Epstein Secrets

c S. Nurik, Esq. Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale FL 33301 Phcine: Fax: Christopher E. Knight, Esq. Joseph L. Ackerman, Esq. Fovher White Burnett, PA. 777. S Flagler Drive, Suite 901 West Palm Beach FL 33401 Phone: Fax' 4 EFTA00722342

ENDANT, JEFFREY EPSTEIN Defendant/Counterplaintiff, Bradley J. Edwards ,by and through his undersigned counsel, recuests, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure, that PlIntifUColuiterdefendant, Jeffrey Epstein, produce and permit Bradley J. Edwards to inspect and copy each of the following documents*: 1.

rida this day of April, 2012. wED p,, 04 vo s ApR u Ar JUDGs ° 20I2 to HONORABLE DAVID F. CR( )w %it CIRCUIT JUDGE Copies furnished to: Joseph L. Ackerman, Jr., Esq. Fowler White Burnett, P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, FL 33401 Lilly Ann Sanchez, Esq. The L•S

ON TO COMPEL DISCOVERY RESPONSES AND FOR SANCTIONS Plaintiff Jeffrey Epstein, by and through his undersigned 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 Pro

oor Miami, Florida 33131 Telephone: (305) 379-9000 Facsimile: (305) 379-3428 E-Mail: [email protected] Ronald Neiwirth, Esq. (VIA EMAIL) Joseph L. Ackerman, Jr., Esq. Fowler White & Burnett, P.A. 777 S. Flagler Dr. ,Ste 901 W. Palm Beach, FL 334016170 Email: [email protected] meiwirthAfowler-whit

e this Court. Therefore, the requested documents are beyond the scope of permissible discovery. The requested materials are it t discoverable under the Florida Rules of Civil Procedure, the Federal Rules of Civil Procedure, the Bankruptcy Rules of Civil Procedure or any other possibly applicable system of rules. Moreover, the docu

August, 2011 to Jack Scarola, Esq., Searcy, Denney, Scarola, Barnhart & Shipley, E., 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409. 2.-O Joseph L. Ackerman, Jr. Fla. Bar No. 235954 WASOPOWROSFIlit-ATI chgnuattS. Asa FOWLER. WHITE BURNETT, Espirito Santo Plaza, Fourteenth Floor 1395 Brickell Avenue

ttr-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to §768.79 of the Florida Statutes and Rule 1.442 of the Florida Rules of Civil Procedure, hereby files this Motion requesting that the Court enter an Order of entitlement to costs and attorneys' fees against Defendant/Counter- Plaintiff

Proposal for Settlement I HEREBY CERTIFY that a true and correct copy of the foregoing Proposal for Settlement was served to Plaintiff's attorney, Joseph L. Ackerman, Esquire, by Email and U.S. Mail via Certified mail, return receipt requested, thi y of Augus 011. Jack Fl ca da cy 139 a No.: 169440 enn

is rejected, the Plaintiff, Jeffrey Epstein, is subject to sanctions, including, but not limited to, those as outlined in Rules 1.442(g) and (h) of the Florida Rules of Civil Procedure, Fla. Stat. 768.79 and any other relief Defendant/Counter-Plaintiff is entitled to as a matter of law and which the Court deems just and proper. 9

nts and Commentary to the Media and Press, and grant such other and further relief as is deemed necessary and proper. Respectfully submitted, By: Joseph L. Ackerman, Esq. Fla. Bar No. 235954 FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 - 9 - FOWLE

LEGAL AUTHORITIES Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.280(c) of the Florida Rules of Civil Procedure, files this Amended Motion for a Protective Order to Preclude Opposing Counsel and Defendant/Counter-Plaintiff From Making Extrajudicial Statements

nts and Commentary to the Media and Press, and grant such other and further relief as is deemed necessary and proper. Respectfully submitted, By: Joseph L. Ackerman, Esq. Fla. Bar No. 235954 FOWLER WHITE BURNETT P.A. 901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 and Christo

LEGAL AUTHORITIES Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.280(c) of the Florida Rules of Civil Procedure, files this Amended Motion for a Protective Order to Preclude Opposing Counsel and Defendant/Counter-Plaintiff From Making Extrajudicial Statements