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

unds, 44.3d 324, 843 =2d 218 (1st Dep't 2007) 15 Associated Gen. Contractors of Conn., Inc. v. City of New Haven, 41 F.3d 62 (2d Cir. 1994) 13 Baxter v. Palmigiano, 425 U.S. 308 (1976) 21 Buttner v. Berg & Dorf, 138 ad 439, 525 MI.2d 858 (2d Dep't 1988) 19 Branzburg v. Hayes, 408 U.S. 665 (1972) 23 Bro

ndants, STATEMENT OF UNDISPUTED FACTS Defendant Bradley J. Edwards, Esq., offers the following specific facts as the undis

this subject at his deposition, Epstein invoked his Fifth Amendment right to remain silent rather than make an incriminating admission. Accordingly, Edwards is entitled to the adverse inference against Epstein that, had Epstein answered, the answer would have been unfavorable to him. "[I]t is well-settle

ffidavit") (Exhibit "N"). 32. On June 13, 2008, attorney Edwards agreed to represent..; on July 2, 2008, attorney

does not forbid adverse inferences against parties to civil actions when they refuse to testify in respqmLwprobative evidence offered against them." Baxter v. Palmigiano, 425 U.S. 308, 318 (1976); accord v. State, 777 So.2d 1200, 1203 (Fla. App. 2001). The reason for this rule "is both logical and utilitarian. A pa

S'S MOTION FOR FINAL SUMMARY JUDGMENT Defendant, Bradley J. Edwards, Esq., by and through his undersigned counsel and pursu

for all claims brought against him in Plaintiff Jeffrey Epstein's Complaint. Not only is there an absence of competent evidence to demonstrate that Edwards participated in any fraud against Epstein, the evidence uncontrovertibly demonstrates the propriety of every aspect of Edwards' involvement in the p

rt claims. The only cases not resolved are this case and two (2) cases in state court (all three Plaintiffs are represented by Plaintiff's counsel, Brad Edwards, Esq. and his firm). I 5. Plaintiffs in other filed cases were represented by various law firms as the court is aware. 6. With the additional disco

not forbid adverse inferences against parties to civil actions when they refuse to testify in response to probative evidence offered against them." Baxter v. Palmigiano, 425 U.S. 308, 318 (1976); accord Vasquez v. State, 777 So.2d 1200, 1203 (Fla. App. 2001). The reason for this rule "is both logical and utilitarian

llion bond to secure any potential judgment that Jane Doe might obtain in this case. DATED this 19th day of June, 2009. Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre AC14 I OCfl And Paul G. Cassell Pro Hac Vice Ll 19 EFTA00234889 Case

venue Suite 340 Coconut Grove, Florida 33133 tein(alewistein.com Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS & ASSOCIATES, LLC By: Brad Edwards, Esquire Attorney for Plaintiff Florida Bar No. 542075 Paul G. Cassell Attorney for Plaintiff Pro Hac Vice EFTA00234902 D5/18O008 15:5$ FA)C,

ne, 2009. Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards ROTHSTEIN ROSENFELDT ADLER

e to permit an adverse inference to be drawn from exercise of the privilege does not implicate the policy considerations underlying the privilege." Baxter v. Palmigiano, 425 U.S.308, 335 (1976). An adverse inference is entirely justified in this case. Epstein has remained silent when asked such straightforward requ

IT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408003OOOOvIBAG DEFENDANT/COUNTER-PLAINTIFF, BRADLEY J. EDWARDS, RESPONSE IN dPPOSITION TO JEFFERY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER RBLATING TO HIS DEPOSITION AND IN SUPPORT OF EDWARDS' MOTINO TO COMPEL

AINTIFF, BRADLEY J. EDWARDS, RESPONSE IN dPPOSITION TO JEFFERY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER RBLATING TO HIS DEPOSITION AND IN SUPPORT OF EDWARDS' MOTINO TO COMPEL AND IMPOSE SANCTIONS j Defendant/Counterplaintiff, Bradley J. Edwards (hereinafter EDWARDS), by and throligh his undersigned

ke the legal system by filing a Complaint against attorney EDWARDS. Accordingly, just like any other civil plaintif

plaintiff's answers can be used against him through adverse inferences. See, e.g , In re J.E.B., 971 So.2d 187, 188 (Fla.App. 2 Dist. 2007) (citing Baxter v. Palmigiano, 425 U.S. 308 (1976) ("[T]he Fifth Amendment does not forbid adverse inferences against parties to civ I actions when they refuse to testify in res