Epstein Secrets

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 THE COURT: We are here on Epstein versus Rothstein and Edwards. The two applicable parties being dealt with -- have a seat, please. Thank you. -- being Mr. Epstein and Mr. Edwards, and the counterclaim brough

Mr. Edwards. THE COURT: Did he bring it against Rothstein's firm? I only have Rothstein individually -- MR. SCAROLA: Rothstein, individually and Bradley Edwards, individually. MR. LINK: My apologies. THE COURT: That statement is retracked. It's Rothstein individually and Edwards, individually. Mr. Scarola

file claims that were false. We are not taking about malice yet. Independent of any evidence that relates to malice, we get to prove the truth of Brad Edwards' underlying claims on behalf of L.M., E.W. and Jane Doe. So that then brings us -- THE COURT: I think I have already essentially ruled on that from

oof with regard to every element. It is also our position that the issue as to whether the underlying claim was bona fiably terminated in favor of Bradley Edwards is an issue of law for the Court. There are no disputed -- Mr. Edwards is present, yes. There are no disputed issues of fact with regard to what

tion case, read questions to the jury that my client took the Fifth Amendment to and draw a negative inference therefrom. The US Supreme Court in Baxter -- that's the case -- that's the Fifth Amendment case -- it says, "It's key that there's independent evidence existing of the fact to which the pa

FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FL JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No. 50 2009 CA 040800XXXXMBAG v. BRADLEY J. EDWARDS, et al., Defendants/Counter-Plaintiff. JUDGE: HAFELE JEFFREY EPSTEIN'S RESPONSE TO BRADLEY EDWARDS'S MOTION IN LIMINE TO STRIKE THE JUNE 30.2017

ion for Summary Judgment, and to "exclude evidence as to which discovery was withheld under claims of privilege." As demonstrated more fully below, Edwards's Motion is deficient on its face, and in direct contravention to the facts. As such, Edwards's Motion should be denied. INTRODUCTION Epstein file

that there were other media, local media. I've been told that the -- his investigator was sent to California to harass people representing his -- Brad Edwards' investigator -- representing fictitiously, fraudulently that he was a FBI agent to try to gather information for Mr. Edwards' claims. See Depositi

sitting over their computer looking at their bank accounts. So, unfortunately, I would have to say, no, sir. Q. Have you ever personally witnessed Bradley Edwards engaged in money laundering? MR. PIKE: Form. THE WITNESS: Again, sir, the U.S. Attorney's Complaint of the Rothstein firm alleges money laundering

(1st Cir. 2003); Baxter v. Pabnigiano, 425 U.S. 308 (1976). See also Doe ex rel. Rudy-Glanzer v. Glanzer, 232 F.3d 1258, 1264 (9th Cir. 2000) ("The Baxter holding is not a blanket rule that allows adverse inferences to be drawn from invocations of the privilege against self-incrimination under all cir

n bond to secure any potential judgment that Jane Doe might obtain in this case. DATED this 19th day of June, 2009. 19 Respectfully Submitted, s/ Bradley J. Edwards Bradley J. Edwards ROTHSTEIN ROSENFELDT ADLER Las Olas City Centre 401 East Las Olas Blvd., Suite 1650 Fort Lauderdale, Florida 33301 Telephone

enue Suite 340 Coconut Grove, Florida 33133 [email protected] By: Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS & AS SOCIA TES, LLC Brad Edwards, Esquire Attorney for Plaintiff Florida Bar No. 542075 2028 Harrison Street Suite 202 Hollywood, Florida 33020 Telephone: 954-414-8033 Facsim

e Lewis Tein, P.L. 3059 Grand A venue Suite 340 Coconut Grove, Florida 33133 [email protected] By: Respectfully Submitted, THE LAW OFFICE OF BRAD EDWARDS & AS SOCIA TES, LLC Brad Edwards, Esquire Attorney for Plaintiff Florida Bar No. 542075 2028 Harrison Street Suite 202 Hollywood, Florida 33020 T

e to permit an adverse inference to be drawn from exercise of the privilege does not implicate the policy considerations underlying the privilege." Baxter v. Palmigiano, 425 U.S.308, 335 (1976). An adverse inference is entirely justified in this case. Epstein has remained silent when asked such strai

Farmer, Jaffe, Weissing, Edwards, Fistos £t Lehrman, P.L. 'Ovid Pam ftoisl pet WWW.PATITTOJUSTKE.COM 425 North Andrews Avenue • Suite 2 Fort Lauderdale, Florida 33301 4 00 "ti

porting exhibit 30 be filed in the public file and docketed as of today's date, as timely filed. DATED: January 21, 2015. Respectfully Submitted, Bradley J. Edwards FARMER, JAFFE, WEISSING, EDWARDS, FISTOS & LEHRMAN, P.L. 425 North Andrews Avenue, Suite 2 Fort Lauderdale, Florida 33301 Telephone (954) 524-28

