Yet
ion titled "Edwards' Direct Involvement in Rothstein's Ponzi Scheme." If nothing but consistent, Epstein, through counsel, then sprinkles throughout the Motion for Court to Declare Relevance direct accusations and implicit insinuations that, regardless of whether 2 The idiom "jumping the shark" is a pejorative refer
EPSTEIN'S MOTION FOR IN CAMERA INSPECTION OF 30 E-MAILS Counter-Defendant Jeffrey Epstein ("Epstein") responds in opposition to Counter-Plaintiff Bradley J. Edwards' ("Edwards") November 13, 2018, Motion to Strike Epstein's Motion for in Camera Inspection of 30 E-Mails and states: INTRODUCTION Edwards knows onl
ividually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO EDWARDS' MOTION TO STRIKE EPSTEIN'S MOTION FOR IN CAMERA INSPECTION OF 30 E-MAILS Counter-Defendant Jeffrey Epstein ("Epstein") responds in opposition to C
ion titled 'Edwards' Direct Involvement in Rothstein's Ponzi Scheme.' If nothing but consistent, Epstein, through counsel, then sprinkles throughout the Motion for Court to Declare Relevance direct accusations and implicit insinuations that, regardless of whether Epstein had probable cause to institute or continue h
EPSTEIN'S MOTION FOR IN CAMERA INSPECTION OF 30 E-MAILS Counter-Defendant Jeffrey Epstein ("Epstein") responds in opposition to Counter-Plaintiff Bradley J. Edwards' ("Edwards") November 13, 2018, Motion to Strike Epstein's Motion for in Camera Inspection of 30 E-Mails and states: INTRODUCTION Edwards knows onl
ividually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO EDWARDS' MOTION TO STRIKE EPSTEIN'S MOTION FOR IN CAMERA INSPECTION OF 30 E-MAILS Counter-Defendant Jeffrey Epstein ("Epstein") responds in opposition to C
ion titled 'Edwards' Direct Involvement in Rothstein's Ponzi Scheme.' If nothing but consistent, Epstein, through counsel, then sprinkles throughout the Motion for Court to Declare Relevance direct accusations and implicit insinuations that, regardless of whether Epstein had probable cause to institute or continue h
Entities connected to both Bradley Edwards and the Motion for Court

Jeffrey Epstein
PERSONJane Doe
PERSON
Paul Cassell
PERSONJack Goldberger
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
Ghislaine Maxwell
PERSON
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
Searcy
PERSONNichole J. Segal
PERSONBurlington & Rockenbach
ORGANIZATION