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3301 54)467-1223 Attorneys for Jeffrey Epstein Bradley J. Edwards, Esq. FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHR
f/Counter-Defendant's Motion for Fees and Costs, and as grounds therefor would state: INTRODUCTION This case arises from Epstein's lawsuit against Edwards, when Epstein sued Edwards merely for his legal representation of people accusing Epstein of misconduct. Edwards counter- sued Epstein for, inter al
District has specifically contemplated that so-called non-monetary terms can have a monetary value, a principal which made the proposal invalid in Zalis v. M.E.J. Rich Corp., 797 So.2d 1289 (Fla. 4th DCA 2001). In that case, the inclusion of a condition of acceptance that the plaintiff and his attorn
000914 EFTA00189669 U.S. Department of Justice United States Attorney Southern District of Florida September 3, 2008 VIA UNITED STATES MAIL Brad Edwards, Esq. 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 Re: Jeffrey Epstein/Sat AMENDED NOTIFICATION OF IDENTIFIE M Dear Mr. Edwards:
ad Edwards, Esq. 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 Re: Jeffrey Epstein/Sat AMENDED NOTIFICATION OF IDENTIFIE M Dear Mr. Edwards: By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following amended not
orida asks that you provide the following amended notice to your client, IMMZ.. Some of the information contained in the July 10, 2008 letter to Ms. Zalis was inaccurate, so please advise her of the following changes. As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter refe
ISION AG CASE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. / PLAINTIFF JEFFREY EPSTEIN'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS BY DEFENDANT BRADLEY EDWARDS
gh his undersigned counsel, hereby respectfully seeks the entry of an Order compelling Defendant Bradley Edwards to produce the documents listed in Edwards' privilege log, or, in the alternative, the entry of an Order compelling Edwards to serve a privilege log that fully complies with Fla. R. Civ. P. 2
ilege in regard to the production of documents because the petitioner filed a privilege log which was "completely inadequate"); Kaye Scholer LLP v. Zalis, 878 So. 2d 447, 449 (Fla. 3d DCA 2004) (the purpose of the privilege log requirement is "to identify materials which might be subject to a privileg
0 South Australian Ave.. Suite 400 West Palm Beach. Fl. 33401 (561) 820-8711 Facsimile: (561) 820-8777 September 3, 2008 VIA UNITED STATES MAIL Brad Edwards, Esq. 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 Re: Jeffrey Epstein/SS:I AMENDED NOTIFICATION OF IDENTIFIE M Dear Mr. Edwards:
d Edwards, Esq. 2028 Harrison Street, Suite 202 Hollywood, Florida 33020 Re: Jeffrey Epstein/SS:I AMENDED NOTIFICATION OF IDENTIFIE M Dear Mr. Edwards: By virtue of this letter, the United States Attorney's Office for the Southern District of Florida asks that you provide the following amended not
orida asks that you provide the following amended notice to your client, IMMZ.. Some of the information contained in the July 10, 2008 letter to Ms. Zalis was inaccurate, so please advise her of the following changes. As you were previously advised, on June 30, 2008, Jeffrey Epstein (hereinafter refe
Entities connected to both Bradley Edwards and Zalis

Jeffrey Epstein
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
United States
LOCATIONSouthern District
LOCATION
Prince Andrew
PERSONthe Southern District
LOCATION
A. Marie Villafana
PERSON
Department of Justice
ORGANIZATION
Alexander Acosta
PERSONRobert C. Josefsberg
PERSONKatherine W. Ezell
PERSON
Marc Rich
PERSONFBI
ORGANIZATIONTonja Haddad Coleman
PERSON
West Palm Beach
LOCATION
Jeffrey Marc Herman
PERSON