Epstein Secrets

cum for Deposition, dated November 5, 2009, upon Bradley J. Edwards, Esq.; Rothstein Rosenfeldt Adler, PA; Stuart Rosenfel

1 561-582-7600 Fax: 561-588-8819 Counsel for Plaintiff in Related Case No. 08-80811 [email protected] Jack Scarola, Esq. Jack P. Hill, Esq. Brad Edwards, Esq. Rothstein Rosenfeldt Adler 401 East Las Olas Boulevard Suite 1650 Fort Lauderdale, FL 33301 Phone: 954-522-3456 Fax: 954-527-8663 bedwar

which were entered into by an investor relating to any plaintiff's case with Jeffrey Epstein and any of the following: a. Scott W. Rothstein b. Bradley J. Edwards C. RRA e. any entity formed by RRA or Bradley J. Edwards or Scott W. Rothstein to create investment opportunities for third party investors to inv

and proper. Rule 7 .1 A. 3. Certification of Pre-Filing Conference Counsel for Defendant in good faith conferred with Plaintiff's counsel, Bradley Edwards, by telephone and Mr. Edwards does not oppose the entry of an order. Counsel for Defendant wrote and enclosed copies of this motion and proposed ag

ll Coffey, Esq., counsel for Stuart A. Rosenfeldt, individually, and Rothstein Rosenfeldt Adler, P.A., Coffey Burlington 2699 South Bayshore Drive, Penthouse, Miami, Florida 33133, and Paul Singerman, Esq., counsel for Herbert Case 9:08-cv-80119-KAM Document 405 Entered on FLSD Docket 11/12/2009 P

-Filed 11/23/2015 05:53:31 PM IN THE CIRCUIT COURT OF THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA CASE NO.: CACE 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs, vs. ALAN M. DERSHOWITZ, Defendant. / PLAINTIFFS/COUNTERCLAIM DEFENDANT EDWARDS AND CASSELL’S RESPONSE TO DERSHOWI

ASE NO.: CACE 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiffs, vs. ALAN M. DERSHOWITZ, Defendant. / PLAINTIFFS/COUNTERCLAIM DEFENDANT EDWARDS AND CASSELL’S RESPONSE TO DERSHOWITZ’S MOTION TO DETERMINE CONFIDENTIALITY OF COURT RECORDS Plaintiffs/Counterclaim Defendants Bradley J. Edwards an

ous adult when she flew on that airplane. Q. You were asked on the occasion of that same Don Lemon CNN interview what possible motive the attorneys, Brad Edwards and Paul Cassell, could have had to have identified you in the pleading that was filed in the Crime Victim's Rights Act case. _ warn nw be wn Bb N

a young woman. MR. SCOTT: Objection. You're cutting the witness off. You're not letting him finish. A. This looks like a picture out of a Playboy or Penthouse magazine. It does not look to me like a person who is under the age of 16 or 17 or 18. But I don't think you can tell anything from the picture. I th

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

xhibits as referenced/used in the Deposition of Scott W. Rothstein taken by Epstein on June 14, 2012. 6. Privilege Log of Farmer, Jaffe, Weissing, Edwards, Fistos & Lehrman, Dated February 23, 2011 as filed in this matter and in In re: Rothstein Rosenfeldt Adler, P.A.; 09-34791 -RBR. 7. Docket from

time 53. Frank Preve Banyon Funding, LLC 2455 E. Sunrise Blvd., Penthouse Suite 54. Kendall Coffey Coffey Burlington PL 2699 S. Bayshore Dr., Penthouse Miami, FL 33133-5408 55. Seth Lehrman Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-326

00 Fort Lauderdale, FL 33301 [email protected] Bradley J. Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman 42

A 201 S Biscayne Blvd., Suite 1300 Miami, FL 33131-4311 47. Any and all witnesses listed by Bradley J. Edwards, depending on their testimony in Edwards's Case in Chief. POSSIBLE REBUTTAL WITNESSES I. Adam Horowitz Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N. Andrews Avenue, Suite 2 Fort

ald Wise Address unknown at this time 27. Wayne Black Address unknown at this time 28. Frank Preve Banyon Funding, LLC 2455 E. Sunrise Blvd., Penthouse Fort Lauderdale, FL 33304 29. Seth Lehrman Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 3330

Petrini, LLP 1320 Columbia Street, Suite 210 San Diego, California 92101-3436 He is expected to testify as to the lack of damages suffered by Mr. Edwards. 5. Mercedes Estrada Address unknown at this time As an employee of RRA mentioned in various documents, she is expected to testify regarding "Ep

ing the Ponzi scheme, the use of the "Epstein Cases" to defraud investors in the furtherance thereof while they were being prosecuted by RRA. 41. Bradley J. Edwards Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301-3268 He is expected to testify regarding hi

Cases" while they were being prosecuted by RRA, and his work on the "Epstein Cases". 28. Frank Preve Banyon Funding, LLC 2455 E. Sunrise Blvd., Penthouse Fort Lauderdale, FL 33304 As an investor in the Ponzi scheme, he is expected to testify regarding the Ponzi scheme, and the use of the "Epstein Ca

00 Fort Lauderdale, FL 33301 [email protected] Bradley J. Edwards, Esq. Farmer Jaffe Weissing Edwards Fistos Lehrman 42

A 201 S Biscayne Blvd., Suite 1300 Miami, FL 33131-4311 48. Any and all witnesses listed by Bradley J. Edwards, depending on their testimony in Edwards's Case in Chief. POSSIBLE REBUTTAL WITNESSES I. Adam Horowitz Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N. Andrews Avenue, Suite 2 Fort

ald Wise Address unknown at this time 28. Wayne Black Address unknown at this time 29. Frank Preve Banyon Funding, LLC 2455 E. Sunrise Blvd., Penthouse Fort Lauderdale, FL 33304 30. Seth Lehrman Farmer Jaffe Weissing Edwards Fistos Lehrman 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 3330

onstitutional basis for precluding trial of criminal case by injunction. Melvin L. Klafter, Leonard R. Harten- feld, Chicago, Ill., for appellant. Edward,. Hanrahan, U. S. Atty., John Peter Lulinski, Thomas W. James, Asst. U. S. Attys., Chicago, Ill., William W. Goodrich, Asst. Gen. Counsel, Joanne

ct Court for the Northern District of Georgia Before TJOFLAT and HENDERSON, Circuit Judges, and LYNNE', District Judge. TJOFLAT, Circuit Judge: Penthouse brought this suit to enjoin the Solicitor General of Fulton County, Geor- gia, Hinson McAuliffe, from prosecuting or threatening to prosecute under

ter is five months pregnant. And you thought John Edwards was in trouble before. Now he’ s rea//y done it.

me subjectively. For a manufacturer of novelty items, | was simply a disembodied inspiration for the marketing of “Presidential Kneepads.” And _ for Penthouse magazine, | would only be considered their next notorious masturbation enhancer. In the eyes of the media—from NBC News to MWghtline, from TIME maga

attorneys against him in Broward County Circuit Court for defamation of them. Moreover, the law cited by Prof. Dershowitz, including the Sackman and Penthouse cases, demonstrates a need and entitlement to intervene to vindicate his legitimate reputational interest that no other party is situated to protect.

y Epstein (Jeffrey Epstein v. Scott Rothstein and Bradley J. Edwards, lawsuit (Case no. 502009-CA- 040800)) in Palm Bea