MEMY-1805 marker2 court-epstein-v-rothstein (salt 4090): 3654/3654

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marker2/court-epstein-v-rothstein/EFTA02770116/EFTA02770116.md

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+## IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+CASE NO.: 502009CA040800XXXXMBAG
+
+JEFFREY EPSTEIN,
+
+Plaintiff(s),
+
+VS.
+
+SCOTT ROTHSTEIN individually, J. individually, and L.M., individually, Vim :pa
+
+` • C4 > r-3 , a n co
+
+/
+
+## t A4C) DEFENDANT/COUNTERPLAINTIFF, J. MOTION FOR ATTORNEY'S FEES PURSUANT TO FLA. STAT. 457.105
+
+Defendant(s).
+
+Defendant/Counterplaintiff, BRADLEY J. , by and through his undersigned counsel, respectfully moves this C ant to §57.105, Fla. Stat., for an award of reasonable attorney's fees i defending Plaintiff/Counterdefendant, JEFFREY EPSTEIN'S Motion for Attorne ees Pursuant to Fla. Stat. §57.105, and in support thereof states as follows:
+
+1. io 7.105 provides, in relevant part:
+
+(1) the court's initiative or motion of any party, the court shall award a reasonable attorney's fee to be paid to the prevailing party in equal amounts by the losing party and the losing party's attorney on any claim or defense at any time during a civil proceeding or action in which the court finds that the losing party or the losing party's attorney knew or should have known that a claim or defense when initially presented to the court or at any time before trial:
+
+adv. Epstein Motion for Attorney's Fees Pursuant to 57.105 Case No.: 502009CA040800XXXXMBAG
+
+(a) Was not supported by the material facts necessary to establish the claim or defense; or
+
+(b) Would not be supported by the application of then-existing law to those material facts.
+
+2. The amendments to §57.105, Fla. Stat. expanded the scope of the statute to apply to any claim or defense. See Boca Burger, Inc. v. Forum, 912 So.2d 561 (Fla. 2005).
+
+3. Pursuant to §57.105, Fla. Stat., attorney's fees ay be awarded if the party or its counsel knew or should have known that the claim or d rted was not supported by the facts or an application of then-existing law. See . d v. Taylor, 832 So.2d 219 (Fla. 4 DCA 2002).
+
+4. On or about September 2:21:11, STEIN filed a Notice of Intent to File a F.S. §57.105 motion seeking to sanction EDWARDS and his counsel for the prosecution of Counterclaim against EPSTEIN. The assertion that the Counterclaim lacked factual and legal support is clearly spurious in light of the factual and legal support detailed in pending Motion for Summary Judgment and Motion to Assert Claim for Punitive Damages. Moreover, at the very same time that EPSTEIN takes the position in his §57.105 motion that EDWARDS' claim is baseless; he has filed a Proposal for Settlement offering to pay hundreds of thousands of dollars to settle that same claim.
+
+WHEREFORE, Defendant/Counterplaintiff, J. respectfully requests that his Motion for Attorney's Fees Pursuant to §57.105, Fla. Stat., be granted and that this Court grant such other and further relief as deemed necessary and proper.
+
+[REDACTED] adv. Epstein  
+Motion for Attorney's Fees Pursuant to 57.105  
+Case No.: 502009CA040800XXXXMBAG
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by  
+U.S. Mail to all Counsel on the attached list, this 5<sup>th</sup> day of October, 2011.
+
+![]()Jack Scarola  
+Florida Bar No.: 169440  
+Searcy Denney Scarola Barnhart & Shipley  
+2139 Palm Beach Lakes Boulevard  
+West Palm Beach, Florida 33409  
+Phone: (561) 686-6300  
+Fax: (561) 383-9451  
+Attorney for [REDACTED] J. [REDACTED]
+
+NOTA CERTIFIED
+
+M adv. Epstein Motion for Attorney's Fees Pursuant to 57.105 Case No.: 502009CA040800XXXXMBAG
+
+## COUNSEL LIST
+
+Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. Attorney For: Jeffrey Epstein 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: (561) 659-8300 Fax: (561) 835-8691
+
+Jaffe, Weissing, Fistos & Lehrman, PL Attorney For: Jeffrey Epstein 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954) 524-2820 Fax: (954) 524-2822
+
+Marc S. Nurik, Esquire Law Offices of Marc S. Nurik Attorney For: Scott Rothstein One E Broward Blvd., Suite 700 • Fort Lauderdale, FL 33301 Phone: (954) 745-5849 Fax: (954) 745-3556
+
+L. Ackerman, Jr., Esquire Burnett, P.A. Attorney For: Jeffrey Epstein 901 Phillips Point West 777 S Flagler Drive West Palm Beach, FL 33401-6170 Phone: (561) 802-9044 Fax: (561) 802-9976
+
+cos

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marker2/court-epstein-v-rothstein/EFTA02770120/EFTA02770120.md

