IAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, Vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, / DEFENDANT/COUNTER-PLAINTIFF’S RESPONSE IN OPPOSITION TO PLAINTIFF/COUNTER-DEFENDANT’S M

non-privileged documents currently in his possession, custody or control. 20. Copies of any and all documents tending to support your assertion that Bradley J. Edwards: a. has a reputation of being sleazy; b. has acted in a sleazy manner; c. has engaged in unethical conduct; d. has knowingly relied upon

015546 --- PAGE BREAK --- Bradley J. Edwards STATE OF FLORIDA COUNTY OF Waa d ) BEFORE ME, the undersigned authority, personally appeared this day Bradley J. Edwards, who is personally known to me or ([_] _ produced , aS identification, and who, after being duly sworn, did state that he/she executed the fo

ein, Case No. 502008CA028058XXXXMB AB), (hereinafter "civil actions"). 3. In each of these civil actions, each of the Plaintiffs is represented by Bradley J. Edwards, William Berger and the RRA law firm, 1109 NE 2d Street, Hallendale Beach, Florida 33009-8515. Attorneys Russell Alder and Peter Feaman hav

s" (Oct. 13, 2020), https://www.nydailynews.corn/new-york/ny-jeffrey-epstein-maxwell-case- 20201013-jmzhl7zdrzdgrbbs7yc6bfnszu-story.html ; see also Bradley J. Edwards, Relentless Pursuit: My Fight for the Victims of.lqffrey Epstein, at 281. b. This request also includes all communications and documents r

in sent a Requett to Produce to Edwards requesting the following documents: 3. All eanAils, data, coirespondenc memos, or singly documents between Bradley J. •Edttaids, Seat W. Re William Elexgesx Aclicr anchor any &folio or itiutietitatitte ofgRA. ga anyn— mita:SW 61911O TI(tty (person or entity) rega

e our "summary judgment" pleadings (which we provided in their entirety to your Office as a courtesy six months ago) on March 18, 2011. Sincerely, Bradley J. dwards Paul . Cassell Co-Counsel for Jane Doe #1 and Jane Doe #2 Cc: Miami FBI He Ice The views expressed in this letter are solely those of it

d through his undersigned counsel, requests, pursuant to Rule 1.3 0 of the Florida Rules of Civil Procedure, that Jeffrey Epstein produce and permit Bradley J. NI/ Ed ards to inspect and copy each of the following documents*: 1. All contracts for legal services rendered in defense of the criminal charges

d through his undersigned counsel, requests, pursuant to Rule 1.3 0 of the Florida Rules of Civil Procedure, that Jeffrey Epstein produce and permit Bradley J. NI/ Ed ards to inspect and copy each of the following documents*: 1. All contracts for legal services rendered in defense of the criminal charges

e: December 31 2014 at 9:37:37 AM EST To: Richard Joslin Cc: Eileen Alexanderso Wechsler Subject: Audit of Ben's 2012 Gift Tax Return Hi Rich, "Bradley J. After you told me yesterday that Ben's 2012 gi=t tax return was being audited I spoke briefly to Alan. He mentioned=that you forwarded to him sever

Cohen Sent: Monday, August 21, 2017 12:12 PM To: ; John Cook >; Wimer, Ruth Cc: Joe Avantario Wechsler Richard Joslin < =>; John Castrucci • Bradley J. >; Joseph Vinciguerra &I<=r> Subject: FW: Plane Straw Man PRIVILEGED AND CONFIDENTIAL<=p> Attached is a proposed straw man structure for ownin= and

mmary Judgment" pleadings (which we provided in their entirety to your Office as a courtesy six months ago) on March 18, 2011. Sincerely, s it74, Bradley J. dwards ?c' Paul . Cassell Co-Counsel for Jane Doe #1 and Jane Doe #2 Cc: Special Agent in Charge John V. Gillies Miami FBI Field Office 16320