N PROGRAM COME NOW the Co-Executors of the Estate of Jeffrey E. Epstein (the "Estate"), DARREN K. INDYKE AND RICHARD D. KAHN, and request that this Honorable Court rule on the Expedited Motion for Establishment of a Voluntary Claims Resolution Program ("Expedited Motion") filed on November 14, 2019. The ground

A, Defendant INTERVENOR EPSTEIN'S UNOPPOSED MOTION FOR A SUPPLEMENTAL PROTECTIVE ORDER Now comes Intervenor, Jeffrey Epstein, who moves that this Honorable Court issue a supplemental Protective Order that would expand the limited Protective Order allowed in its decision Granting in Part and Denying in Part t

Defendant(s). MOTION TO STRIKE UNTIMELY OBJECTIONS TO FINANCIAL DISCOVERY BRADLEY J. EDWARDS, by and through his undersigned counsel, moves this Honorable Court to strike all objections to the financial discovery propounded by him to JEFFREY EPSTEIN, with the exception of objections based on EPSTEIN'S assert

A, Defendant INTERVENOR EPSTEIN'S UNOPPOSED MOTION FOR A SUPPLEMENTAL PROTECTIVE ORDER Now comes Intervenor, Jeffrey Epstein, who moves that this Honorable Court issue a supplemental Protective Order that would expand the limited Protective Order allowed in its decision Granting in Part and Denying in Part t

osition duces tecum of the Rocords Custodian of The New York Daily News. WHEREFORE, Defendant, Bradley J. Edwards, respectfully requests that this Honorable Court grant his Motion to Appoint Commissioner. EFTA00725960 - 1. 07/18/2018 .14:22 FAS 5016840816 SEARCY PENNEY WM/use) CERTICATE OF $ERVICE I HER

dually, and L.M., individually, Defendant(s). MOTION TO SET CASE FOR TRIAL Bradley J. Edwards, by and through his undersigned counsel, moves this Honorable Court to set the above-styled cause for trial by jury. This long delayed matter is now ripe for resolution and is expected to take approximately 10 days

osition duces tecum of the Rocords Custodian of The New York Daily News. WHEREFORE, Defendant, Bradley J. Edwards, respectfully requests that this Honorable Court grant his Motion to Appoint Commissioner. EFTA00596573 - 1. 07/19/2010 A4:22 FAX 5616848816 SEARCY VENNhY CERTICATE OF $ERVICE ! I HEREBY CER

ndant more than 20 days before the hearing on this motion regarding the Punitive Damages amendment. WHEREFORE, Plaintiff respectfully requests this Honorable Court enter an Order allowing Plaintiff to file a Second Amended Complaint, adding a RICO count and to allow Plaintiff to seek Punitive Damages, and for

I DEFENDANT'S MOTION TO PERMIT ADDITIONAL. INTERROGATORY The Defendant, Bradley J. Edwards, by and through the undersigned attorneys, moves this) Honorable Court to enter an order Permitting Defendant, Jeffrey Epstein, to propound an additional interrogatory upon Plaintifc Jeffrey Epstein, and states: 1. Th

laintiffs JEFFREY EPSTEIN and L.S.J., LLC, by and through their undersigned counsel, KELLERHALS FERGUSON FLETCHER KROBLIN LLP, and hereby move this Honorable Court for an award of costs and attorneys' fees. I. APPLICABLE LAW Title 5, section 541, provides the applicable law governing the award of costs and a

laintiffs are allowed to proceed on the present course. WHEREFORE, Defendant / Counterclaim Plaintiff ALAN M. DERSHOWITZ respectfully requests this Honorable Court enter an Order that (a) directs Plaintiffs BRADLEY J. EDWARDS and PAUL G. CASSELL to make, within ten (10) days of the entry of the Order, a final

TO COMPEL SUBSTANTIVE RESPONSE TO REOUEST TO PRODUCE SERVED APRIL 15, 2011 Bradley J. Edwards, by and through his undersigned attorneys, moves this Honorable Court to compel Jeffrey Epstein's substantive response to the attached Request to Produce over the objections asserted by Jeffrey Epstein. WHEREFORE, Br

he "Offer"). A true and correct copy of same is attached hereto as "Exhibit A." Edwards failed to accept Epstein's Offer. On January 27, 2014, this Honorable Court granted summary judgment in favor of Epstein on both counts. This Court entered Tonja Haddad, P.A. • 315 SE 70, Street, Fort Lauderdale, FL 33301 E

ein, Civil No and Jane Doe 102 v Epstein, Civil No . Additional lawsuits have been filed by others and consolidated for pretrial purposes by this Honorable Court as Jane Doe 2 v Epstein, Civil No . This Declaratory Judgment results directly from Epstein's intent and purpose to fulfill and not violate each