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+IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT  
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+CIVIL DIVISION AG  
+CASE NO. 502009CA040800XXXXMB  
+Judge David F. [REDACTED]
+
+JEFFREY EPSTEIN,
+
+Plaintiff,
+
+vs.
+
+SCOTT ROTHSTEIN, individually,  
+[REDACTED] J. [REDACTED], individually,  
+Defendants.
+
+FILED  
+2010CT21 PM 4:33  
+SHARON R. BOCK, CLERK  
+PALM BEACH COUNTY, FL  
+CIRCUIT CIVIL
+
+**PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS  
+AMENDED COUNTERCLAIM AND INCORPORATED MEMORANDUM OF LAW**
+
+Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his undersigned counsel, hereby moves to dismiss the Amended Counterclaim of the Defendant/Counter-Plaintiff, [REDACTED] ("[REDACTED]"), and in support thereof states as follows:
+
+**I. SUMMARY OF ARGUMENT**
+
+[REDACTED] Amended Counterclaim should be dismissed because it fails to state an actionable claim against Epstein for abuse of process or malicious prosecution. Count I fails to state a valid abuse of process claim because [REDACTED] does not allege (1) that Epstein made any illegal, improper, or perverted use of process; (2) that Epstein had any ulterior motive or purpose; and (3) that [REDACTED] suffered any legally cognizable damage as a result of Epstein's actions in the pending litigation. Count II fails to state a valid claim for malicious prosecution because [REDACTED] does not -- and cannot -- allege that there was a bona fide termination of an
+
+original proceeding in his favor, much less that any such original proceeding was without merit. Count II also improperly commingles claims for abuse of process and malicious prosecution.
+
+## II. BACKGROUND
+
+In December, 2009, Epstein, through prior counsel, filed a Complaint naming as a defendant. filed an Answer and Counterclaim for abuse of process. The Court denied Epstein's motion to dismiss Counterclaim. then filed a motion for summary judgment on Epstein's Complaint and a motion for leave to assert punitive damages. The Court denied summary judgment motion as "premature" because Epstein "has not been able to obtain records which clearly are calculated to lead to admissible evidence in this case" and because of pending privilege issues, and denied the, punitive damages motion pending finalization of the pleadings.
+
+On April 15, 2011, Epstein filed an Amended Complaint at the Court's direction, which consisted of a single count against for abuse of process, and a count against Defendant Scott Rothstein for conspiracy. moved to dismiss Epstein's Amended Complaint. At a July 13, 2011 hearing, the Court granted motion to dismiss the Amended Complaint with leave to amend. Epstein had previously advised the Court at other hearings that further amendments may be needed as discovery proceeds.'
+
+Epstein then filed a Second Amended Complaint which contained a single count against Edwards for abuse of process, and a single count against Rothstein for conspiracy to commit abuse of process. moved to dismiss the Second Amended Complaint. The Court denied MI' motion after a hearing on September 28, 2011. During that hearing, the Court explained that abuse of process requires improper use of process after it has issued and expressed
+
+The Court has deferred ruling on privilege issues until the pleadings are finalized.
+
+"serious concerns" as to whether Swards' Counterclaim pleaded a viable claim for abuse of process against Epstein. (Hr'g Tr. 9/28/2011 at 25).
+
+On October 4, 2011, filed an Amended Counterclaim which contained a claim against Epstein for abuse of process (Count I) and a claim for malicious prosecution (Count H). Count I alleges inter alia that Epstein invoked his Fifth Amendment right against selfincrimination (16); notwithstanding Epstein's "intimidation" tactics, clients have continued to prosecute their claims (17); has not engaged in any unethical or improper conduct (1 8); Epstein filed civil claims against and others to intimidate them (19); Epstein knew and has known that his prior Complaint had no factual support and could not be prosecuted "to a successful conclusion" (112; see also 1110-11); in filing and "continuing to prosecute each of the claims" against M, Epstein acted maliciously and "to extort into abandoning the claims he was prosecuting against (114); and each pleading, motion, subpoena and request for production by Epstein was intended to "advance Epstein's efforts at extortion . . . and constituted a perversion of process after its initial service." (116).
+
+M ' malicious prosecution claim (Count 11) incorporates all allegations of his abuse of process claim and further alleges as follows: .
+
+> After unsuccessful efforts to defend and amend his maliciously filed and prosecuted claims over a period of almost two years, Epstein abandoned the claims except for an ongoing effort to salvage his abuse of process claim. That abandonment brings to successful conclusion defense against each of the other abandoned claims. (118)
+
+seeks damages for abuse of process and malicious prosecution "including but not limited to" injury to reputation, interference in his professional relationships, the loss of the value of his time "required to be directed from his professional responsibilities," and the cost of defending against Epstein's claims. (117).
+
+#### ARGUMENT
+
+#### A. COUNT I OF THE AMENDED COUNTERCLAIM SHOULD BE DISMISSED FOR FAILURE TO STATE A VALID CLAIM FOR ABUSE OF PROCESS
+
+### 1. Legal Standards
+
+'Mt amended abuse of process claim should be dismissed because it is legally insufficient. Abuse of process under Florida law requires pleading and proof of the following three elements: 1) an illegal, improper or perverted use of process; 2) an ulterior motive or purpose in exercising the illegal, improper or perverted process; and 3) resulting damiges. See, e.g., S&I Invs. v. Payless Flea Mkt., 36 So. 3d 909, 917 (Fla. 4th DCA 2010); Valdes v. GAB Robins North America, Inc., 924 So. 2d 862, 867 n.2 (Fla. 3d DCA 2006).
+
+In addition, it "is a fundamental principle of pleading that the complaint, to be sufficient, must allege ultimate facts as distinguished from legal conclusions which, if proved, would establish a cause of action .. ." Maiden v. Carter, 234 So. 2d 168, 170 (Fla. 1st DCA 1970). See also v. Gardens by the Sea South Condominium Ass'n, 424 So. 2d 181, 183 (Fla. 4th DCA 1983) ("Florida uses what is commonly considered as a notice pleading concept and it is a fundamental rule that the claims and ultimate facts supporting same must be alleged. The reason for the rule is to appraise [sic] the other party of the nature of the contentions that he will be called upon to meet, and to enable the court to decide whether same are sufficient."). The ai ded Counterclaim does not meet even this basic requirement.
+
+### 2. Failure To Allege Illegal, Improper or Perverted Use of Process
+
+With regard to the first element of the tort of abuse of process, it is axiomatic that "Vie mere filing of a complaint and having process served is not enough to show abuse of process.' [Citation omitted] The plaintiff must prove improper use of process after it issues." S&I Invs., 36 So. 3d at 917 (quotation omitted)(emphasis added). See also Valdes, 924 So. 2d at 867 ("Valdes' failure to allege any improper willful acts by the appellees during the course of the prior action requires dismissal of the abuse of process claim...."); Yoder v. Adriatico, 459 So. 2d 449, 450 (Fla. 5th DCA 1984) ("the tort of abuse of process is concerned with the improper use of process after it issues") (emphasis added); Cazares v. Church of Scientology, 444 So. 2d 442, 444 (Fla. 5th DCA 1983) (holding that a cause of action for abuse of process would not lie where the Church alleged no act other than the wrongful filing of a lawsuit); Peckins v. Kaye, 443 So. 2d 1025, 1026 (Fla. 2d DCA 1986) (counterclaim allegedly causing undue expenditure of time and money did not constitute abuse of process); McMurray v. U-Haul Co., 425 So. 2d 1208, 1209 (Fla. 4th DCA 1983) (same); Blue v. Weinstein, 381 So. 2d 308, 311 (Fla. 3d DCA 1980) ("[N]o abuse of the process apart from the complaint is pled and the effort to do so amounts to nothing more than a thinly disguised malicious prosecution claim.").
+
+amended abuse of process claim alleges that Epstein "filed' baseless claims against him (see ¶¶9-15) in an attempt to "intimidate" and "extort" into abandoning the claims he was prosecuting against Epstein. (See ¶¶14-15). Because abuse of process claim is based on the filing of allegedly insufficient claims, it fails to state a valid claim for relief. See, e.g., S&I Invs., 36 So. 3d at 917; McMurray, 425 So. 2d at 1209 (counterclaim for abuse of process was properly dismissed with prejudice when based on filing of complaint "for a multitude of improper purposes"). "The maliciousness or lack of- foundation of the asserted cause of action itself is actually irrelevant to the tort of abuse of process." Cazares, 444 So. 2d at 444.
+
+Although attempts to bolster his amended abuse of process claim with conclusory allegations that the alleged "perversion of process" consists of "every" pleading
+
+Epstein has filed and "every motion, every request for production, every subpoena issued and every deposition taken" (¶16), that attempt fails for two reasons. First, never alleges how or why such acts -- which on their face do not constitute abuse of process -- demonstrate a "perversion of process," or are illegal or improper. Indeed, far from constituting perversion of process, filing motions and conducting discovery are common and often necessary actions in every litigation. See, e.g., Fla. R. Civ. P. 1.280 (general provisions authorizing and delineating discovery). And has not even attempted to allege that the commonplace actions that Epstein has taken are not related to or in furtherance of this litigation. Standing alone, IM bald assertion that Epstein's motions and discovery efforts amount to perversion of process is • insufficient. Instead, "must allege and prove that the process was used for an immediate purpose other than that for which it was designed." Biondo v. Powers, 805 So. 2d 67, 69 (Fla. 4th DCA 2002). This is particularly true in this case, given that the Court has already decreed that the parties must plead with enough specificity to enable it to address critical discovery issues. (See Hr'g Tr. 7/13/20,11 at 18). In the absence of specific factual allegations as to what was illegal, improper or perverted about the process issued by Epstein after filing the Complaint in this action, has failed to plead the first element of abuse of process. And for the same reason, amended abuse of process claim does not provide a "short and plain statement of the ultimate facts showing that the pleader is entitled to relief," as it must. Fla. R. Civ. P. 1.110(b). See also =, 424 So. 2d at 183. In failing to plead the first required element, has failed to plead an abuse of process claim and therefore, Count I should be dismissed.
+
+Second, the crux of Mi claim is that the lawsuit itself is without merit and thus everything within it constitutes an abuse of process and should be dismissed. Count I of the
+
+Amended Counterclaim is nothing more than an invalid malicious prosecution claim in disguise because it is simply targeted at Epstein's entire case against M, and does not allege how the lawsuit compels to do "some collateral action not properly involved in the proceeding." Miami Herald Publ'g Co. v. Ferre, 636 F. Supp. 970, 975 (S.D. Fla. 1985).
+
+# 3. Failure To Allege An Ulterior Motive or Purpose
+
+Even if had alleged perverted use of process -- which he — he has offered nothing more than vague and unfounded allegations to suppo n~cond , required element in an abuse of process claim -- ulterior motive or malicious inte•• 14 that Epstein "effectively" conceded illicit sexual activity, in 15 that many civil suits against Epstein remain pending, and in ¶16 &7 that his "victims and their legal counsel" have been "intimidate[d] . . . into abandoning legitimate claims." The allegations do not identify which suits remain pending, do not identify which victims and their legal counsel have been intimidated, and do not identify a particular agreement pursuant to which Epstein allegedly "effectively concede[d] illicit sexual activity with a large number of female children . . . ." (¶4). Moreover, M claims of intimidation are undermined by his contrary allegations that his clients were not intimidated. (See 14). Without specificity regarding who, what, where and when, Epstein cannot effectively formulate a response and the door will be open to discovery into matters not likely to lead to relevant evidence. See 424 So. 2d at 183. Again, M new allegations do not mask the fact that Count I is nothing more than a weak attempt at a malicious prosecution claim in disguise, as squarely demonstrated by the fact that all of la abuse of process allegations are incorporated into his malicious prosecution claim.
+
+Moreover, all of the allegations in ¶14-7 of the Amended Counterclaim refer to events that occured before filing of the Complaint. It is well established, however, that events that
+
+occur before the filing of a complaint and service of process, are not sufficient-to satisfy the element of ulterior motive or malice. See Marty v. Gresh, 501 So. 2d 87 (Fla. 1st DCA 1987); S&I Inn., 36 So. 3d at 917. Accordingly, M abuse of process claim should be dismissed for the additional and independently sufficient reason that he has not properly alleged the second element required to state an abuse of process claim.
+
+# 4. Failure to Plead Damages
+
+Finally, damages claim — "including but not limited to" us elements of damages (¶17) -- should be stricken. First, the open-ended phrase "inc bill not limited to" does not put Epstein on notice as to the specific damages that is claiming and must, therefore, be struck. (See Hr'g Tr. 7/13/2011 at 19-20 (this Court struck similar language from Epstein's Amended Complaint); =, 424 So. 2d at 183).
+
+Second, demand for damag utation is a thinly-veiled and impermissible attempt to inject defamation into the IF A kittion. aire milady, demand for damages for "interference in his professional relations ps" is a thinly-veiled and impermissible attempt to inject tortious interference into the litigation. Such kitchen-sink pleading denies Epstein due process and due notice. These are separate claims with separate defenses commingled in a single count, in violation of Fla. R. Civ. P. 1.110(0, which requires separate statements of claim.
+
+Third, there is no legal authority which permits to recover damages for abuse of process for the "loss of the value of his time required to be diverted from his professional responsibilities." (¶17). A litigant cannot recover damages for the time spent defending a claim. See, e.g., Miami National Bank v. Nunez, 541 So. 2d 1259, 1260 (Fla. 3d DCA 1989) ("We fmd no precedent for awarding a litigant compensatory damages for her own participation in the preparation for litigation."); Maulden v. Corbin, 537 So. 2d 1085, 1087 (Fla. 1st DCA 1989)
+
+(ruling that an attorney litigant was not entitled to compensation for his time participating' n litigation when he engaged counsel to represent him in the matter). Since has engaged Mr. Scarola from the outset of this case, cannot claim his time assisting counsel or participating in this case as damages.
+
+Finally, seeks damages for the "cost of defending against [sic] Epstein's spurious and baseless claims." Although a party who recovers a judgment is entitled to taxable costs pursuant to §57.104, Fla. Stat., a party is not entitled to an award of attorney's fees unless there is a statutory or contractual entitlement pleaded and established. To the extent seeks attorney's fees, the claim should be denied because of his failure to plead entitlement by statute or contract. See Florida Hurricane Prot. & Awning, Inc. v. Pastina, 43 So. 3d 893, 895 (Fla. 4th DCA 2010). In short, has failed to plead that he has suffered any legally cognizable damages. Thus, he has failed to plead the third element of his abuse of process claim. As a result, Count I should be denied.
+
+#### B. COUNT II OF THE AMENDED COUNTERCLAIM SHOULD BE DISMISSED FOR FAILURE TO STATE A VALID CLAIM FOR MALICIOUS PROSECUTION
+
+Malicious prosecution requires pleading and proof of the following elements: "(I) an original criminal or civil judicial proceeding against the present plaintiff was commenced or continued; (2) the present defendant was the legal cause of the original proceeding against the present plaintiff as the defendant in the original proceeding; (3) the termination of the original proceeding constituted a bona fide termination of that proceeding in favor of the present plaintiff; (4) there was an absence of probable cause for the original proceeding; (5) there was malice on the part of the present defendant; and (6) the plaintiff suffered damage as a result of the original proceeding." Alamo Rent-A-Car v. Mancusi, 632 So. 2d 1352, 1355 (Fla. 1994) (emphasis
+
+added). A claim for malicious prosecution is defeated if a plaintiff fails to allege or establish any one of these six elements. Id.
+
+A "bona fide termination" of the proceedings has been described as follows:
+
+It is axiomatic that a plaintiff in a malicious prosecution case must, as an essential elements of that cause of action, establish that the prior litigation giving rise to the malicious prosecution suit ended with a "bona fide termination" in that party's favor. That is a fancy phrase which means that the first suit, on which the malicious prosecution suit is based, ended in a manner indicating the original defendant's (and current plaintiffs) innocence of the charges or 'allegations contained in the first suit, so that a court handling the malicious prosecution suit, can conclude with confidence, that the termination of the first suit was not only favorable to the defendant in that suit, but also that it demonstrated the first suit's lack of merit.
+
+Doss v. Bank of Am., N.A., 857 So. 2d 991, 994 (Fla. 5th DCA 2003) (emphasis added).
+
+Given the requirement that an original or prior proceeding terminate in favor of a malicious prosecution claimant, under settled Florida law "malicious prosecution may not be brought as a counterclaim when directed against the filing of some or all of the counts in the pending main action." Blue, 381 So. 2d at 311. That is precisely what has done. As explained in Cazares, 444 So. 2d at 447: "Florida courts clearly hold that an action for malicious prosecution cannot be filed until the original action is concluded, thus precluding any counterclaims from being filed in the underlying action itself." See also Bieley v. Du Pont, Clore, Forgan, Inc., 316 So. 2d 66, 67 (Fla. 3d DCA 1975) ("A counterclaim for malicious prosecution or abuse or process cannot be maintained in a pending action since the abuse claimed is the pending suit which cannot be said to have terminated in favor of the counterclaimant."); American Salvage & Jobbing Co., Inc. v. Salomon, 295 So. 2d 710, 712 (Fla. 3d DCA 1974) (a malicious prosecution counterclaim was properly dismissed where the complaint was still pending: "It is readily apparent that an action which is pending cannot be said to be terminated in favor of the counterclaimant.").
+
+Based upon the foregoing authorities, M' malicious prosecution counterclaim fails to state a valid claim for relief because there has been no termination of the "original proceeding" -- by definition, a proceeding different from and prior to the present action -- as absolutely required to state a claim for malicious prosecution. has not pleaded — and cannot plead — that "the first suit, on which the malicious prosecution suit is based, ended"Doss, 857 So. 2d at 994 (emphasis added). has not pleaded — and certainly cannot plead — that Epstein's pending suit against him has terminated in favor. Indeed, IM Amended Counterclaim squarely violates the rule that "malicious prosecution may not be brought as a counterclaim when directed against the filing of some or all of the counts in the pending action." Blue, 381 So. 2d at 311 (IC/Lir decisions holding that malicious prosecution may not be brought as a counterclaim when directed against the filing of some or all of the counts in the pending main action are sound and are herein affirmed."). Thus, unless and until Epstein's pending action against terminates in ME favor, any malicious prosecution claim by is invalid as a matter of law.
+
+Moreover, Edwards cannot save his malicious prosecution claim with his allegations in 118 of Count II that Epstein "abandoned" certain other claims and that "abandonment brings to successful conclusion defense against each of the other abandoned claims." These allegations do not satisfy the requirement that plead that a prior action brought by Epstein terminated in Me favor. The mere dropping or amendment of claims in the course of pending litigation -- a very common occurrence -- does not, by definition, constitute the termination of a proceeding. See, e.g., American Salvage & Jobbing Co., Inc., 295 So. 2d at 712
+
+("It is readily apparent that an action which is pending cannot be said to be terminated in favor of the counterclaimant."). Moreover, the mere dropping or amending of a claim in ongoing litigation pursuant to an interlocutory order cannot constitute a favorable determination of the action or proceeding, as unquestionably required to state a claim for malicious prosecution. Absent allegations by that a prior proceeding terminated in his favor, it malicious prosecution claim is not actionable.
+
+Finally, because adopts in Count II his damage claims alleged in Count I, Epstein incorporates by reference herein his damages arguments as stated above.
+
+In sum, claim for malicious prosecution is defective and should be dismissed with prejudice. / 14/'
+
+#### C. COUNT II SHOULD BE DISMISSED BECAUSE IT CONTAINS COMMINGLED CLAIMS n
+
+Count II should be dismisse44tg 'additional and independently sufficient reason that it improperly incorporates all allegations supporting the abuse of process claim, thereby impermissibly commingling the two claims. Florida courts recognize that commingling multiple legal claims in a single count severely hampers a defendant's ability to prepare a responsive pleading and require that such claims be repled. See, e.g., Gerantine v. Coastal Sec. Sys., 529 So. 2d 1191, 1194 (Fla. 5th DCA 1988) ("[B)y the time a defendant reached the sixth count of the complaint, he would find himself faced with 72 previous paragraphs, many with numerous subdivisions, replete with evidentiary facts and together forming a total morass which would make it difficult, if not impossible, to respond to."); Frugoli v. Winn-Dixie Stores, 464 So. 2d 1292 (Fla. 1st DCA 1985) (requiring claims to be alleged in separate counts and not intermingled). Such shotgun pleadings are rejected for good reason: "Experience teaches that,
+
+unless cases are pled clearly and precisely, issues are not joined, discovery is not controlled, the trial court's docket becomes unmanageable, the litigants suffer and society loses confidence in the court's ability to administer justice." v. Dist. Bd. of Trs. of Cent. Fla. Cmty. Colt, 77 F. 3d 364, 366-67 (11th Cir. 1996).
+
+### CONCLUSION
+
+Based upon the foregoing arguments and authorities, PlaintifKounter-Defendant, Jeffrey Epstein, respectfully requests that the Court dismiss Defendant/Coun gIttiff
+
+Amended Counterclaim.
+
+Respectfully submitted, C.)
+
+Ir /1.4.44— •Ar Tfe/ L. Ackerman, Jr.
+
+Florida Bar No. 235954. FOWLER BURNETT, P.A. 901 Phillips Point West 77 South Flagler Drive West Palm Beach, Florida 33401 Telephone: (561) 802-9044 Facsimile: (561) 802-9976 Attorneys for Jeffrey Epstein, Plaintiff
+
+and
+
+E. Knight Florida Bar. No. 607363 BURNETT, P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131 Telephone: (305) 789-9200 Facsimile: (305) 789-9201 Attorneys for Jeffrey Epstein, Plaintiff
+
+**CERTIFICATE OF SERVICE**
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via e-mail  
+and U.S. Mail this 21<sup>ST</sup> day of October, 2011 to:
+
+Jack Scarola, Esq.  
+Searcy Denney Scarola Barnhart & Shipley, P.A  
+2139 Palm Beach Lakes Blvd.  
+West Palm Beach, FL 33409
+
+Jack A. Goldberger, Esq.  
+Atterbury Goldberger & Weiss, P.A.  
+250 Australian Avenue South  
+Suite 1400  
+West Palm Beach, FL 33401-5012
+
+Marc S. Nurik, Esq.  
+Law Offices of Marc S. Nurik  
+One E. Broward Blvd., Suite 700  
+Ft. Lauderdale, FL 33301
+
+By:
+
+![]()

