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nder Acosta, Esq. USAO Barbara Burns, Esq. ASAO Bradley J. Edwards, Esq. William J. Berger, Esq. Robert D. Critton, Esq.
e provided an inaccurate description of another feature of the non- prosecution agreement to the victims. See Attachment 2 (Oct. 15, 2008 Letter from Brad Edwards, Esq. to AUSA Dexter Leo (noting Government's representation to victims of a right to recover at least $150,000 in damages from Jeffrey Epstein whil
, Esq. USAO Barbara Burns, Esq. ASAO Bradley J. Edwards, Esq. William J. Berger, Esq. Robert D. Critton
ON AGREEMENT AND ADDENDUM PENDING REVIEW Defendant, JEFFREY EPSTEIN ("EPSTEIN"), by and through his undersigned counsel and pursuant to Rule 9.310, Florida Rules of Appellate Procedure, moves to stay disclosure of the Non-Prosecution Agreement and Addendum (collectively, the "NPA") pending review, and states: 1. In the event the
st Palm Beach, FL 33401 William J. Berger, Esq. Bradley J. Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Bo
m Beach, Florida. Hon. Jeffrey Colbath CIRCUIT JUDGE cc: U.S. Attorney's Office State Attorney's Office Jack Alan Goldberger, Esq. Bradley 1. Edwards, Esq. Deanna K. Shullman, Esq. Spencer T. Kuvin, Esq. 2 EFTA00231170 KnEusixn-WALsit, COMPIANI & VARGAS, P.A. SUITE 5O3. FLAGLER CENTER 501
romised in the Crime Victims' Rights Act. DATED this 7th day oil& 2008. Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS & ASSOCIATES, LLC Brad Edwards, Esquire Attorney for Petitioner Florida Bar #542075 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: Facsimile: 8 emu, E
ON AGREEMENT AND ADDENDUM PENDING REVIEW Defendant, JEFFREY EPSTEIN ("EPSTEIN"), by and through his undersigned counsel and pursuant to Rule 9.310, Florida Rules of Appellate Procedure, moves to stay disclosure of the Non-Prosecution Agreement and Addendum (collectively, the "NPA") pending review, and states: 1. In the event the
nder Acosta, Esq. USAO Barbara Burns, Esq. ASAO Bradley J. Edwards, Esq. William J. Berger, Esq. Robert D. Critton. Esq.
sed in the Crime Victims' Rights Act. DATED this 7th day of July, 2008. Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS & ASSOCIATES, LLC Brad Edwards, Esquire Attorney for Petitioner Florida Bar if 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: Facsimile: 8 $0410 EFTA00
, Esq. USAO Barbara Burns, Esq. ASAO Bradley J. Edwards, Esq. William J. Berger, Esq. Robert D. Critton
ON AGREEMENT AND ADDENDUM PENDING REVIEW Defendant, JEFFREY EPSTEIN ("EPSTEIN"), by and through his undersigned counsel and pursuant to Rule 9.310, Florida Rules of Appellate Procedure, moves to stay disclosure of the Non-Prosecution Agreement and Addendum (collectively, the "NPA") pending review, and states: 1. In the event the
plaintiff/counter-defendant below, challenges the circuit court's Order entered March 8, 2018' by the Honorable Donald Hafele, granting Respondent Bradley J. Edwards' Motion for Separate Trials.'' By separate motion, Petitioner moves to consolidate this petition with his pending Emergency Petition for Writ of Man
admittedly running a $1.2 billion Ponzi scheme by convincing investors he had negotiated multi-million settlements in high-profile cases. Three of Edwards' clients at the time alleged tort claims against Epstein, which Epstein ultimately settled. Based on publicly available information about 3 All bac
original jurisdiction to issue writs of certiorari under Article V, section 4(b)(3) of the Florida Constitution, and under Rule 9.030(b)(3) of the Florida Rules of Appellate Procedure. Ordering bifurcation where claims are inextricably woven warrants certiorari relief. See, e.g., Maris Distrib. Co. v. Anheuser—Busch, Inc., 710 So
DISTRICT Appellate Case No.: LT Case No: 502009CA0408003OOOCMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants. EMERGENCY PETITION FOR WRIT OF MANDAMUS On Review of a Non-Final Order of the Circuit Court of the Fifteen
ocess d. (4) Fraud e. (5) Conspiracy to Commit Fraud (App. 1). On December 21, 2009, just 17 days after Epstein instituted the civil proceeding, Edwards filed a Counterclaim for abuse of process against Epstein. (App. 2). Thereafter, Edwards amended his Counterclaim several times, ultimately allegi
as original jurisdiction to issue writs of mandamus under Article V, section 4(b)(3) of the Florida Constitution, and under Rule 9.030(b)(3) of the Florida Rules of Appellate Procedure. Mandamus is "a proper vehicle to enforce the time restrictions for the setting of a trial under rule 1.440." Campbell v. Wells Fargo Bank, N.A., 2
as Blvd., Suite 1650, Fort Lauderdale, FL 33394; Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas B
uite 1650, Fort Lauderdale, FL 33394; Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las
ON AGREEMENT AND ADDENDUM PENDING REVIEW Defendant, JEFFREY EPSTEIN ("EPSTEIN"), by and through his undersigned counsel and pursuant to Rule 9.310, Florida Rules of Appellate Procedure, moves to stay disclosure of the Non-Prosecution Agreement and Addendum (collectively, the "NPA") pending review, and states: 1. In the event the
as Blvd., Suite 1650, Fort Lauderdale, FL 33394; Bradley J. Edwards, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas B
-3456 Telecopier (954) 527-8663 By: Bradley J. Edwards Florida Bar No. 542075 bcdwardsarra-law.com Wi
ON AGREEMENT AND ADDENDUM PENDING REVIEW Defendant, JEFFREY EPSTEIN ("EPSTEIN"), by and through his undersigned counsel and pursuant to Rule 9.310, Florida Rules of Appellate Procedure, moves to stay disclosure of the Non-Prosecution Agreement and Addendum (collectively, the "NPA") pending review, and states: 1. In the event the
Entities connected to both Bradley Edwards and Florida Rules of Appellate Procedure

Jeffrey Epstein
PERSONJane Doe
PERSON
Paul Cassell
PERSONJack Goldberger
PERSON
Kenneth Marra
PERSON
Alan Dershowitz
PERSONScott Rothstein
PERSON
George W. Bush
PERSONJack Scarola
PERSON
United States
LOCATIONRobert D. Critton
PERSON
Scarlett Johansson
PERSONthe Southern District
LOCATION
Donald Trump
PERSONMichael J. Pike
PERSON
Alexander Acosta
PERSONSpencer Kuvin
PERSONBruce E. Reinhart
PERSONAtterbury Goldberger & Weiss
ORGANIZATION
Palm Beach County
LOCATION