o sleazy, unprofessional, disbarrable lawyers, Paul Cassell, a former federal judge [and] current professor, and another sleazy lawyer from Florida, Brad Edwards — . .. and said who would fit into this description: A lawyer, who knows Epstein, who helped draft ...? Ha, Dershowitz! So they and the woman got t

is . . . evidence of the most persuasive character." United States ex rd. Biloktanskyl. Tod. 263 U.S. 149, 153-54 (1923) (Brandeis, J.), quoted in Baxter". Pahnigiano, 425 U.S 308, 319 (1976). And that silence takes on an even more sinister cast when combined with the fact that Epstein's sexual intere

ion Motion Page 23 of24 Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Brad Edwards, Esq. Adam D. Horowitz, Esq. Rothstein Rosenfeldt Adler Mermelstein & Horowitz, P.A. 401 East Las Olas Boulevard 18205 Biscayne Boulevard Suite

st to a defendant of treating his claim of privilege as an admission would be to excuse a plaintiff of presenting proof of his claim; "[ w ]e think Baxter indicates that this is too great a cost"). As Jane Doe fails to present any independent evidence of fraudulent transfer, the Court must deny her re

ge without requiring the complainant to produce evidence in support of its allegations would impose too great a cost and exceed the authorization of Baxter [v. Palmigiano, 425 U.S. 308 (1976)]." See LaSalle Bank Lake View, 54 F.3d at 391; see also National Acceptance v. Bathalter, 705 F.2d 924, 931-32

on Motion Page 23 of 24 Certificate of Service Jane Doe No. 2 v. Jeffrey Epstein Case No. 08-CV-80119-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Brad Edwards, Esq. Adam D. Horowitz, Esq. Rothstein Rosenfeldt Adler Mermelstein & Horowitz, P.A. Counsel for Plaintiff in Related Case No. 08-80893 ounse o

-MARRA/JOHNSON Stuart S. Mermelstein, Esq. Brad Edwards, Esq. Adam D. Horowitz, Esq. Rothstein Rosenfel

ge without requiring the complainant to produce evidence in support of its allegations would impose too great a cost and exceed the authorization of Baxter v. Palmigiano, 425 U.S. 308 (1976)]." See LaSalle Bank Lake View, 54 F.3d at 391; see also National Acceptance v. Bathalter, 705 F.2d 924, 931-32 (

TRUE 680, LLC KING,GIOCONDA ST EDWARDS RECTORY BELL JR,LOWRY M 375 SOUTH C

WILLIAM AND MARCIA RICKMAN REVOCABLE TRUST BAXTER,LAURA RUKEYSER,SUSAN C MIKUS,WILLIA

to Amended to Assert Punitive Damages; Exhibit “E” — Transcript of Deposition of Jeffrey Epstein dated January 25, 2012; Exhibit “F’ — Deposition of Bradley Edwards dated March 23, 2010; Exhibit “G” - Deposition of Scott Rothstein dated June 14, 2012; Exhibit “H” — Order of HOUSE_OVERSIGHT_013305 --- PAGE BREAK

s not forbid adverse inferences against parties to civil actions when they refuse to testify in response to probative evidence offered against them.” Baxter v. Palmigiano, 425 U.S. 308, 318 (1976); Accord, Vasquez v. State, 777 So. 2d 1200, 1203 (Fla. at 2001). The reason for this rule “is both logical an

dwards Affidavit”) (Exhibit 32. On June 13, 2008, attorney Edwards agreed to represent E.W.; on July 2, 2008, tomes

or touching her vagina, inserting his fingers and civil actions when they refuse to testify in response to probative evidence offered against them.” Baxter v. Palmigiano, 425 U.S. 308, 318 (1976); accord Vasquez v. State, 777 So.2d 1200, 1203 (Fla. App. 2001). The reason for this rule “is both logical an

a discussions and the right to confer with prosecutors about any plea arrangement). See 14 HOUSE_OVERSIGHT_010579 --- PAGE BREAK --- Affidavit of Bradley J. Edwards, Esq. at {1 - 2, §4 (hereinafter “Edwards Affidavit”) (Exhibit 32. On June 13, 2008, attorney Edwards agreed to represent E.W.; on July 2, 2008, attorney E

dwards Affidavit”) (Exhibit 32. On June 13, 2008, attorney Edwards agreed to represent E.W.; on July 2, 2008, attorn

e and punish Epstein for his crimes against them in whatever avenue remained open to them. On August 12, 2008, at the request of his client Jane Doe, Brad Edwards filed a civil suit against Jeffrey Epstein to recover damages for his sexual assault of Jane Doe. See Edwards Affidavit, “N” at 7. Included in this c

m engaging in what was a blatant effort to extort Bradley Edwards, utilizing the nearly limitless resources of a ven

s not forbid adverse inferences against parties to civil actions when they refuse to testify in response to probative evidence offered against them." Baxter v. Palmigiano, 425 U.S. 308, 318 (1976); accord Vasquez v. State, 777 So.2d 1200, 1203 (Fla. App. 2001). The reason for this rule "is both logical an