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marker2/court-epstein-v-rothstein/EFTA02770134/EFTA02770134.md

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+IN THE CIRCUIT COURT OF THE  
+FIFTEENTH JUDICIAL CIRCUIT, IN AND  
+FOR PALM BEACH COUNTY, FLORIDA
+
+CASE NO.: 502009CA040800XXXXMBAG
+
+JEFFREY EPSTEIN,
+
+Plaintiff,
+
+vs.
+
+SCOTT ROTHSTEIN, individually,  
+[REDACTED] J. [REDACTED], individually, and  
+L.M., individually,
+
+Defendant,
+
+FILED  
+11 OCT 25 PM 3:19  
+SHARON R. BOCK, CLERK  
+PALM BEACH COUNTY, FL  
+CIRCUIT CIVIL 4
+
+NOTICE OF UNAVAILABILITY
+
+Defendant/Counter-Plaintiff, [REDACTED] J. EDWARDS, hereby states that the law offices of Searcy Denney Scarola Barnhart & Shipley, P.A. will be closed from December 23, 2011 through and including December 30, 2011, and respectfully request that no hearings, depositions, trials or any other matter involving the above-styled cause be scheduled during this time.
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by U.S. Mail to all counsel on the attached list, this 25th day of October, 2011.
+
+![]()Jack Scarola  
+Florida Bar No.: 169440  
+Searcy Denney Scarola Barnhart & Shipley, P.A.  
+2139 Palm Beach Lakes Boulevard  
+West Palm Beach, Florida 33409  
+Phone: (561) 686-6300  
+Fax: (561) 383-9451  
+Attorneys for [REDACTED] J. [REDACTED]
+
+Case No.: 502009CA040800XXXXMBAG Notice of Unavailability Christmas 2011 Page 2 of 2
+
+## COUNSEL LIST
+
+Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: (561) 659-8300 Fax: (561) 835-8691 Fistos & cos
+
+MBJaffe, Weissing, Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954) 524-2820 Fax: (954) 524-2822
+
+Marc S. Nurik, Esquire Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954) 745-5849 Fax: (954) 745-3556
+
+L. Ackerman, Jr., Esqui Burnett, P. 901 Point West 777 S Flagler Drive West Palm Beach, F1.O3401-6170 Phone: (561) 802-90W Fax: (561) 997

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marker2/court-epstein-v-rothstein/EFTA02770136/EFTA02770136.md

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+IN THE CIRCUIT COURT OF THE  
+FIFTEENTH JUDICIAL CIRCUIT, IN AND  
+FOR PALM BEACH COUNTY, FLORIDA
+
+CASE NO.: 502009CA040800XXXXMBAG
+
+JEFFREY EPSTEIN,
+
+Plaintiff(s),
+
+vs.
+
+SCOTT ROTHSTEIN, individually,  
+██████████ J. ██████████, individually, and  
+L.M., individually,
+
+Defendant(s).
+
+FILED  
+11 OCT 28 PM 3:42  
+SHARON R. BOCK, CLERK  
+PALM BEACH COUNTY, FL  
+CIRCUIT CIVIL 4
+
+NOTICE OF PROPOUNDING INTERROGATORIES  
+TO JEFFREY EPSTEIN
+
+██████████ J. ██████████ hereby gives notice that pursuant to Rule 1.340(e), Florida Rules of Civil Procedure, that Interrogatories numbered 1 through 8 have been directed to Jeffrey Epstein, this 28<sup>th</sup> day of October, 2011.
+
+It is requested that the aforesaid answers be served within thirty (30) days at the offices of Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida, 33409.
+
+adv. Epstein Interrogatories to Epstein Case No.: 502009CA040800)OOO(MBAG
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Fax and U.S. Mail to all Counsel on th n this 281h day f Octobe 2011.
+
+> OLA No.: 169440 nney Scarola Barnhart tic Shipley, P.A. alm Beach Lakes Boulevard Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-94 1 Attorney for
+
+[REDACTED] adv. Epstein  
+Interrogatories to Epstein  
+Case No.: 502009CA040800XXXXMBAG
+
+### COUNSEL LIST
+
+Jack A. Goldberger, Esquire  
+jgoldberger@agwpa.com;  
+smahoney@agwpa.com  
+Atterbury, Goldberger & Weiss, P.A.  
+250 Australian Avenue South, Suite 1400  
+West Palm Beach, FL 33401  
+Phone: (561)-659-8300  
+Fax: (561)-835-8691  
+Attorneys for Jeffrey Epstein
+
+[REDACTED], Jaffe, Weissing, [REDACTED], Fistos &  
+Lehrman, PL  
+425 N. Andrews Avenue, Suite 2  
+Fort Lauderdale, FL 33301  
+Phone: (954)-524-2820  
+Fax: (954)-524-2822  
+Attorneys for Jeffrey Epstein
+
+[REDACTED] L. Ackerman, Jr., Esquire  
+[REDACTED]; [REDACTED]  
+[REDACTED] Burnett, P.A.  
+901 [REDACTED] Point West  
+777 S Flagler Drive  
+West Palm Beach, FL 33401-6170  
+Phone: (561)-802-9044  
+Fax: (561)-802-9976  
+Attorneys for Jeffrey Epstein
+
+Marc S. Nurik, Esquire  
+marc@nuriklaw.com  
+Law Offices of Marc S. Nurik  
+One E Broward Blvd., Suite 700  
+Fort Lauderdale, FL 33301  
+Phone: (954)-745-5849  
+Fax: (954)-745-3556  
+Attorneys for Scott Rothstein

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marker2/court-epstein-v-rothstein/EFTA02770139/EFTA02770139.md

@@ -0,0 +1,126 @@
+### IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+CASE NO.: 502009CA040800XXXXMBAG
+
+JEFFREY EPSTEIN,
+
+Plaintiff,
+
+VS.
+
+SCOTT ROTHSTEIN individually, J. , individually, and L.M., individually,
+
+Defendant,
+
+Defendant, J. (EDWARDS), responds to Plaintiff's Introduction by stating that it is irrelevant surplusage requiring no answer.
+
+### ANSWER AND AFFIRMATIVE DEFENSES TO SECOND AMENDED COMPLAINT
+
+### L ALLEGATIONS
+
+1. Defendant, ies the allegations contained in paragraph 1 and demands strict proof thereof.
+
+2. Admitted. il itly
+
+3. itted.
+
++ Cmitted. 4. -
+
+5. Defendant, . denies the allegations contained in paragraph 5 and demands strict proof thereof.
+
+6. Defendant, , is without knowledge to either admit or deny the allegations contained in paragraph 6 so therefore denies same and demands strict proof thereof.
+
+adv. Epstein Case No.: 502009CA040800X200(MBAG ANSWER TO SECOND AMENDED COMPLAINT Page 2 of 6
+
+7. Defendant, I , is without knowledge to either admit or deny the allegations contained in paragraph 7 so therefore denies same and demands strict proof thereof.
+
+8. Defendant, , admits that RRA was engaged in litigation against Epstein in three civil cases, but Defendant, , is without knowledge to either admit or deny the balance of the allegations of paragraph 8 so therefore denies sa O \ (1 demands strict proof thereof.
+
+C
+
+g either admit or deny the 10. Defendant, is without lat allegations contained in paragraph 10 so therefore and demands strict proof thereof.
+
+9. Admitted.
+
+11. Defendant, isten and Jenne provided investigative services relating to the prosecution of thrEpstein Actions. Defendant, la, denied the balance of the allegations of paragraph 11 and demands strict proof thereof.
+
+12. Defendant, ...., admits that Fisten and Jenne reported to regarding matters related to the Epstein Actions. Defendant, is without knowledge as to the balance 4S'tice allegations of paragraph 12 so therefore denies same and demands strict proof therepO
+
+dMitted.
+
+14. Defendant, admits that incurred costs in the prosecution of the. Epstein Actions. Defendant, is without knowledge as to the balance of the allegations of paragraph 14 so therefore denies same and demands strict proof thereof.
+
+15. Defendant, is without knowledge to either admit or deny the allegations contained in paragraph 15 so therefore denies same and demands strict proof thereof.
+
+16. Defendant, is without knowledge to either admit or deny the allegations contained in paragraph 16 so therefore denies same and demands strict proof thereof.
+
+17. Defendant, EDWARDS, is without knowledge to either admit or deny the allegations contained in paragraph 17 so therefore denies same and demands strict proof thereof.
+
+18. Defendant, is without knowledge to either admit or deny the allegations contained in paragraph 18 so therefore denies same and demands strict proof thereof
+
+19. Defendant, has accurately testified regarding the prosecution of the Epstein Actions and all conflicting allegations are denied and defendant demands strict proof thereof
+
+20. Defendant, EDWARDS, has accurately testified regarding the prosecution of the Epstein Actions and all conflicting allegations are denied and defendant demands strict proof thereof
+
+is without knowledge to either admit or deny the allegatio s co ained in paragraph 22 so therefore denies same and demands strict proof thereof.
+
+23. Admitted.
+
+24. Defendant, admits the allegations contained in subparts (e) and (f) of paragraph 24. Defendant, denies the balance of the allegations contained in paragraph 2 and demands strict proof thereof
+
+adv. Epstein Case No.: S02009CA040800,OOO(MBAG ANSWER TO SECOND AMENDED COMPLAINT Page 4 of 6
+
+25. Defendant, denies the allegations contained in paragraph 25 and demands strict proof thereof.
+
+26. Defendant, is without knowledge to either admit or deny the allegations contained in paragraph 26 so therefore denies same and demands strict proof thereof.
+
+27. Admitted.
+
+28. Defendant, admits that Rothstein was arrested, arraigned in federal court, pled guilty and ultimately was sentenced to a 50 ye prison sentence for fraud and racketeering. Defendant, I , is without lcnowl the balance of the allegations contained in paragraph 29 so therefore denies same 'Sipa lids strict proof thereof. 1
+
+# COUNT I: ABUSE orptc ss
+
+29. Defendant, =M, admits or denies each of the allegations contained in paragraphs 1 through 28 as if fully setforth here.
+
+30. Defendant, MINII, denies the allegations contained in paragraph 30 and demands strict proof th
+
+31.
+
+32. denies the allegations contained in paragraph 32 and deman s tnc roof thereof.
+
+33. Defendant, . denies the allegations contained in paragraph 33 and demands strict proof thereof.
+
+34. Defendant, , denies the allegations contained in paragraph 34 and demands strict proof thereof.
+
+COUNT II: CONSPIRACY TO COMMIT ABUSE OF PROCESS—ROTHSTEIN
+
+35. The allegations of paragraphs 35-39 are not directed to Defendant, [REDACTED], and are therefore not responded to.
+
+AFFIRMATIVE DEFENSES
+
+1. 1. The actions of [REDACTED] are absolutely protected from liability in accordance with the litigation privilege.
+2. 2. The actions of [REDACTED] are qualifiedly protected in accordance with the litigation privilege.
+3. 3. The claims against [REDACTED] are barred by the sword-shield doctrine.
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Fax and U.S. Mail to all counsel on the attached list, this 28<sup>th</sup> day of October, 2011.
+
+![]()Jack Scarola  
+Florida Bar No.: 169440  
+Searcy Denney Scarola Barnhart & Shipley, P.A.  
+2139 Palm Beach Lakes Boulevard  
+West Palm Beach, Florida 33409  
+Phone: (561) 686-6300  
+Fax: (561) 383-9451  
+Attorneys for [REDACTED] J. [REDACTED]
+
+adv. Epstein Case No.: 502009CA040800XXXXMBAG ANSWER TO SECOND AMENDED COMPLAINT Page 6 of 6
+
+## COUNSEL LIST
+
+Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. Attorney For: Jeffrey Epstein 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: (561) 659-8300 Fax: (561) 835-8691
+
+\_,Jaffe, Weissing, Fistos & Lehrman, PL Attorney For: Jeffrey Epstein 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954) 524-2820 Fax: (954) 524-2822
+
+Marc S. Nurik, Esquire Law Offices of Marc S. Nurik Attorney For: Scott Rothstein One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954) 745-5849 Fax: (954) 745-3556
+
+L. Ackerman, Jr., Esquire Burnett, P.A. For: Jeffrey Epa 901 Point West 777 S Flagler Drive West Palm Beach, FL 33401-6170 Phone: (561) 802-9044 Fax: (561) 802-9976

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marker2/court-epstein-v-rothstein/EFTA02770145/EFTA02770145.md

