Epstein Secrets

gned counsel and pursuant to Rule 1.380 of the Florida Rules of Civil Procedure, hereby moves this Court to enter an order compelling the Defendant Bradley Edwards, yet again, to provide responses to Plaintiff's Request for Production. Plaintiff likewise requests that this Court order sanctions against Defenda

» that > some >> of the items to which you are objecting, for example, are electronic >> communications to/from government entities which, as Mr. Edwards is >> likely aware from his days as a government attorney, are legally a >> matter of > public >> record, will not, in fact, be privileged under

ward Blvd., Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. Fernier, Jaffe, Weissing, Edwards, Fistos & Lehr

enue, Suite 2 Fort-Lauderdale; FL 33301 EFTA00208204 Case 9:08-cv-80736-KAM Document 177-1 Entered on FLSD Docket 06/06/2012 Page 21 of 22 TO A HADDAD, PA nurc Lanaoraate, 33304 May itt; 204 Via:W andtectbmiellail Itik " Searcy enney;etia West Palm gad; 33.40 Re: EnorpziN &Wyk aid peat M

PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800SSSSMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, vs. SCOTT ROTHSTEIN, INDIVIDUALLY and BRADLEY J. EDWARDS, INDIVIDUALLY, Defendants/Counter-Plaintiffs. / PROCEEDINGS HELD BEFORE JUDGE DONALD HAFELE Epstein's Motion for Fees and Costs HELD: Decembe

p?-4.* EFTA00617909 4 4 5 6 7 8 9 10 11 12 13 14 15 16 materials here from you and I've got the response in opposition filed by Mr. Edwards as well. MR. BREWER: As your Honor might remember, you entered a summary judgment THE COURT: Right. I remember the facts. I presume it's on appea

de it absolutely unethical _ ..pgam BEACH REPOR.T1NG SERVICE, INC. _561-471-2995 EFTA00617920 15 3 4 6 8 9 10 11 12 13 14 15 16 for Brad Edwards to have accepted this proposal for settlement. That requires an evidentiary basis, and I am prepared to give testimony with regard to that aspect.

al amount. I reject it also because of the presence of the Etchaverria case and the other case that involves the law firm that slips my mind. MS. HADDAD: Levin. THE COURT: The Levin case. So there was language principally used in the Wolfe case -- that's the underlying case that you primarily reli

UIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXX MB AG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant(s). / PROCEEDINGS HELD BEFORE JUDGE DONALD HAFELE PLAINTIFF'S MOTION TO SET CASE FOR TRIAL H

21 22 23 24 25 the 23rd -- MR. SCAROLA: I'll have somebody else cover for me, sir. I don't want this matter delayed being set for trial. Mr. Edwards is co-counsel with me in this matter, and he will be here if I'm not available. I have offered those alternatives to the other side, and I am just

ON BEHALF OF THE PLAINTIFF(S): SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. By: JACK SCAROLA, ESQUIRE ON BEHALF OF THE DEFENDANT(S): TiN A HADDAD P A By: TONYA HADDAD COLEMAN, ESQUIRE Palm Beach Reporting Service, Inc. EFTA00610184 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408

) of the Florida Rules of Civil Procedure, hereby moves this Court for entry of an order directing Defendant/Counter-Plaintiff Bradley J. Edwards ("Edwards") to respond to questions asked of him at his deposition taken on March 23, 2010, and again on May 15, 2013, and to such follow up questions as are

put you in a position where you would not have been able to, nor would you have proceeded with questions today. Id. at page 100; lines 20-23. MR. HADDAD: We wouldn't even — no, as long as it's pending before the Court, I saw no purpose in having to reestablish that you were objecting. Id. at page 100

ACH COUNTY, FLORIDA Case Pa. 502009CAO40B00/COM 1 4 THE COURT: Announce your appearances for the Court, MR. SCAROLA: Jack Scarola on behalf of Bradley Edwards, Your Honor. 3 JEFFREY EPSTEIN, MR. BREWER: Chester Brewer on behalf Plaintiff, of Jeffrey Epstein. SCOTT ROTHSTEIN, individbally, BRADLEY SWA

MR. SCAROLA: Jack Scarola on behalf of Bradley Edwards, Your Honor. 3 JEFFREY EPSTEIN, MR. BREWER: Ch

Y EPSTEIN, MR. BREWER: Chester Brewer on behalf Plaintiff, of Jeffrey Epstein. SCOTT ROTHSTEIN, individbally, BRADLEY SWARDS, individually, MS. HADDAD: Tonya Haddad on behalf of Jeffrey Epstein. Defendente/Covnter-Plaintlffe. I'm sorry. / 10 THE COURT: That's okay. You have a TRANSCRIPT OF PR

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408

) of the Florida Rules of Civil Procedure, hereby moves this Court for entry of an order directing Defendant/Counter-Plaintiff Bradley J. Edwards ("Edwards") to respond to questions asked of him at his deposition taken on March 23, 2010, and again on May 15, 2013, and to such follow up questions as are

put you in a position where you would not have been able to, nor would you have proceeded with questions today. Id. at page 100; lines 20-23. MR. HADDAD: We wouldn't even — no, as long as it's pending before the Court, I saw no purpose in having to reestablish that you were objecting. Id. at page 100

nt. Here is an agenda for the conference: 1. Motion to Compel re: Deposition Questions a. if we are moving to exclude certain things and/or prevent Edwards from using them I do not want to compel discovery from him on it; and b. Attorney/client privilege argument 2. Trial Exhibit and Witness list from

Counsel Defense and Discovery EFTA00384930 5. Can we disqualify Scarola (as per Darren and Jeffrey's request). Tonja Haddad Coleman, Esq. TONY% HADDAD, P.A. Advocate Building 315 SE 7th Street Fort Lauderdale, FL 33301 acsimile The information contained in this transmission may contain privileg