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EY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M., individually. Accordingly, EPSTEIN states: SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees
ey Edwards whether he would withdraw them in exchange for an affidavit from Mr. Rush attesting to the fact that he had interviewed Mr. Epstein. Mr. Edwards said he would not. 10. On Friday, April 30, 2010, I received service of a subpoena from Doe's counsel requiring movant journalist George Rush to a
etoric directed to cases against EPSTEIN used by Attorney EDWARDS and Berger changed dramatically in addressing th
for Admission as "[y]ou have committed sexual assault against Plaintiff, a minor," and "[y]ou digitally penetrated Plaintiff when she was a minor," SJ Opp. at 4, and his refusal to answer numerous questions at a Mar. 8, 2010, deposition, id. at 10 & Ex. D. 8. Annexed hereto as Exhibit E is a copy of
EY EPSTEIN, (hereinafter "EPSTEIN"), by and through his undersigned attorneys, files this action against Defendants, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and M., individually. Accordingly, EPSTEIN states: SUMMARY OF ACTION Attorney Scott Rothstein aided by other lawyers and employees
ey Edwards whether he would withdraw them in exchange for an affidavit from Mr. Rush attesting to the fact that he had interviewed Mr. Epstein. Mr. Edwards said he would not. 10. On Friday, April 30, 2010, I received service of a subpoena from Doe's counsel requiring movant journalist George Rush to a
etoric directed to cases against EPSTEIN used by Attorney EDWARDS and Berger changed dramatically in addressing th
tein's silence in the face of such confrontational Requests for Admission as "[y]ou have committed sexual assault against Plaintiff, a minor," and SJ Opp. at 4, and his refusal to answer numerous questions at a Mar. 8, 2010, deposition, id. at 10 & Ex. D. 8. Annexed hereto as Exhibit E is a copy of
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
ed on April 13.2010 ("Si Opp.").8 she repeatedly argues that in fact she has more than enough evidence against him to survive the motion. See. egs, SJ Opp. at 12 ("far from supporting summary judgment for the defendant, the evidence overwhelmingly inclines in favor") (see other examples Carroll Reply
tled his case; finding that "the probative value of this testimony is ex- tremely high because of its similarity with the allegations in this case"); SJ Opp. at 10-11 (- Statement of Material Fact (-SOMF") 1 19), citing F.R.E. 415 and passages of Epstein's and her own depositions in support of statement
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
d on April 13, 2010 ("Si Opp.").8 she repeatedly argues that in fact she has more than enough evidence against him to survive the motion. See. egs, SJ Opp. at 12 ("far from supporting summary judgment for the defendant, the evidence overwhelmingly inclines in Jane Doe's favor") (see other examples Carr
tled his case; finding that "the probative value of this testimony is ex- tremely high because of its similarity with the allegations in this case"); SJ Opp. at 10-11 (Doe's Statement of Material Fact (-SOMF") 1 19), citing F.R.E. 415 and passages of Epstein's and her own depositions in support of state
Entities connected to both Bradley Edwards and SJ Opp

Jeffrey Epstein
PERSONJane Doe
PERSON
Kenneth Marra
PERSONScott Rothstein
PERSON
George W. Bush
PERSONthe Southern District
LOCATION
Department of Justice
ORGANIZATION
Marc Rich
PERSON
Julie K. Brown
PERSON
New York
LOCATION
Prince Charles
PERSON
Palm Beach County
LOCATION
Stephen Hawking
PERSON
Southern District of New York
ORGANIZATION
Harvey Weinstein
PERSON
Bill Richardson
PERSON
Bradley Cooper
PERSON
the United States District Court
ORGANIZATION
South Florida
LOCATIONSecond Circuit
ORGANIZATION