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+## IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+CASE NO.: 502009CA040800XXXXMBAG
+
+JEFFREY EPSTEIN,
+
+Plaintiff(s),
+
+vs.
+
+SCOTT ROTHSTEIN individually, J. individually, and L.M., individually,
+
+Defendant(s).
+
+/Th4 tr-in 9 \*-4S CD CO n < c , r-z r 0
+
+## • rn .r. REOUEST TO PRODUCE TO JE cQF YJEPSTEIN 7212 , , no.
+
+J. by and through his un i unsel, requests, pursuant to Rule 1.350 of the Florida Rules of Civil Procedure Epstein produce and permit J. to inspect and copy each of the followin documents\*:
+
+- 1. All contracts for legal services rendered in defense of the criminal charges and civil claims prosecuted against you arising out of allegations involving your misconduct with minor females.
+  - 2. All invoices for legal services rendered in connection with the referenced matters.
+  - 3. All statements for costs incurred in connection with the referenced matters.
+- 4. All documents reflecting and/or relating to the payment for services and costs incurred in connection with the referenced matters.
+
+"Documents" shall include, but not be limited to all non-identical copies of writings, drawings, graphs, charts, photographs, phono-records, recordings, and/or any other data compilations from which information can be obtained, translated, if necessary, by the party to
+
+[REDACTED] adv. Epstein  
+Case No.: 502009CA040800XXXXXMBAG  
+Plaintiffs' Request to Produce to Jeffrey Epstein
+
+whom the request is directed through detection devices into reasonably usable form. "Documents" also include all electronic data as well as application metadata and system metadata. All inventories and rosters of your information technology (IT) systems—e.g., hardware, software and data, including but not limited to network drawings, lists of computing devices (servers, PCs, laptops, PDAs, cell phones, with data storage and/or transmission features), programs, data maps and security tools and protocols.
+
+It is requested that the aforesaid production be made within thirty days of service of this request at the offices of Searcy Denney Scarola Barnhart & Shipley, P.A., 2139 Palm Beach Lakes Boulevard, West Palm Beach, Florida. Inspection will be made by visual observation, examination and/or copying.
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Fax and U.S. Mail to all Counsel on the attached list, this 28<sup>th</sup> day of October, 2011.
+
+![]()Jack Scarola  
+Florida Bar No.: 169440  
+Searcy Denney Scarola Barnhart & Shipley  
+2139 Palm Beach Lakes Boulevard  
+West Palm Beach, Florida 33409  
+Phone: (561) 686-6300  
+Fax: (561) 383-9451  
+Attorneys for [REDACTED] J. [REDACTED]
+
+adv. Epstein Case No.: 502009CA040800XXXXMBAG Plaintiffs' Request to Produce to Jeffrey Epstein
+
+## COUNSEL LIST
+
+Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. Attorney For: Jeffrey Epstein 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: (561) 659-8300 Fax: (561) 835-8691
+
+Farmer, Jaffe, Weissing, Fistos & Fort Lauderdale, FL 33301 Lehrman, PL Attorney For: Jeffre Epstein 425 N. Andrews Ave enue, Suite 2 Phone: (954) 524-2820 Fax: (954) 524-2822
+
+Marc S. Nurik, Esquire ( S" Law Offices of Marc S. Nurik Attorney For: Scott Rothstein One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954) 745-5849 Fax: (954) 745-3556 t wilit.\_
+
+L. Ackerman, Jr., Esquire Burnett, P.A. Attorney For: Jeffrey Epstein 901 Point West 777 S Flagler Drive West Palm Beach, FL 33401-6170 Phone: (561) 802-9044 Fax: (561) 802-9970

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marker2/court-epstein-v-rothstein/EFTA02770148/EFTA02770148.md

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+IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT  
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+CIVIL DIVISION AG  
+CASE NO. 502009CA040800XXXXMB  
+Judge David F. [REDACTED]
+
+JEFFREY EPSTEIN,
+
+Plaintiff,
+
+v.
+
+SCOTT ROTHSTEIN, individually and  
+[REDACTED] J. [REDACTED], individually,
+
+Defendants.
+
+FILED  
+11 OCT 31 PM 3:06  
+SHARON R. BOCK, CLERK  
+PALM BEACH COUNTY, FL  
+CIRCUIT CIVIL 4
+
+FILED
+
+**PLAINTIFF JEFFREY EPSTEIN'S RENEWED MOTION FOR  
+PROTECTIVE ORDER RELATING TO HIS DEPOSITION**
+
+Plaintiff Jeffrey Epstein moves the Court for entry of a protective order, pursuant to Florida Rule of Civil Procedure 1.280, to prevent the taking on November 14, 2011 of his further deposition which Defendant [REDACTED] J. [REDACTED] ("[REDACTED]") has noticed over the Plaintiff's objection. The grounds for this Motion are:
+
+1. 1. On or about October 27, 2011, counsel to [REDACTED] noticed the video deposition of the Plaintiff for November 14, 2011 in West Palm Beach, Florida to retake the deposition of the Plaintiff. A copy of the Notice is attached as Exhibit A.
+2. 2. The Plaintiff seeks a protective order to prevent his further deposition at this time because (a) he has already been deposed at length; (b) no meaningful grounds have been alleged to justify the taking of a second deposition other than the unsubstantiated assertion that the Plaintiff has somehow waived his rights under the Fifth Amendment to the U.S. Constitution which he has not; (c) the timing is in conflict with the Court's recent order requiring the
+
+resolution of the pleadings so that the Court may determine the scope of inquiry; and (d) it is burdensome, oppressive, and harassing to allow another deposition.
+
+Moreover, the taking of a video deposition in light of the publicity surrounding these parties would be particularly prejudicial to the Plaintiff, so the Plaintiff requests restrictions on the taking and/or use of a video deposition. Aft"
+
+3. Rule 1.280(c) affords the Court discretion to grant pro "crders for good cause shown and to protect a party from annoyance, embarrassment, oppression, or undue burden or expense. See also Logitech Cargo v. JW M, 817 So. 2d 1033 (Fla. 3d DCA 2002). Moreover, the Court may determine the time, place of a deposition, and circumstances of how a 4 deposition can occur. Fla. R. Civ. P. 1.280(cX2). In this case, the Court should determine whether a fiirther deposition of the Plainti Ai\ i led or necessary and whether a video c tIc deposition should be allowed; and if so, what re • .lions should be placed on its use.
+
+WHEREFORE, for the above stated reasons, Plaintiff Jeffrey Epstein moves for entry of a protective order to prevent the taking of his deposition set for November 14, 2011 and for such other relief as the Court deems proper in the circumstances.
+
+Respectfully submitted,
+
+oseph L. Ac erman, Jr.
+
+Florida Bar No. 235954 BURNETT, P.A.
+
+901 Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: (561) 802-9044 Facsimile: (561) 802-9976 Attorneys for Jeffrey Epstein, Plaintiff
+
+and
+
+E. Knight Florida Bar. No. 607363 BURNETT, P.A. Espirito Santo Plaza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131 Telephone: (305) 789-9200 Facsimile: (305) 789-9201 Attorneys for Jeffrey Epstein, Plaintiff
+
+## CERTIFICATE OF SERVICE
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via U.S.
+
+Mail on this 28, day of October, 2011 to:
+
+Jack Scarola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. \' 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409
+
+?S'
+
+Jack A. Goldberger, Esq. Atterbury Goldberger & Weiss, P. 250 Australian Avenue South, Suite West Palm Beach, FL 33401-5012
+
+Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301
+
+By:
+
+JEFFREY EPSTEIN,
+
+Plaintiffis),
+
+vs.
+
+### IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+CASE NO.: 502009CA040800XXXXMBAG
+
+L.M., widual y, J. individually, and C O
+
+Defendant(s).
+
+### RE-NOTICE OF TAKING VIDEi'EPOSMON
+
+TO: All counsel on the attached Counsel L'
+
+stew
+
+PLEASE TAKE NOTICE that e gned attorneys will take deposition(s) of:
+
+### NAME AND ADDRESS (ItA TIME LOCATION
+
+Jeffrey Epstein November 14, 2011 9:00 a.m.
+
+VIDEOGRAPHER: To be arranged by Phipps Reporting
+
+Searcy Denney, et al 2139 Palm Beach Lakes Boulevard, WPB
+
+upon oral examination before Phipps Reporting, a Notary Public; or any other officer authorized by law to take depositions in the State of Florida. The oral examination is being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the applicable Statutes or Rules.
+
+![](_page_3_Picture_19.jpeg)
+
+[REDACTED] adv. Epstein  
+Case No. 502009CA040800XXXXXMBAG  
+RE-Notice of Taking Video Deposition  
+Page 2
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by  
+Fax and U.S. Mail to all Counsel on the attached list, this 27<sup>nd</sup> day of October, 2011.
+
+![]()Jack Scarola  
+Florida Bar No.: 169440  
+Searcy Denney Scarola Barnhart & Shipley  
+2139 Palm Beach Lakes Boulevard  
+West Palm Beach, Florida 33409  
+Phone: (561) 686-6300  
+Fax: (561) 383-9451  
+Attorney for [REDACTED] J. [REDACTED]
+
+cc: Phipps Reporting
+
+**E-TRANSCRIPT, ASCII, CD AND/OR DVD REQUESTED**
+
+**AMERICANS WITH DISABILITIES ACT**
+
+In accordance with the Americans With Disabilities Act, persons in need of a special accommodation to participate in this proceeding should contact the Human Resources Manager, Searcy Denney Scarola Barnhart & Shipley, P.A., no later than seven days prior to the proceeding. Please telephone (561) 686-6300.
+
+adv. Epstein Case No. 502009CA040800,OOOO4BAG RE-Notice of Taking Video Deposition Page 3
+
+# COUNSEL LIST
+
+Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Paint Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691
+
+Jaffe, Weissing, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fax: (954)-524-2822
+
+L. Ackerman, Jr., Esquire Burnett, P.A. 901 Point West 777 S Flagler Drive West Palm Beach, FL 33401-61 Phone: (561)-802-9044 Fax: (561)-802-9976
+
+Marc S. Nurik, Esquire \,\* marc@nurildaw.coM Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556
+
+cos

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marker2/court-epstein-v-rothstein/EFTA02770154/EFTA02770154.md

