Epstein Secrets

FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FL JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No. 50 2009 CA 040800XXXXMBAG v. BRADLEY J. EDWARDS, et al., Defendants/Counter-Plaintiff. JUDGE: HAFELE JEFFREY EPSTEIN'S RESPONSE TO BRADLEY EDWARDS'S MOTION IN LIMINE TO STRIKE THE JUNE 30.2017

ion for Summary Judgment, and to "exclude evidence as to which discovery was withheld under claims of privilege." As demonstrated more fully below, Edwards's Motion is deficient on its face, and in direct contravention to the facts. As such, Edwards's Motion should be denied. INTRODUCTION Epstein file

that there were other media, local media. I've been told that the -- his investigator was sent to California to harass people representing his -- Brad Edwards' investigator -- representing fictitiously, fraudulently that he was a FBI agent to try to gather information for Mr. Edwards' claims. See Depositi

sitting over their computer looking at their bank accounts. So, unfortunately, I would have to say, no, sir. Q. Have you ever personally witnessed Bradley Edwards engaged in money laundering? MR. PIKE: Form. THE WITNESS: Again, sir, the U.S. Attorney's Complaint of the Rothstein firm alleges money laundering

dence [is] substantially outweighed by the danger of unfair prejudice" to the party asserting the privilege. Id. at 1266 (citing Fed. R. Evid. 403; Brink's Inc. v. City of New York, 717 F.2d700, 710 (2d Cir. 1983)). Moreover, the inference may be drawn only when there is independent evidence of the fact abo

t nor pages reflecting the earlier testimony, are included in the exhibit.) M. is another anonymous plaintiff who is suing Epstein and is apparently Edwards' client. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as wel

aut Ins. Co. 757 F.2d 523 (2d Cir. 1985) 12 Best Canvas Products & Supplies. Inc. v. Ploof Truck Lines. Inc., 713 F.2d 618 (II th Cir. 1983) 12 Brink's Inc. v. City of New York 717 F.24 700 (2d Cir. 1983) 7 Drown & Williamson Tobacco Coro. v. Wigand, No. 101678/96, 1996 WL 350827 (N.Y. Sup. Ct. Feb. 2

t nor pages reflecting the earlier testimony, are included in the exhibit.) M. is another anonymous plaintiff who is suing Epstein and is apparently Edwards' client. Edwards Mitt 11 I I.24. She is also a co- defendant with Edwards in Epstein's racketeering and fraud suit against both Edwards and M. as wel

aut Ins. Co. 757 F.2d 523 (2d Cir. 1985) 12 Best Canvas Products & Supplies. Inc. v. Ploof Truck Lines. Inc., 713 F.2d 618 (II th Cir. 1983) 12 Brink's Inc. v. City of New York 717 F.24 700 (2d Cir. 1983) 7 Drown & Williamson Tobacco Coro. v. Wigand, No. 101678/96, 1996 WL 350827 (N.Y. Sup. Ct. Feb. 2