Epstein Secrets

IN THE DISTRICT COURT OF APPEAL OF FLORIDA FOURTH DISTRICT CASE NO. 4D14-2282 BRADLEY J. EDWARDS, Appellant, v. JEFFREY EPSTEIN, Appellee. MOTION FOR LEAVE TO FILE SUPPLEMENTAL ARGUMENT The appellee, Jeffrey Epstein, respectfully moves for

28 So. 3d 67 (Fla. 3d DCA 2013) (holding that the litigation privilege applies to causes of action for malicious prosecution and abuse of process). Edwards appealed and is challenging the final judgment solely as to the malicious prosecution claim. 2. After the parties' briefs were filed, this Court is

rds, Rothstein was deposed. At the morning session of deposition on December 12, 2011, Rothstein was asked the following about Bradley Edwards: Q: Brad Edwards, would he have reported illegal activity? A: I don't know. Q: Would he have reported trust account defalcations? 22 R. 816, citing letter dated Ju

: I don't know." Rothstein's response to the same line of questioning when asked about all of the other attorneys with whom Edwards worked, such as Gary Fanner, Seth Lehrman, and Mark Fistos was, unequivocally, "yes", that they would have reported illegal activity." In the afternoon session of his deposit

ward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman 42

xhibits as referenced/used in the Deposition of Scott W. Rothstein taken by Epstein on June 14, 2012. 6. Privilege Log of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, Dated February 23, 2011 as filed in this matter and in In re: Rothstein Rosenfeldt Adler, P.A.; 09-34791 -RBR. 7. Docket from

Elizabeth Kim 4855 Technology Way, Suite 630 Boca Raton, FL 33431-3351 26. Christina Fitch 5 EFTA00691740 Address unknown at this time 27. Gary Fanner Fanner, Jaffe, Weissing, Edwards Fistos & Lerhman 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 28. Denis Kleinfeld 1001 Bricke

2 pertains to MS Capital, and on and on. 23 So, in any event, what we realized is 24 the case with respect to the Epstein vs. Scott 25 Rothstein, Bradley Edwards case, is this is 6 (Pages 21 to 24 OUELLETTE & MAULDIN COURT REPORTERS, INC. (335)358-8875 EFTA00206629 Case 9:08-cv-80893-KAM Document 214-3

tettin requesting doctunents from the RRA estate. 14 GARY PAPJAHR. ESQUIRE BRAD EDWARDS. ESQUIRE 15 That was back in April. 15 out getlf NUL BM Edwards and 16 While this was still in process, in Forma Rage %Wig Etats Fl3t0$ 4 Lchrman 17 May, under Docket Entry 672, your Honor entered 16 17 18

E BY DENTS (907L AMENDED MOTION FOR PROTECTIVEORDER 14 end of it. 13 14 15 ($19) August 4, 2010 15 16 MR. FARMER: Good morning, your Honor. Gary Fanner on behalf of LM, Brad Edwards, and 16 17 the Fanner Jaffe Wasting law firm. We are an 17 TN show-asdard ass came on for 18 interested party and

2 pertains to MS Capital, and on and on. 23 So, in any event, what we realized is 24 the case with respect to the Epstein vs. Scott 25 Rothstein, Bradley Edwards case, is this is 6 (Pages 21 to 24 OUELLETTE & MAULDIN COURT REPORTERS, INC. (335)358-8875 EFTA00213922 Case 9:08-cv-80893-KAM Document 214-3

tettin requesting doctunents from the RRA estate. 14 GARY PAPJAHR. ESQUIRE BRAD EDWARDS. ESQUIRE 15 That was back in April. 15 out getlf NUL BM Edwards and 16 While this was still in process, in Forma Rage %Wig Etats Fl3t0$ 4 Lchrman 17 May, under Docket Entry 672, your Honor entered 16 17 18

E BY DENTS (907L AMENDED MOTION FOR PROTECTIVEORDER 14 end of it. 13 14 15 ($19) August 4, 2010 15 16 MR. FARMER: Good morning, your Honor. Gary Fanner on behalf of LM, Brad Edwards, and 16 17 the Fanner Jaffe Wasting law firm. We are an 17 TN show-asdard ass came on for 18 interested party and

tained images or copies of the subject documents on its computer or otherwise, the Court retains jurisdiction to award sanctions in favor of Farmer, Brad Edwards, or his client. This type of Order was essential to protect Farmer Jaffe and its client from the potential problems that could arise from the unpre

at Rothstein, Rosenfeldt, Adler ("RRA") and continued the prosecution of those civil cases against Jeffrey Epstein. When the RRA law firm imploded, Edwards joined in forming the law firm of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman ("Farmer Jaffe"), and continued prosecuting those cases. Days a

rney—Farmer Jaffe vehemently objected to this Fowler White in-house printing process. In fact, after a series of both written and verbal objections, Gary Fanner specifically explained to Judge Carney, "based on your meeting and assurance, and in order to move this whole matter forward to the inevitable conc

22 pertains to MS Capital, and on and on 23 So, in any event, what we realized is 24 the cue with respect to the Epstein vs. Scott 25 Rothstein, Bradley Edwards case, is this is 6 (Pages 21 10 24 OUELLETTE & MAULDIN COURT REPORTERS, MC. EFTA00235306 Case 9:08-cv-80893-KAM Document 214-3 Entered on FLSD

or 5 the interested party, LM, also on behalf of 6 it, whether ifs a special master or whether it's 6 Brad Edwards and I'm sorry, your Honor, Mr. Edwards 7 a contract attorney, if they need to do that, but 7 is here with me. I neglected to Introduce him to S 8 1 don't think wo even need to reach th

BY DB0672 (S07), AMENDED MOTION FOR PROTL'CTIVE ORDER 14 end of It. 13 (SIR) 15 MR. FARMER: Good morning, your HOME 14 15 August 4,2010 16 Gary Fanner on behalf of LM, Brad Edwards, and I6 17 the Fanner Jaffe Wasting law firm. We are an 17 The ahow-cndaal ass mit on for 18 interested party and