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+IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT  
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+CIVIL DIVISION AG  
+CASE NO. 502009CA040800XXXXMB  
+Judge David F. [REDACTED]
+
+JEFFREY EPSTEIN,
+
+Plaintiff,
+
+vs.
+
+SCOTT ROTHSTEIN, individually,  
+[REDACTED] J. [REDACTED], individually,
+
+Defendants.
+
+FILED  
+11 OCT 31 PM 3:06  
+SHARON R. BOCK, CLERK  
+PALM BEACH COUNTY, FL
+
+**PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN  
+OPPOSITION TO DEFENDANT/COUNTERPLAINTIFF [REDACTED] J. [REDACTED]  
+MOTION FOR ATTORNEY'S FEES PURSUANT TO FLA. STAT. §57.105**
+
+Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his undersigned counsel, hereby offers the following Response In Opposition To Defendant/Counterplaintiff Bradley J. [REDACTED] Motion For Attorney's Fees Pursuant To Fla. Stat. §57.105, and states as follows :
+
+**I. SUMMARY OF ARGUMENT**
+
+[REDACTED] motion for attorney's fees pursuant to §57.105, Fla. Stat. ("§57.105 motion"), is frivolous. [REDACTED] seeks sanctions against Epstein based upon Epstein's service of a §57.105(4) notice of intent directed to [REDACTED] Counterclaim for abuse of process. Epstein asserted in his §57.105 motion that [REDACTED] abuse of process counterclaim was legally insufficient because it did not allege any abuse of process *after* Epstein filed his Complaint. At a September 28, 2011 hearing, this Court expressed the same concern that [REDACTED] Counterclaim for abuse of process did *not* state a valid claim because it failed to allege any improper process by Epstein subsequent
+
+to the filing of the Complaint. In response to the Court's concerns, on October 4, 2011, filed an Amended Counterclaim for abuse of process and malicious prosecution. The next day, after filing an Amended Counterclaim, nevertheless filed the subject sanctions motion, contending that Epstein's §57.105 motion was frivolous because initial Counterclaim for abuse of process was valid. But Epstein's contentions regarding the invalidity of a abuse of process claim have been validated by both this Court's statements at the September 28 hearing and by a' own decision to amend his counterclaim. As a result, cannot credibly claim that his initial abuse of process claim was valid, much less that he is entitled to sanctions on that basis.
+
+a ' sanctions motion should also be denied because a §57.105 motion cannot be based on an unfiled §57.105 motion. Finally, §57.105 motion should be denied and stricken because it reveals the general amount of a proposal for settlement that Epstein made to in this litigation, which information is confidential and inadmissible.
+
+# IL BACKGROUND
+
+In December, 2009, Epstein, through prior counsel, filed a Complaint naming as a defendant. filed an Answer and Counterclaim for abuse of process, followed by a motion for summary judgment and motion for leave to assert punitive damages. The Court denied a' summary judgment motion and denied without prejudice a' motion for leave to assert punitive damages. Epstein filed an Amended Complaint, which moved to dismiss. The Court granted a motion to dismiss the Amended Complaint, with leave to amend. Epstein then filed a Second Amended Complaint containing a single count against for abuse of process, and a single count against Rothstein for conspiracy, which moved to dismiss.
+
+On or about August 25, 2011, Epstein sent a proposal for settlement directed to Counterclaim. On or about September 2, 2011, Epstein served with a notice of intent pursuant to §57.105(4), Fla. Stat., and a §57.105 motion alleging that i abuse of process counterclaim was legally insufficient because it was based solely on the filing of an allegedly baseless complaint, and not on any post-issuance process.
+
+At a September 28, 2011 hearing on motion to dismiss Epstein's Second Amended Complaint, the Court expressed "serious concerns" as to whether Counterclaim stated a viable claim for abuse of process, and explained that abuse of process required improper use of process after it issued. (Hearing Tr. 9/28/2011 at 24-6).
+
+On October 4, 2011, filed an Amended Counterclaim for abuse of process (Count I) and malicious prosecution (Count II). The Amended Counterclaim alleged inter alia that: Epstein filed civil claims against and others to intimidate them (¶9); Epstein knew and knows that his prior Complaint had no factual support (1110-12); in filing and "continuing to prosecute each of the claims" against Edwards, Epstein acted maliciously and to extort into abandoning his claims against Epstein (114); and each pleading, motion, subpoena and request for production by Epstein was extortion and "constituted a perversion of process after its initial service." (116).
+
+On October 5, 2011, served the subject one-and-a-half—page §57.105 motion seeking sanctions based on Epstein's filing "a Notice of Intent to File a F.S. §57.105 motion seeking to sanction and his counsel for the prosecution of Counterclaim against Epstein." la entire argument is as follows (id.):
+
+> The assertion that the Counterclaim lacked factual and legal support is clearl s urious in light of the factual and legal support detailed in pending Motion for Summary Judgment and Motion to Assert Claim for Punitive Damages. Moreover, at
+
+the very same time that EPSTEIN takes the position in his §57.105 motion that claim is baseless, he has filed a Proposal for Settlement offering to pay hundreds of thousands of dollars to settle that same claim.
+
+### III. ARGUMENT
+
+## A. LEGAL STANDARDS
+
+Section 57.105(1), Fla. Stat., provides as follows:
+
+- (1) Upon the court's initiative or motion of any party, the court shall award a reasonable attorney's fee, including prejudgment interest, to be paid to the prevailing party in equal amounts by the losing party and the losing party's attorney on any claim or defense at any time during a civil proceeding or action in which the court finds that the losing party or the losing party's attorney knew or should have known that a claim or defense when initially presented to the court or at any time before trial:
+- (a) Was not supported by the material facts necessary to establish the claim or defense; or
+- (b) Would not be supported by the application of then-existing law to those material facts.
+
+Section 57.105(4), Fla. Stat., states:
+
+A motion by a party seeking sanctions under this section must be served but may not be filed with or presented to the court unless, within 21 days after service of the motion, the challenged paper, claim, defense, contention, allegation, or denial is not withdrawn or appropriately corrected.
+
+B. 57.105 MOTION IS IMPROPERLY I DIRECTED TO A NOTICE OF INTENT UNDER §57.105(4), KLA. STAT.
+
+§57.105 motion seeks sanctions based on the notice of intent that Epstein served on incorrectly states in his motion that Epstein filed his notice of intent. Section 57.105, Fla. Stat., however, does not authorize the imposition of sanctions based on the service of a notice of intent. Rather, the statute limits a §57.105 motion to seeking attorney's fees on the basis of an unsupportable "claim or defense." An unified notice of intent
+
+served pursuant to the statute's mandatory safe-harbor provision is not a "claim or defense." It is nothing more than a procedural condition precedent to seeking attorney's fees pursuant to the statute, and §57.105, by its terms, does not authorize a party to seek attorney's fees from an opposing party who has done nothing more than comply with the statute's notice of intent requirement. Indeed, if attorney's fees could be awarded solely on the basis of a notice of intent, the courts judicial system would become mired in endless rounds of retaliatory §57.105 motions. §57.105 motion would trigger a retaliatory §57.105 motion, and so on. Section §57.105, however, does not license such gamesmanship.
+
+## §57.105 MOTION IS FRIVOLOUS BECAUSE COUNTERCLAIM FOR ABUSE OF PROCESS FAILED TO STATE A VALID CLAIM FOR RELIEF
+
+Assuming arguendo that a §57.105 motion can properly be based on a notice of intent, §57.105 motion should still be denied because it is patently untenable. has not demonstrated that Epstein's notice of intent was frivolous when served, nor can he. To the contrary, as Epstein argued in his recently filed motion to dismiss, I= counterclaim for abuse of process is, and has always been, factually and legally unsupported. All that has demonstrated is that his own §57.105 motion is baseless.
+
+cannot credibly argue that Epstein's notice of intent was "clearly spurious" motion at 2) for at least two reasons. First, this Court expressed precisely the same "serious concerns" as to whether Counterclaim for abuse of process was viable (see Tr. 9/28, 2011 at 24-26) as those that Epstein raised in his notice of intent. Second, in response to the Court's "serious concerns," immediately amended his counterclaim for abuse of process. It is staggering that — one week after the Court vindicated Epstein's position that abuse of process claim was not actionable -- turned around and sought sanctions on the ground that Epstein's argument was "spurious." Given the inescapable fact that
+
+this Court effectively agreed with Epstein that abuse of process claim was legally insufficient, subsequent filing of a §57.105 motion directed to Epstein's notice of intent is abusive and sanctionable.
+
+## D. a §57.105 MOTION SHOULD BE STRICKEN BECAUSE IT DISCLOSES CONFIDENTIAL INFORMATION
+
+contends that he is entitled to §57.105 sanctions because Epstein "filed a Proposal for Settlement offering to pay hundreds of thousands of dollars to settle that claim." §57.105 motion should be denied and stricken on the additional ground that it improperly discloses the fact and general amount of Epstein's Proposal for Settlement. Fla. R. Civ. P. 1.442(i) states that "[e]vidence of a proposal . . . is admissible only in proceedings to enforce an accepted proposal or to determine the imposition of sanctions." (Emphasis added).' Thus, pursuant to Rule 1.442, the fact or amount of a proposal for settlement is confidential and may not be disclosed until the end of the case, and then only if the result is better than the proposal as provided by the Rule.
+
+a disclosure of confidential information in the public domain is impermissible and inexcusable, requiring denial of his §57.105 motion.
+
+Moreover, as and his attorneys are well aware, the making of a proposal for settlement does not indicate in any way that a claim has merit or that a §57.105 motion directed to that claim is without merit. Accordingly, Epstein's proposal for settlement is not probative of whether a abuse of process claim was actionable.
+
+Similarly, under §768.79, Fla. Stat., evidence of an offer of judgment is admissible "only in proceedings to enforce an accepted offer or to determine the imposition of sanctions under this section."
+
+**IV. CONCLUSION**
+
+Based upon the foregoing arguments and authorities, ██████ §57.105 motion should be denied.
+
+Respectfully submitted,
+
+![]()Joseph L. Ackerman, Jr.  
+Florida Bar No. 235954  
+██████ BURNETT, P.A.  
+901 ██████ Point West  
+777 South Flagler Drive  
+West Palm Beach, Florida 33401  
+Telephone: (561) 802-9044  
+Facsimile: (561) 802-9976  
+Attorneys for Jeffrey Epstein, Plaintiff
+
+and
+
+██████ E. Knight  
+Florida Bar. No. 607363  
+██████ BURNETT, P.A.  
+Espirito Santo Plaza, 14th Floor  
+1395 Brickell Avenue  
+Miami, Florida 33131  
+Telephone: (305) 789-9200  
+Facsimile: (305) 789-9201  
+Attorneys for Jeffrey Epstein, Plaintiff
+
+# CERTIFICATE OF SERVICE
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via U.S.
+
+Mail on this 28th day of October, 2011 to:
+
+Jack Scuola, Esq. Searcy Denney Scarola Barnhart & Shipley, P.A. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409
+
+Jack A. Goldberger, Esq. Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401-5012
+
+Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Ft. Lauderdale, FL 33301
+
+K
+
+O S
+
+\ -9 1 C) A B # Jo 7 p h L. Ackerman, Jr.

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marker2/court-epstein-v-rothstein/EFTA02770162/EFTA02770162.md

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+JEFFREY EPSTEIN,
+
+Plaintiff(s),
+
+vs.
+
+SCOTT ROTHSTEIN individually, J. individually, and L.M., individually,
+
+Defendant(s).
+
+### IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+CASE NO.: 502009CA040800XXXWBAG
+
+co° C co n-tr > x n n g —c. c), \_\_—hT, leC2 r -C3C
+
+# RE-NOTICE OF TAKING VIDA634/\EYOSITION -,rte
+
+TO: All counsel on the attached Counsel omI' t •
+
+0
+
+Co.
+
+0
+
+PLEASE TAKE NOTICE that the undersigned attorneys will take deposition(s) of:
+
+## NAME AND ADDRESS DATE AND TIME LOCATION
+
+Jeffrey Epstein November 14, 2011 Seamy Denney, et al 9:00 a.m. 2139 Palm Beach Lakes Boulevard, WPB
+
+VIDEOGRAPHER: To be arranged by Phipps Reporting
+
+r rn O
+
+upon oral examination before Phipps Reporting, a Notary Public; or any other officer authorized by law to take depositions in the State of Florida. The oral examination is being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the applicable Statutes or Rules.
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by  
+Fax and U.S. Mail to all Counsel on the attached list, this 27<sup>nd</sup> day of October, 2011.
+
+![]()Jack Scarola  
+Florida Bar No.: 169440  
+Searcy Denney Scarola Barnhart & Shipley  
+2139 Palm Beach Lakes Boulevard  
+West Palm Beach, Florida 33409  
+Phone: (561) 686-6300  
+Fax: (561) 383-9451  
+Attorney for [REDACTED] J. [REDACTED]
+
+cc: Phipps Reporting
+
+**E-TRANSCRIPT, ASCII, CD AND/OR DVD REQUESTED**
+
+**AMERICANS WITH DISABILITIES ACT**
+
+In accordance with the Americans With Disabilities Act, persons in need of a special accommodation to participate in this proceeding should contact the Human Resources Manager, Searcy Denney Scarola Barnhart & Shipley, P.A., no later than seven days prior to the proceeding. Please telephone (561) 686-6300.
+
+adv. Epstein Case No. 502009CA040800XXXXMBAG RE-Notice of Taking Video Deposition Page 3
+
+## COUNSEL LIST
+
+Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 Wcst Palm Beach, FL 33401 Phone: (561)-659-8300 Fax: (561)-835-8691
+
+\_,Jaffe, Wcissing, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954)-524-2820 Fax: (954)-524-2822
+
+L. Ackerman, Jr., Esquire Burnett, P.A. 901 Point West 777 S Flagler Drive West Palm Beach, FL 33401-6)70 Phone: (561)-802-9044 Fax: (561)402-9976
+
+Marc S. Nurik, Esquire marc@nuriklaw.com Law Offices of Marc S. Nurik Onc E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556

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marker2/court-epstein-v-rothstein/EFTA02770165/EFTA02770165.md

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+## IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+CASE NO.: 502009CA040800XXXXMBAG
+
+JEFFREY EPSTEIN,
+
+Plaintiff(s),
+
+vs.
+
+Or -o 91. r rn C
+
+SCOTT ROTHSTEIN, individually, J. L.M., individually, , individually, and
+
+Defendant(s).
+
+## NOTICE OF HEARIN\_ ACP
+
+YOU ARE HEREBY NOTIFIED that the undersigned has called up for hearing the following:
+
+DATE: November 9, 2011 ACcia:\*".
+
+TIME: 8:45 a.m.
+
+JUDGE: Honorable David F. (Palm Beach County Courthouse)
+
+PLACE: 205 N. Dixie Highway, West Palm Beach, FL 33401
+
+ROOM #:k
+
+## SPECIFISATTERS TO BE HEARD:
+
+PLAINTIFF JEFFREY EPSTEIN'S RENEWED MOTION FOR PROTECTIVE ORDER RELATING TO HIS DEPOSITION
+
+Moving counsel certifies that he or she contacted opposing counsel and attempted to resolve the dispute without hearing.
+
+[REDACTED] adv. Epstein  
+Case No.: 502009CA040800XXXXMBAG  
+Notice of Hearing
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by  
+Fax and U.S. Mail to all Counsel on the attached list, this 2<sup>nd</sup> day of November, 2011.
+
+![]()JACK SCAROLA  
+Florida Bar No.: 169440  
+Searcy Denney Scarola Barnhart & Shipley  
+2139 Palm Beach Lakes Boulevard  
+West Palm Beach, Florida 33409  
+Phone: (561) 686-6300  
+Fax: (561) 383-9451  
+Attorney for Bradley J. [REDACTED]
+
+[REDACTED] adv. Epstein  
+Case No.: 502009CA040800XXXXMBAG  
+Notice of Hearing
+
+### COUNSEL LIST
+
+Jack A. Goldberger, Esquire  
+jgoldberger@agwpa.com; smahoney@agwpa.com  
+Atterbury, Goldberger & Weiss, P.A.  
+250 Australian Avenue South, Suite 1400  
+West Palm Beach, FL 33401  
+Phone: (561)-659-8300  
+Fax: (561)-835-8691  
+Attorneys for Jeffrey Epstein
+
+[REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman, PL  
+425 N. Andrews Avenue, Suite 2  
+Fort Lauderdale, FL 33301  
+Phone: (954)-524-2820  
+Fax: (954)-524-2822  
+Attorneys for Jeffrey Epstein
+
+[REDACTED] L. Ackerman, Jr., Esquire  
+[REDACTED]; LRoberts@fowler-white.com  
+[REDACTED] Burnett, P.A.  
+901 [REDACTED] Point West  
+777 S Flagler Drive  
+West Palm Beach, FL 33401-6170  
+Phone: (561)-802-9044  
+Fax: (561)-802-9976  
+Attorneys for Jeffrey Epstein
+
+Marc S. Nurik, Esquire  
+marc@nuriklaw.com  
+Law Offices of Marc S. Nurik  
+One E Broward Blvd., Suite 700  
+Fort Lauderdale, FL 33301  
+Phone: (954)-745-5849  
+Fax: (954)-745-3556  
+Attorneys for Scott Rothstein
+
+"If you are a person with a disability who needs any accommodation in ?order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Krista Garber, Americans with Disabilities Act Coordinator, at least 7 days before your scheduled court appearance, or immediately upon receiving this !notification if the time before the scheduled appearance is less than 7 `days; if you are hearing or voice impaired, call 711."
+
+"Si usted es una persona minuswilida que neces n vSr ta algun acomodamiento para poder participar en este procedimiento, usted tiene derecho, sin tener gastos propios, a que sejskprovea cierta ayuda. Tenga la amabilidad de ponerse en contacto con Krista Garber Americans with Disabilities Act Coordinator" por lo menos 7 dias antes 'de la cita fijada para su comparftdripAy en los tribunales, o inmediatamente despues de recibir estinotificacion si el tiempo antes de ila comparecencia que se ha programado es menos de 7 dias; si usted tiene discapacitacion del oido o delve\* Ilame al 711."
+
+"Si ou se yon moun ki enfiyt ki bezwen akomodasyon pou w ka patisipe nan pwosedi sa, ou kalifY4san ou pa gen okenn lajan pou w peye, gen pwovizyon pou jwen kek ed. Tanpri kontakte nan 7 jou anvan dat ou 'gen randevou pou paret nan tribinal la, oubyen imedyatman apre ou fin resevwa konvoka an si le ou gen pou w paret nan tribinal la mwens ke 7 jou; si ott een oblem pou w tande oubyen pale, rele 711."

