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ALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF
ce Pursuant to Florida Statutes Section 90.202 and 90.203 dated December 4, 2017 [D.E. 1104] filed by DefendanUCounter-Plaintiff, Bradley Edwards ("Edwards"). BACKGROUND In support of his malicious prosecution Counterclaim, Edwards has identified as witnesses multiple women who filed civil tort claims
ds did not represent is absolutely improper, as such evidence has no bearing on the malicious prosecution Counterclaim and is unfairly prejudicial. Honeywell Intern., Inc. v. Guilder, 23 So. 3d 867 (Fla. 3nd DCA 2009); Long Tenn Care Found., Inc. v. Martin, 778 So. 2d 1100, 1102-03 (Fla. 5th DCA 2001) (allegati
FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, JUDGE: DAVID CROW VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, MOTION IN LIMINE TO PRECLUDE AT TRIAL THE USE OF THE FOLLOWING ITEMS LISTED ON EDWARDS'S REVISED EXHI
y, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, MOTION IN LIMINE TO PRECLUDE AT TRIAL THE USE OF THE FOLLOWING ITEMS LISTED ON EDWARDS'S REVISED EXHIBIT LIST Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel moves for an Order in Limine
is germane to the issues in this case, any mention of or use of information from any other case is not. Such information is unfairly prejudicial. Honeywell Intern., Inc. v. Guilder, 23 So. 3d 867 (Fla. 3d DCA 2009). As seen from Edwards's trial exhibit list items above, it is apparent that he intends to use as
e commentary from Edwards, his counsel, or his witnesses, is impermissible. Any Reference to any Cases Against Epstein Which were not Prosecuted by Bradley J. Edwards. While it foreseeable that a limited amount of the information regarding Edwards's prosecution of the three cases against Epstein could potentially
Australian Ave. South, Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. 1 East Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Bradle . Edwards E . armer a e eissing wards Fistos Lehrman 425 N Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 1 Financial Plaza, Suite 2612 Fort Laude
DCA 2009). Moreover, any mention of or use of information from any other case is absolutely improper, as such information is unfairly prejudicial. Honeywell Intern., Inc. v. Guilder, 23 So. 3d 867 (Fla. 3d DCA 2009); Long Term Care Found., Inc. v. Martin, 778 So. 2d 1100, 1102-03 (Fla. 5th DCA 2001) (allegatio
Entities connected to both Bradley Edwards and Honeywell Intern

Jeffrey Epstein
PERSONJane Doe
PERSONJack Goldberger
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
Alfredo Rodriguez
PERSON
Jean-Luc Brunel
PERSONTonja Haddad Coleman
PERSON
Barry Diller
PERSONLarry Visoski
PERSON
Samantha Power
PERSON
Michael Reiter
PERSON
Paul Ryan
PERSONSearcy Denney Scarola
PERSONJoe Recarey
PERSON
Barry Krischer
PERSON
Juan Alessi
PERSONMarc Nurik
PERSONWright
PERSON