Epstein Secrets

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, Plaintiff(s), vs. ALAN M. DERSHOWITZ, Defendant(s). PROPOSAL FOR SETTLEMENT PURSUANT TO RULE 1.442, FLORIDA RULES OF CIVIL PROCEDURE AND $768

: CACE 15-000072 BRADLEY J. EDWARDS and PAUL G. CASSELL, Plaintiff(s), vs. ALAN M. DERSHOWITZ, Defend

ent this proposal is rejected, the Defendant 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 Plaintiff is entitled to as a matter of law and which the Court deems just and proper. 11. GOOD-FAITH: Thi

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, Plaintiff, vs. ALAN M. DERSHOWITZ, Defendant, PROPOSAL FOR SETTLEMENT PURSUANT TO RULE 1.442, FLORIDA RULES OF CIVIL PROCEDURE AND V68.79, FL

of 5 3. CLAIMS THE PROPOSAL ATTEMPTS TO RESOLVE: All damages that would otherwise be awarded in a Final Judgment in this action between Plaintiff Cassell and Defendant including both Plaintiff Cassell's claim against the Defendant and Defendant's counterclaim against Plaintiff Cassell. 4. TOTAL AMO

ent this proposal is rejected, the Defendant 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 Plaintiff is entitled to as a matter of law and which the Court deems just and proper. 11. GOOD-FAITH: Thi

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, Defendants. PLAINTIFFS' REOUEST FOR PRODUCTION TO DEFENDANT (PUNITIVE DAMAGES) BRADLEY J. EDWARDS and PAU

ies, desk calendar entries, reported recollections and other written form of EFTA00602638 Edwards, Bradley vs. Dershowitz Plaintiffs, Edwards and Cassell, Request to Produce to Def. (Punitive Damages) Case No.: CACE 15-000072 Page 2 notation of events or intentions, transcripts and recordings of con

uments and things described below for the purpose of inspection, copying, photographing, testing or sampling and any other purposes permitted under the Florida Rules of Civil Procedure at the office of the undersigned within thirty (30) days of service of this request. DEFINITIONS AND INSTRUCTIONS: A. The term "documents" as use

tions and responses to the "Net Worth Interrogatories" ("Interrogatories") propounded by Plaintiffs / Counterclaim Defendants Bradley J. Edwards and Paul G. Cassell ("Plaintiffs"). PRELIMINARY STATEMENT These responses and objections reflect the current state of Defendant's knowledge regarding the matters dis

erclaim Defendants Bradley J. Edwards and Paul G. Cassell ("Plaintiffs"). PRELIMINARY STATEMENT These re

damages. Defendant further objects because the Interrogatories and subparts served by Plaintiffs exceed the limitations contained in Rule 1.340 of the Florida Rules of Civil Procedure. There has been no application for leave of Court to exceed the cap imposed by Rule 1.340. By responding to 2 EFTA00604950 this Interrogatory, D

IN THE CIRCUIT COURT FOR THE SEVENTEENTH JUDICIAL CIRCUIT, IN AND FOR BROWARD COUNTY, FLORIDA BRADLEY J. EDWARDS and PAUL G. CASSELL, CASE NO.: 15-000072 Plaintiff(s), JUDGE: LYNCH v. ALAN M. DERSHOWITZ, Defendant. I MOTION FOR RECONSIDERATION OF THIS COURT'S ORDER DENYING

COUNTY, FLORIDA BRADLEY J. EDWARDS and PAUL G. CASSELL, CASE NO.: 15-000072 Plaintiff(s), JUDGE: LYN

SUBPOENA Jeffrey Epstein (hereinafter "Epstein"), a non-party to this action, by and through his undersigned counsel and pursuant to Rule 1.530 of the Florida Rules of Civil Procedure, hereby moves this Court for Reconsideration regarding its not yet final ruling' denying Epstein's Motion to Quash the Subpoena Duces Tecum issued