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marker2/court-epstein-v-rothstein/EFTA02770169/EFTA02770169.md

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+IN THE CIRCUIT COURT OF THE 15<sup>th</sup> JUDICIAL CIRCUIT  
+IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+CIVIL DIVISION AG  
+CASE NO. 502009CA040800XXXXMB  
+Judge David F. [REDACTED]
+
+JEFFREY EPSTEIN,
+
+Plaintiff/Counter-Defendant,
+
+v.
+
+SCOTT ROTHSTEIN, individually and  
+[REDACTED] J. [REDACTED], individually,
+
+Defendants/Counter-Plaintiffs.
+
+\_\_\_\_\_/
+
+SHARON R. BOCK, CLLER  
+PALM BEACH COUNTY, FL  
+CIRCUIT CIVIL
+
+FILED
+
+2011 NOV - 3 AM 10: 17
+
+**NOTICE OF SPECIAL SET HEARING**  
+**(30 Minutes)**
+
+**PLEASE TAKE NOTICE** that the undersigned has set down for hearing before the Honorable David F. [REDACTED], one of the Judges of the above-styled Court, in Courtroom 9C at the Palm Beach County Courthouse, 205 North Dixie Highway, West Palm Beach, Florida on Monday, November 21, 2011 at 9:30 a.m. for thirty minutes, the following:
+
+**PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS AMENDED COUNTERCLAIM AND INCORPORATED MEMORANDUM OF LAW**
+
+1. 1. The JA cannot cancel this hearing unless the issue is resolved.
+2. 2. No add-ons are permitted.
+3. 3. Any Memorandums submitted are limited to 10 double-spaced pages.
+4. 4. Any materials submitted are due at least 7 days prior to the hearing.
+5. 5. The moving party is required to bring to the hearing a blank proposed Order with copies and envelopes.
+
+I hereby certify that I have made a good faith attempt to resolve this matter prior to my noticing this Motion for hearing.
+
+PLEASE GOVERN YOURSELVES ACCORDINGLY.
+
+In accordance with the Americans With Disabilities Act, if you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Krista Garber, ADA Coordinator, in the Administrative Office of the Court, Palm Beach County Courthouse, 205 North Dixie Highway, Room 5.2500, West Palm Beach, Florida 33401; telephone number (561) 355-4380 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired call 711.
+
+## CERTIFICATE OF SERVICE
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via e-mail and U.S. Mail on this 3rd day of Novem 11 to: Jack Scarola, Esq., Searcy Denney Scarola et al., 2139 Palm Beach Lakes Roble West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger & ss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401-5012; and Marc S. Nurik, Esq., Law Offices of Marc S. Nurik, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301.
+
+> oseph L. Ackerman, Jr. Florida Bar No. 235954 BURNETT, P.A. Mort for PlaintiffJeffrey Epstein 901 Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: (561) 802-9044 Facsimile: (561) 802-9976

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marker2/court-epstein-v-rothstein/EFTA02770171/EFTA02770171.md

