Epstein Secrets

ESQUIRE Burman, rr4tfnn or al. 1 1 1 1 14 15 1 17 18 19 20 21 22 23 2 2 On behalf of Third Party E.W. WILLIAM J. BERGER, ESQUIRE BRADLEY J. EDWARDS, ESQUIRE Rothstein Rosenfeldt Adler On behalf of Third Party, The Post DEANNA SHULLMAN, ESQUIRE Thomas, LoCiero & EFTA00233769 Proceedings Jun

Ms. Shullman, good morning. Mr. Borger, gOOd morning. And Hr. Berger, your client is E -- HR. BERGER: E.W., yes. THE COURT: Anybody else here? MR. EDWARDS: Brad Edward■ on behalf of E.N. as well, Judge. Thanks. EFTA00233748 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 2

man, good morning. Mr. Borger, gOOd morning. And Hr. Berger, your client is E -- HR. BERGER: E.W., yes. THE COURT: Anybody else here? MR. EDWARDS: Brad Edward■ on behalf of E.N. as well, Judge. Thanks. EFTA00233748 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25

fense was confirmed when she was interviewed by 'Attorney Edwards filed his Motion on behalf of "Jane Doe," without

2d 153 (Fla. 4th DCA 1996); see, Menke'. Broward School Bd, 916 So.2d 8 (Fla. 4th DCA 2005). The requirement of irreparable harm is jurisdictional. Allstate; Barad & Co. A petitioner's failure to demonstrate the satisfaction of this jurisdictional element should result in dismissal of a petition for wri

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

tein"), by and through his undersigned counsel, hereby files his Memorandum of Law in Opposition to Defendant/Counter-Plaintiff Bradley Edwards's ("Edwards") legally and factually deficient Motion for Protective Order. In support thereof, Epstein states: INTRODUCTION On or about January 9, 2013, Edwar

ird, Edwards asserts that a protective order is warranted because the production requested "is unnecessarily intrusive into the financial privacy of BRADLEY EDWARDS'." See Exhibit B. However, because Edwards has put his financial status at issue by his assertion of damages, his Motion must be denied. When a party

e Ins. Co. v. Boecher, 733 So. 2d 993, 994 (Fla.1999) (noting the lack of "affidavits, depositions or other sworn testimony in the record to support Allstate's claims."). Here, Edwards fails to do so, and further fails to explain how these allegedly overbroad requests are intended to annoy, embarrass, op

, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN. Plaintiff, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF'S MOTION TO OUASH SUBPOENA AND FOR PROTECTIVE ORDER TO PREVENT DEPOSITION OF ALFRED SECKEL Plaintiff Jeffrey

commanding non-party Alfred Seckel to appear for deposition in Los Angeles, California on May 23, 2011 which subpoena Defendant Bradley J. Edwards ("Edwards") has noticed over the Plaintiffs objection. The grounds for this Motion are: I. On or about April 7, 2011, counsel to Edwards noticed the deposit

ith in the process and if the cost and expense are so great that access is basically denied to all but the few who can afford it. 13. Likewise, in Allstate, the Court had reasoned: - 3 - FOWLER WHITE BURNETT P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLF.R DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561

l state their appearances? 4 MR. HOROWITZ: Adam Horowitz, counsel for plaintiffs 5 Jane 2 through Jane Doe 7. 6 THE COURT: Good morning. 7 MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane 8 Doe. 9 THE COURT: Good morning. 10 MR. GARCIA: Good morning, Your Honor. Sid Garcia for 11 Jane Doe

heir appearances? 4 MR. HOROWITZ: Adam Horowitz, counsel for plaintiffs 5 Jane 2 through Jane Doe 7. 6 THE COURT: Good morning. 7 MR. EDWARDS: Brad Edwards, counsel for plaintiff Jane 8 Doe. 9 THE COURT: Good morning. 10 MR. GARCIA: Good morning, Your Honor. Sid Garcia for 11 Jane Doe II. 12 THE

.2d 153 (Fla. 4th DCA 1996); see, Menke' Broward School Bd, 916 So.2d 8 (Fla. 4111DCA 2005). The requirement of irreparable harm is jurisdictional. Allstate; Barad & Co. A petitioner's failure to demonstrate the satisfaction of this jurisdictional element should result in dismissal of a petition for wri

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) Testified at trial, 3/26/98 CA v. Robert Mark Edwards (Santa Ana, California) Testified at sentencing

motion hearing, 6/12/95 In the Matter of the Appeal by John Perry (Sacramento, California) Testified at administrative hearing, 6/29/95 Jerner v. Allstate (Orlando, Florida) Testified at evidentiary hearing, 9/1/95 EFTA00072971 Park Dietz, M.D., M.P.H., Ph.D. Page 26 Am. Natl. Fire Ins. Co. v. Bir