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+#### IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+Case No.: 50 2009CA 040800XXXXMBAG
+
+JEFFREY EPSTEIN,
+
+Plaintiff,
+
+vs..
+
+SCOTT ROTHSTEIN individually, and J. individually,
+
+Defendants,
+
+CG SCO '17 0 CD ▪ **r \_ Sri r C rl**  ✓lxt r
+
+Z'N
+
+m rn O
+
+#### DEFENDANT l ilLILLAI/ ikl ' RENEWED MOTION FOR FINAL SUMMARY JUDGMENT
+
+Defendant, J. MI, Esq., by and through his undersigned counsel and pursuant to Rule 1.510, Florida Ru es of Civil Procedure, hereby moves for Final Summary Judgment and in support thereo /SS follows:
+
+## L INTRODUCTION v•
+
+The pleadings and iscovery taken to date show that there is no genuine issue as to any material facts and that J. Esq. is entitled to summary judgment for all claims brought against him in Plaintiff Jeffrey Epstein's Second Amended Complaint. Not only is there an absence of competent evidence to demonstrate that participated in any fraud against Epstein, the evidence uncontrovertibly demonstrates the propriety of every aspect of EM involvement in the prosecution of legitimate claims against Epstein. Epstein sexually abused three clients of — L.M., E.W., and Jane Doe — and properly and successfully
+
+represented them in a civil action against Epstein. Nothing in capable and competent representation of his clients can serve as the basis for a civil lawsuit against him. Allegations about participation in or knowledge of the use of the civil actions against Epstein in a "Ponzi Scheme" are not supported by any competent evidence and could never be supported by competent evidence as they are entirely false.
+
+# A. Epstein's Complaint
+
+Epstein's Second Amended Complaint essentially alleges that Epstein was damaged by NM, acting in concert with Scott Rothstein (President of the Rothstein Rosenfeldt Adler law firm ("RRA") where worked for a short period of time). Epstein appears to allege that joined Rothstein in the abusive prosecution of sexual assault cases against Epstein to "pump" the cases to Ponzi scheme investors. As described by Epstein, investor victims were told by Rothstein that three minor girls who were sexually assaulted by Epstein: L.M., E.W., and Jane Doe were to be paid up-front money to prevent those girls from settling their civil cases against Epstein. In Epstein's view, these child sexual assault cases had "minimal value" (Complaint & 42(h)), and refusal to force his clients to accept modest settlement offers is claimed to breach some duty that owed to Epstein. Interestingly, Epstein never states that he actually made any settlement offers.
+
+The supposed "proof" of the Complaint's allegations against includes alleged contacts with the media, his attempts to obtain discovery from high-profile persons with whom Epstein socialized, and use of "ridiculously inflammatory" language in arguments in court. Remarkably, Epstein has filed such allegations against despite the fact that Epstein had sexually abused each of clients and others while they were minors. Indeed, in discovery Epstein has asserted his Fifth Amendment privilege rather than answer questions about the extent of the sexual abuse of his many victims. Even more remarkably, since filing his suit against M, Epstein has now settled the three cases handled for an amount that Epstein insisted be kept confidential. Without violating the strict confidentiality terms required by Epstein, the cases did not settle for the "minimal value" that Epstein suggested in his Complaint. Because Epstein relies upon the a darepancy between the "minimal value" Epstein ascribed to the claims and the subitattitl value sought to recover for his clients, the settlement amounts Epstein voluntarily agreed to pay while these claims against were pending will be disclosed to the court in-camera.
+
+## B. Summary of the Argument
+
+J. Esq., is entitled to summary judgment on Epstein's frivolous claim for at least three separate reasons.
+
+First, because Epstein has elected to hide behind the shield of his right against self incrimination to preclude his disclosing au relevant information about the criminal activity at the, center of his claims, he is barred from prosecuting this case against M. Under the well-established "sword and shield" doctrine, Epstein cannot seek damages from while at the same time asserting a Fifth Amendment privilege to block relevant discovery. His case must therefore be dismissed.
+
+Second, all of conduct in the prosecution of valid claims against Epstein is protected by the litigation privilege.
+
+Third, and most fundamentally, Epstein's lawsuit should be dismissed because it is not only unsupported by but is also directly contradicted by all of the record evidence. From the beginning, diligently represented three victims of sexual assaults perpetrated by Epstein. As explained in detail below, each and every one of litigation decisions was grounded in proper litigation judgment about the need to pursue effective discovery against Epstein, particularly in the face of Epstein's stonewalling tactics. successful representation finally forced Epstein to settle and pay appropriate damages. Effective and proper representation of child victims who have been repeatedly sexually assaulted cannot form the basis of a separate, "satellite" lawsuit, and therefore is entitled tocary judgment on these grounds as well.
+
+The truth is the record is entirely devoid of any evidnupport Epstein's claims and is completely and consistently corroborative of =I's sworn assertion of innocence. Put siniply, Epstein has made allegations that have no basis in fact. To the contrary, his lawsuit was merely a desperate measure by a serial pedophile to prevent being held accountable for repeatedly sexually abusing minor fe a . Epstein's ulterior motives in filing and prosecuting this lawsuit are blatantly obvio es behavior is another clear demonstration that he feels he lives above the law and that 1 5use of his wealth he can manipulate the system and pay for lawyers to do his dirty work - even to the extent of having them assert baseless claims against other members of the Florida Bar. Epstein's Second Amended Complaint against is nothing short of a far-fetched fictional fairy-tale with absolutely no evidence whatsoever to support his preposterous claims. It was his last ditch effort to escape the public disclosure by and his clients of the nature, extent, and sordid details of his life as a serial child molester. Motion for Summary Judgment should be granted without equivocation.
+
+#### ARGUMENT
+
+II. IS ENTITLED TO SUMMARY JUDGMENT ON EPSTEIN'S CLAIM BECAUSE THERE ARE NO MATERIAL DISPUTED FACTS AND THE UNDISPUTED FACTS ESTABLISH THAT CONDUCT COULD NOT POSSIBLY FORM THE BASIS OF ANY LIABILITY IN FAVOR OF EPSTEIN
+
+#### A. The Summary Judgment Standard.
+
+Rule 1.510(c), Florida Rules of Civil Procedure, provides that a court may enter summary judgment when the pleadings, depositions and factual showings reveal that there is no genuine issue of material fact and that the moving party is entitled to judgment as a matter of law. See v. Cheezem Development Corp., 373 So. 2d 719, 720 (Fla. 2d DCA 1979); Rule 1.510(c), Fla. R. Civ. P. Once the moving party conclusively establishes that the nonmoving party cannot prevail, it is incumbent on the nonmoving party to submit evidence to rebut the motion for summary judgment. See Ho!! v. Talcott, 191 So. 2d 40, 43 (Fla. 1966). It is not enough for the opposing party merely to assert that an issue of fact does exist. Fisel v. Wynns, 667 So.2d 761, 764 (F1a.1996); Landers v. Milton, 370 So.2d 368, 370 (Fla.1979) (same).
+
+Moreover, it is well-recognized that the non-moving party faced with a summary judgment motioned by appropriate proof may not rely on bare, conclusory assertions found in gs to create an issue and thus avoid summary judgment. Instead, the party must pr unter-evidence establishing a genuine issue of material fact. See v. Shands Teaching Hospital and Clinics, Inc., 479 So.2d 165, 168 (Fla. 1st Dist. Ct. App. 1985); see also Lanzner v. City of North Miami Beach, 141 So.2d 626 (Fla. 3d Dist Ct. App. 1962) (recognizing that mere contrary allegations of complaint were not sufficient to preclude summary judgment on basis of facts established without dispute). Where the nonmoving party fails to present evidence rebutting the motion for summary judgment and there is no genuine issue of material fact, then entry of judgment is proper as a matter of law. See v. Hathaway, 408 So. 2d 688, 689 (Fla. 2d Dist. Ct. App. 1982); see also Holl, 191 So. 2d at 43.
+
+# B. Epstein's Claim Reeardine Have Absolutely No Factual Basis.
+
+This is not a complicated case for granting summary judgment. To the contrary, this is a simple case for summary judgment because each and every one of Epstein's claim against lacks any merit whatsoever:
+
+- 1. Epstein's allegations regarding involvement in Rothstein's "Ponzi Scheme" are unsupported and unsupportable because he was simply not involved in any such scheme.
+
+## a. Had No Involvement in the Pont Scheme.
+
+The bulk of Epstein's claims against Edwards hinge on the premise that was involved in a Ponzi scheme run by Scott Rothstein. Broad allegations of wrongdoing on the part of are scattered willy-nilly throughout the complaint. None of the allegations provide any substance as to how actually assisted the Ponzi scheme, and allegations that he "knew or should have known" of its existence are based upon an impermissible pyramiding of inferences. In any event, these allegations all fail for one straightforward reason: was simply not involved in any Ponzi scheme. He has provided sworn testimony and an affidavit in support of that assertion, and there is not (and could never be) any contrary evidence.
+
+has now been deposed at length in this case. As his deposition makes crystal clear, he had no knowledge of any fraudulent activity in which Scott Rothstein may have been
+
+A decision by the Court to grant summary judgment on Epstein's claims against would not affect Epstein's claims against Scott Rothstein. Epstein has already chosen to dismiss all of his claims against L.M., the only other defendant named in the suit.
+
+involved. See, e.g., Depo. at 301-02 (Q: " . . . [W]ere you aware that Scott Rothstein was trying to market Epstein cases ... ?" A: "No.").
+
+has supplemented his deposition answers with an Affidavit that declares in no uncertain terms his lack of involvement in any fraud perpetrated by Rothstein. See, e.g., Affidavit attached to Statement of Undisputed Material Facts as Exhibit "N" at ¶8-10, 120, ¶22-23. Indeed, no reasonable juror could find that was involved in the scheme, as joined RRA well after Rothstein began his fraud and would have been already deeply in debt. In fact, the evidence of Epstein's crimes is now clear, and Edwards's actions in this case were entirely in keeping with his obligation to provide the highest possible quality of legal representation for his clients to obtain the best result possible.
+
+In view of this clear evidence rebutting all allegations against him, Epstein must now "produce counter-evidence establishing a genuine issue of material fact." See v. Shands Teaching Hospital and Clinics, Inc., 479 So.2d 165, 168 (Fla. 1st Dist. Ct. App. 1985). Epstein cannot do this. Indeed, when asked at his deposition whether he had any evidence of involvement, Epstein declined to answer, purportedly on attorney-client privilege grounds:
+
+', ant to know whether you have any knowledge of evidence that personally ever participated in devising a plan through which were sold purported confidential assignments of a structured payout settlement? . . .
+
+A. I'd like to answer that question by saying that the newspapers have reported that his firm was engaged in fraudulent structured settlements in order to fleece unsuspecting Florida investors. With respect to my personal knowledge, I'm unfortunately going to, today, but I look forward to at some point being able to disclose it, today I'm going to have to assert the attorney/client privilege.
+
+See Deposition of Jeffrey Epstein, Mar. 17, 2010 (hereinafter "Epstein Depo.") at 67-68. Therefore summary judgment should be granted for on all claims involving any Ponzi scheme by Rothstein.
+
+### b. Epstein's Allegations of Negligence by are Unfounded and Not Actionable in Any Event.
+
+In his Second Amended Complaint Epstein recognizes at least the possibility that was not involved in any Rothstein Ponzi scheme. Therefore, seemingly as a fallback, Epstein alleges without explanation that "should have known" about the existence of this concealed Ponzi scheme. Among other problems, this fallback negligence position suffers the fatal flaw that it does not link at all to the intentional tort of abuse of process alleged in the complaint.
+
+Epstein's negligence claim is also deficient tQ ft) • simply fails to satisfy the requirements for a negligence cause of action: c
+
+"Four elements are necessary to stistaitka gligence claim: 1. A duty, or obligation, recognized by the law, requiring the [defendant] to conform to a certain standard of conduct, for the protection of others against unreasonable risks. 2. A failure on the [defendant's] part to conform to the standard required: a breach of the duty . . . . 3. A reasonably close causal connection between he conduct and the resulting injury. This is what is commonly known as 'legal cause,' or 'proximate cause,' and which includes the notion of cause in fact. 4. Actual loss or damage.
+
+Curd v. Mosaic Fertilizer, LLC, So.2d , 2010 WL 2400384 at \*9 (Fla. 2010). Epstein does not allege a particular duty on the part of that has been breached. Nor does Epstein explain how any breach of the duty might have proximately caused him actual damages. Summary judgment is therefore appropriate for these reasons as well.
+
+Finally, for the sake of completeness, it is worth noting briefly that no reasonable jury could find to have been negligent in failing to anticipate that a managing partner at his law firm would be involved in an unprecedented Ponzi scheme. Scott Rothstein deceived not
+
+only but also more than 60 other reputable lawyers at a major law firm. Cf . Sun Sentinel, Fort Lauderdale, Dec. 11, 2009, 2009 WLNR 25074193 at \*1 ("Sure, some outlandish John Grisham murder plot[s] sound far-fetched. But if you asked me a few months ago if Scott Rothstein was fabricating federal court orders and forging a judge's signature on documents to allegedly fleece his friends, as federal prosecutors allege, I would have said that was far-fetched, too."). No reasonable lawyer could have expected that a fellow member of the bar would have been involved in such a plot. Nobody seemed to know of Rothstein's Ponzi scheme, not even his best friends, or the people he did business with on a daily basis, or even his wife. Many of the attorneys at RRA had been there for years and knew nothing. was a lawyer at RRA for less than 8 months and had very few personal encounters with Rothstein during his time at the firm, yet Epstein claims that he should have known of Rothstein's intricate Ponzi scheme. No doubt for this reason the U.S. Attorney's Office has now listed as a "victim" of Rothstein's crimes. See Statement of Undisputed Facts filed contemporaneously.
+
+Epstein's Complaint does not offer any specific reason why a jury would conclude that was negligent, and he chose not to offer any explanation of his claim at his deposition. Accordingly, is entitled to summary judgment to the extent the claim against him is somehow dependent upon his negligence in failing to discover Rothstein's Ponzi scheme.
+
+- 2. is Entitled to Summary Judgment to the Extent the Claim Against Him is Dependent on Allegations Regarding "Pumping the Cases" Because He Was Properly Pursuing the Interests of His Three Clients Who Had Been Sexually Abused by Epstein.
+
+Epstein alleges that somehow improperly enhanced the value of the three civil cases he had filed against Epstein. represented three young women — L.M., E.W., and Jane Doe — by filing civil suits against Epstein for his sexual abuse of them while they were
+
+minors. Epstein purports to find a cause of action for this by alleging that was involved in "'pumping' these three cases to investors." somehow
+
+As just explained, to the extent that Epstein is alleging that somehow did something related to the Ponzi scheme, those allegations fail for the simple reason that was not involved in any such scheme. for example, could not have possibly "pumped" the cases to investors when he never participated in any communication with investors.
+
+Epstein's "pumping" claims, however, fail for an even more has' was entitled — indeed ethically obligated as an attorney — to secure the axi um recovery for his clients during the course of his legal representation. As own, "[a]s an advocate, a lawyer zealously asserts the client's position under the 1 ,f the adversary system." Fla. Rules of Prof. Conduct, Preamble. therefo7N uired to pursue (unless otherwise instructed by his clients) a maximum recovery against Epstein. therefore, cannot be liable for doing something that his ethical duties as an attorney required?
+
+Another reason that Epstein's claims that was "pumping" cases for investors fails is that filed all three cases almost a year before he was hired by RRA or even knew of Scott Rothstein. Epstein makes allegations that the complaints contained sensational allegations for the purposes of luring investors; however, language in the complaints remained virtually uncbanged from the first filing in 2008 and from the overwhelming evidence the Court can see for itself that all of the facts alleged by in the complaints were true.
+
+Epstein ultimately paid to settle all three of the cases filed against him for more money than he paid to settle any of the other claims against him. At Epstein's request, the terms
+
+<sup>2</sup> In a further effort to harass MI, Epstein also filed a bar complaint with the Florida Bar against The Florida Bar has dismissed that complaint. See Statement of Undisputed Facts.
+
+of the settlement were kept confidential. The sum that he paid to settle all these cases is therefore not filed with this pleading and will be provided to the court for in-camera review. Epstein chose to make this payment as the result of a federal court ordered mediation process, which he himself sought (over the objection of Jane Doe, client in federal court) in an effort to resolve the case. See Defendant's Motion for Settlement Conference, or in the Alternative, Motion to Direct Parties back to Mediation, Doe v. Epstein, No. 9:08-CV-80893 (S.D. Fla. June 28, 2010) (Marra, J.) (doc. #168) attached hereto as Exhibit "A". Notably, Epstein sought this settlement conference — and ultimately made his payments as a result of that conference - in July 2010, more than seven months after he filed this lawsuit against Accordingly, Epstein could not have been the victim of any scheme to "pump" the cases against him, because he never paid to settle the cases until well after had left RRA and had severed all connection with Scott Rothstein (December 2009).
+
+In addition, if Epstein had thought that there was some improper coercion involved in, for example, Jane Doe's case, his remedy was to raise the matter before Federal District Court Judge Kenneth A. Marra who was presiding over the matter. Far from raising any such claim, Epstein simply chose to settle that case. He is therefore now barred by the doctrine of its judicata from somehow re-litigating what happened in (for example) the Jane Doe case. "The doctrine of res judicata makes a judgment on the merits conclusive 'not only as to every matter which was offered and received to sustain or defeat the claim, but as to every other matter which might with propriety have been litigated and determined in that action." AMEC Civil, LLC v. State Dept. of Tranip., So.2d -, 2010 WL 1542634 at \*2 (Fla. Ist Dist. Ct. App. 2010) (quoting Kimbrell v. Paige, 448 So.2d 1009, 1012 (Fla. 1984). Obviously, any question of improper "pumping" of a
+
+particular case could have been resolved in that my case rather than now re-litigated in satellite litigation.
+
+#### 3. is Entitled to Summary Judgment on the Claim of Abuse of Process Because He Acted Properly Within the Boundaries of the Law In Pursuit of the Legitimate Interests of his Clients.
+
+Epstein's Second Amended Complaint raises several claims of "abuse of process." An abuse of process claim requires proof of three elements: "(1) that the defendant made an illegal, improper, or perverted use of process; (2) that the defendant had ulterior motives or purposes in exercising such illegal, improper, or perverted use of process; and (3) that, as a result of such action on the part of the defendant, the plaintiff suffered damage. " S & I Investments v. Payless Flea Market, Inc., 36 So.3d 909, 917 (Fla. 4th Dist. Ct. App. 2010) (internal citation omitted). In fact, this Court is very familiar with this cause of action, as has correctly stated this cause in his counterclaim against Epstein. Edwards is entitled to summary judgment because Epstein cannot prove these elements.
+
+The first element of an abuse of process claim is that a defendant made "an illegal, improper, or perverted use of process." On the surface, Epstein's Complaint appears to contain several allegations of such improper process. On examination, however, each of these allegations amounts to nothing other than a claim that Epstein was unhappy with some discovery proceeding, motion or argument made by M. This is not the stuff of an abuse of process claim, particularly where Epstein fails to allege that he was required to do something as the result of pursuit of the claims against him. See Marty v. Gresh, 501 So.2d 87, 90 (Fla. Ist Dist. Ct. App. 1987) (affirming summary judgment on an abuse of process claim where "appellant's lawsuit caused appellee to do nothing against her will").
+
+In any event, none of the allegations of "improper" process can survive summary judgment scrutiny, because every action took was entirely proper and reasonably calculated to lead to the successful prosecution of the pending claims against Epstein as detailed in Affidavit.
+
+Epstein also fails to meet the second element of an abuse of process claim: that had some sort of ulterior motive. The case law is clear that on an abuse of process claim a "plaintiff must prove that the process was used for an immediate purpose other than that for which it was designed." S&I Investments v. Payless Flea Market, Inc., 36 So.3d 909, 917 (Fla. 4th Dist. Ct. App. 2010) (citing Biondo v. Powers, 805 So.2d 6i, 69 (Fla. 4th Dist. Ct. App. 2002). As a consequence, "[wjhere the process was used to accomplish the result for which it was intended, regardless of an incidental or concurrent motive of spite or ulterior purpose, there is no abuse of process." Id. (internal quotation omitted). Here, has fully denied any improper motive, See Statement of Undisputed Facts, and Epstein has no evidence of any such motivation. Indeed, it is revealing that Epstein chose not to ask even a single question about this subject during the deposition of In addition, all of the actions that Epstein complains about were in fact used for the immediate purpose of furthering the lawsuits filed by L.M., E.W., and Jane Doe. In other words, these actions all were both intended to accomplish and, in fact, successfully "accomplished the results for which they were intended" -- whether it was securing additional discovery or presenting a legal issue to the court handling the case or ultimately maximizing the recovery of damages from Epstein on behalf of his victims. Accordingly, is entitled to summary judgment on any claim that he abused process for this reason as well.
+
+- 4. is Entitled to Summary Judgment to the Extent His Claim is Based On Pursuit of Discovery Concerning Epstein's Friends Because All Such Efforts Were Reasonably Calculated to Lead to Relevant and Admissible Testimony About Epstein's Abuse of Minor Girls.
+
+Epstein has also alleged that improperly pursued discovery from some his close friends. Such discovery, Epstein claims, was improper because knew that these individuals lacked any discoverable information about the sexual assault cases against Epstein.
+
+Here again, is entitled to summary judgment, as each of the friends of Epstein were reasonably believed to possess discoverable information. The undisputed facts show the following with rcgard to each of the persons raised in Epstein's complaint:
+
+- With regard to Donald Trump, had sound legal basis for believing Mr. Trump had relevant and discoverable information. See Statement of Undisputed Facts.
+- With regard to Alan Dershowl\* Law Professor), had sound legal basis for believing Mr. Dershowitz had relevant and discoverable information. See Statement of Undisputed Facts.
+- With regard to former President Bill Clinton, had sound legal basis for believing former President Clinton had relevant and discoverable information. See Statement of Undisputed Facts.
+- With regard to former Sony Record executive Tommy Mottola, was not the attorney that noticed Mr. Mottola's deposition. See Statement of Undisputed FadtS\\_ Wit regard to illusionist David Copperfield, had sound legal basis for elieving Mr. Copperfield had relevant and discoverable information. See tatement of Undisputed Facts.
+- With regard to former New Mexico Governor Bill had sound legal basis for naming Former New Mexico Governor Bill on his witness list. See Statement of Undisputed Facts.
+
+It is worth noting that the standard for discovery is a very liberal one. To notice someone for a deposition, of course, it is not required that the person deposed actually end up producing admissible evidence. Otherwise, every deposition that turned out to be a false alarm would lead to an "abuse of process" claim. Moreover, the rules of discovery themselves provide that a deposition need only be "reasonably calculated to lead to the discovery of admissible evidence." Fla. R. Civ. P. 1.280(b) (emphasis added).
+
+Moreover, the discovery that pursued has to be considered against the backdrop of Epstein's obstructionist tactics. As the Court is aware, in both this case and all other cases filed against him, Epstein has asserted his Fifth Amendment privilege rather than answer any substantive questions. Epstein has also helped secure attorneys for his other household staff who assisted in the process of recruiting the minor girls, who in turn also asserted their Fifth Amendment rights rather than explain what happened behind closed doors in Epstein's mansion in West Palm Beach. See Statement of Undisputed Facts. It is against this backdrop that followed up on one of the only remaining lines of inquiry open to him: discovery aimed at Epstein's friends who might have position to corroborate the fact that Epstein was sexually abusing young girls.
+
+In the context of the sext721 essault cases that had filed against Epstein, any act of sexual abuse had undeniable relevance to the case — even acts of abuse Epstein committed against minor girls other than L.M., E.W., or Jane Doe. Both federal and state evidence rules make acts of child abuse against other girls admissible in the plaintiff's case in chief as proof of "modus operandi" or "motive" or "common scheme or plan." See Fed. R. Evid. 415 (evidence of other acts of sexual abuse automatically admissible in a civil case); Fla. Stat. Ann. 90.404(b) (evidence of common scheme admissible); v. State, 110 So.2d 654 (Fla. 1959) (other acts of potential sexual misconduct admissible).
+
+A second reason exists for making discovery of Epstein's acts of abuse of other minor girls admissible. Juries considering punitive damages issues are plainly entitled to consider "the existence and frequency of similar past conduct." TXO Production Corp. v. Alliance Resources Corp., 509 U.S. 443, 462 n.28 (1993). This is because the Supreme Court recognizes "that a recidivist may be punished more severely than a first offender .. . [because] repeated misconduct is more reprehensible than an individual instance of malfeasance." BMW of North America, Inc. v. Gore, 517 U.S. 559, 577 (1996) (supporting citations omitted). In addition, juries can consider other similar acts evidence as part of the deterrence calculation in awarding punitive damages, because "evidence that a defendant has repeatedly engaged in prohibited conduct while knowing . . . that it was unlawful would provide relevant supped for an, argument that strong medicine is required to cure the defendant's disrespect for the law." Id. at 576-77. In the cases filed against Epstein, his clients were entitled to attempt to prove that Epstein "repeatedly engaged in prohibited conduct" — i.e., because he was a predatory pedophile, he sexually assaulted dozens and dozens of minor girls. The discovery of Epstein's friends who might have had direct or circumstantial evidence of other acts of sexual assault was accordingly entirely proper. is therefore entitled summary judginent to the extent his claim is based on efforts by Edwards to obtain discovery of Epstein's friends.
+
+#### III EPSTEIN'S LAWSUIT MUST BE DISMISSED BECAUSE OF HIS REFUSAL TO PARTICIPATE IN REASONABLE DISCOVERY.
+
+As is readily apparent from the facts of this case, Epstein has filed a lawsuit but then refused to allow any real discovery about the merits of his case. Instead, when asked hard questions about whether he has any legitimate claim at all, Epstein has hidden behind the Fifth
+
+Amendment. As a result, under the "sword and shield doctrine" widely recognized in Florida caselaw, his suit must be dismissed.
+
+"[T]he law is well settled that a plaintiff is not entitled to both his silence and his lawsuit." Boys & Girls Clubs of Marion County, Inc. v.14., 22 So.3d 855, 856 (Fla. 5th Dist. Ct. App. 2009) ( J., concurring specially). Thus, "a person may not seek affirmative relief in a civil action and then invoke the fifth amendment to avoid giving discovery, using the fifth amendment as both a 'sword and a shield.'" DePalma v. DePalma, 538 So.2d 1290, 1290 (Fla. 4th Dist. Ct. App. 1989) (quoting DeLisi v. Bankers Insurance Co., 436 So.2d 1099 (Fla. 4th Dist. Ct. App. 1983)). Put another way, la] civil litigant's fifth amendment right to avoid selfincrimination may be used as a shield but not a sword. This means that a plaintiff seeking affirmative relief in a civil action may not invoke the fifth amendment and refuse to comply with the defendant's discovery requests, thereby thwarting the defendant's defenses." Rollins Burdick Hunter of New York, Inc. v. Euroclas Sted, Inc., 502 So. 2d 959 (Fla. r <sup>d</sup> Dist. Court App. 1983).
+
+Here, Epstein is trt'ng " 34"/to recisely what the "well settled" law forbids. Specifically, he is trying to obtain "a ative relief' — i.e., forcing to pay money damages — while simultaneously precluding from obtaining legitimate discovery at the heart of the allegations that form the basis for the relief Epstein is seeking. As recounted more fully in the statement of undisputed facts, Epstein has refused to answer such basic questions about his lawsuit as:
+
+- "Wally what are the allegations against you which you contend Mr. ginned up?"
+- "Well, which of Mr. cases do you contend were fabricated?"
+
+- "Is there anything in L.M.'s Complaint that was filed against you in September of 2008 which you contend to be false?"
+- "I would like to know whether you ever had any physical contact with the person referred to as Jane Doe in that [federal] complaint?"
+- "Did you ever have any physical contact with E.W.?"
+- "What is the actual value that you contend the claim of E.W. against you has?"
+
+The matters addressed in these questions are the central focus of Epstein's claims against IMM. Epstein's refusal to answer these and literally every other substantive question put to him in discovery has deprived of even a basic understanding of the evidence alleged to support claims against him. Moreover, by not offering any explanation of his allegations, Epstein is depriving of any opportunity to conduct third party discovery and opportunity to challenge Epstein's allegations.
+
+It is the clear law that "the chief purpose of our discovery rules is to assist the truthfinding function of our justice system and to avoid trial by surprise or ambush," Scipio v. State, 928 So.2d 1138 (Fla.2006), and "full and fair discovery is essential to these important goals," McFadden v. State, 15 So.3d 755, 757 (Fla. 4i° Dist. Ct. App. 2009). Accordingly, it is important for the Court to insure "not only compliance with the technical provisions of the discovery rules, but also adherence to the purpose and spirit of those rules in both the criminal and civil context." McFadden, 15 So.3d at 757. Epstein has repeatedly blocked "full and fair discovery," requiring dismissal of his claim against
+
+#### IV. IS ENTITLED TO ADVERSE INFERENCES FROM EPSTEIN'S INVOCATION OF THE FIFTH AMENDMENT AND THEREFORE TO SUMMARY JUDGMENT ON EPSTEIN'S CLAIM.
+
+is entitled to summary judgment on the claim against him for a second and entirely independent reason: Epstein's repeated invocations of the Fifth Amendment raise adverse inferences against him that leave no possibility that a reasonable factfinder could reach a verdict in his favor. In ruling on a summary judgment motion, the court must fulfill a "gatekeeping function" and should ask whether "a reasonable trier of fact could possibly" reach a verdict in favor of the plaintiff. Willingham v. City of Orlando, 929 So.2d 43, 48 (Fla. 5th Dist. Ct. App. 2006) (emphasis added). Given all of the inferences that are to be drawn against Epstein, no reasonable finder of fact could conclude that Epstein was somehow the victim of improper civil lawsuits filed against him. Instead, a reasonable, finder of fact could only find that Epstein was a serial molester of children who was being held accountable through legitimate suits brought by and others on behalf of the minor girls that Epstein victimized.
+
+"[I]t is well-settled that the Fifth Amendment does not forbid adverse inferences against parties to civil actions when they refuse to testify in response to probative evidence offered against them." Baxter v. Palmigiano, 425 U.S. 308, 318 (1976); accord Vasquez v. State, 777 So.2d 1200, 1203 (Fla. App. 2001). The reason for this rule "is both logical and utilitarian. A party may not trample upon the rights of others and then escape the consequences by invoking a constitutional privilege — at least not in a civil setting." Fraser v. Security and Inv. Corp., 615 So.2d 841, 842 (Fla. 4th Dist. Ct. App. 1993). And, in the proper circumstances, "'Silence is often evidence of the most persuasive character." Fraser v. Security and Inv. Corp., 615 So.2d
+
+In the circumstances of this case, a reasonable finder of fact would have "evidence of the most persuasive character" from Epstein's repeated refusal to answer questions propounded to him. To provide but a few examples, here are questions that Epstein refused to answer and the reasonable inference that a reasonable finder of fact would draw:
+
+- Question not answered: "Specifically what are the allegations against you which you contend Mr. ginned up?" Reasonable inference: No allegations against Epstein were ginned up.
+- Question not answered: "Well, which of Mr. cases do contend were fabricated?" Reasonable inference: No cases filed by against Epstein were fabricated.
+- Question not answered: "Did sexual assaults ever take place on a private airplane on which you were a passenger?" Reasonable inference: Epstein was on a private airplane while sexual assaults were taking place.
+- Question not answered: "How many minors have you procured for prostitution?" Reasonable inference: Epstein has procured multiple minors for prostitution.
+- Question not answered: "Is there anything in L.M.'s Complaint that was filed against you in September of 2008 which you contend to be false?" Reasonable inference: Nothing in L.M.'s complaint filed in September of 2008 was false i.e., as alleged in L.M.'s complaint, Epstein repeatedly sexually assaulted her while she was a minor and she was entitled to substantial compensatory and punitive damages as a result.
+- Question not answered: "I would like to know whether you ever had any physical contact with the person referred to as Jane Doe in that [federal] complaint?" Reasonable inference: Epstein had physical contact with minor Jane Doe as alleged in her federal complaint.
+- Question not answered: "Did you ever have any physical contact with E.W.?" Reasonable inference: Epstein had physical contact with minor E.W. as alleged in her complaint.
+- Question not answered: "What is the actual value that you contend the claim of
+
+E.W. against you has?" Reasonable inference: E.W.'s claim against Epstein had substantial actual value.
+
+Without repeating each and every invocation of the Fifth Amendment that Epstein has made and the reasonable inferences to be drawn from those invocations of privilege, the big picture is unmistakably clear: No reasonable finder of fact could rule in Epstein's favor on his claims against M. Accordingly, is entitled to summary judgment based on the Fifth Amendment inferences that the jury would draw.
+
+The inferences against Epstein are not limited to those arising from his privilege assertions. Epstein's guilt is also reasonably inferred from his harassment of, intimidation of, efforts to exercise control over, and limitation of access ses who might testify against him.
+
+Epstein's efforts to intimidate his vic ' 4ort the inference that Epstein knew that they were going to provide compelling testim y against him. The evidence that Epstein tampered with witnesses (later designated as his accomplices and co-conspirators) will be admissible to demonstrate his consciousness of guilt. "[1]t is precisely because of the egregious nature of such conduct that the law expressly permits the jury to make adverse inferences from a party's efforts to 4nticdate witnesses . . . ." Jost v. Ahmad, 730 So.2d 708, 711 (Fla. 2nd Dist. Ct. App. 1 ) (i ernal quotation omitted). To be clear, Epstein's attempt to tamper with witne of simply admissible as impeachment evidence of the tampering party's credibility. The opposing party is entitled to introduce facts regarding efforts to intimidate a witness as substantive evidence." Id. at 711 (emphasis in original) (internal citation omitted). This substantive evidence of Epstein's witness intimidation provides yet another reason why no reasonable jury could find in favor of his claims against
+
+## V. IS ENTITLED TO SUMMARY JUDGMENT ON THE BASIS OF HIS AFFIRMATIVE DEFENSE OF PRIVILEGE
+
+Absolute immunity must be afforded any act occurring during course of judicial proceeding, regardless of whether act involves defamatory statement or other tortious behavior, such as tortious interference with business relationship, so long as act has some relationship to proceeding. See Levin, Middlebrooks, Mabie, Mayes & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994). The immunity afforded to statements made during the course of a judicial proceeding extends not only to the parties in a proceeding but to judges, witnesses, and counsel as well. Id. The litigation privilege applies in all causes of action, whether for commonlaw torts or statutory violations. See Echevarria, McCalla, Raymer, & Frappier v.., 950 So. 2d 380 (Fla. 2007). Defamatory statements made by lawyer while interviewing a witness in preparation for and connected to pending litigation are covered by the absolute immunity conferred by the litigation privilege. See DelMonico v. Traynor, 50 So. 3d 4 (Fla. Dist. Ct. App. 4th Dist. 2010), review granted, 47 So. 3d 1287 (Fla. 2010). The privilege extends to statements in judicial proceedings or those "necessarily preliminary thereto. See Stewart v. Sun Sentinel Co., 695 So.2d 360 (Fla. 4th DCA 1997)(an attorney's delivery of a copy of a notice of claim to a reporter, which notice was a required filing prior to instituting suit, was protected by absolute immunity).
+
+#### CONCLUSION
+
+For all the foregoing reasons, defendant, the Court should grant defendant J. M , Esq., summary judgment in his favor on the only remaining claim filed against him by plaintiff Jeffrey Epstein, and any other relief that the Court deems just and proper.
+
+**CERTIFICATE OF SERVICE**
+
+**I HEREBY CERTIFY** that on November 3rd, 2011 a copy of the foregoing has been served via Fax and U.S. Mail to all those on the attached service list.
+
+Jack Scarola  
+Searcy, Denney, Scarola, Barnhart & Shipley  
+2139 Palm Beach Lakes Blvd  
+West Palm Beach, FL 33409  
+(561) 686-6300  
+(561) 684-5816 (fax)
+
+By:
+
+![]()JACK SCAROLA  
+Florida Bar No.: 169440
+
+**SERVICE LIST**
+
+[REDACTED] E. Knight, Esq.  
+[REDACTED] L. Ackerman, Esq.  
+[REDACTED] BURNETT P.A.  
+901 [REDACTED] Point West  
+777 South Flagler Drive  
+West Palm Beach, FL 33401
+
+Jack Alan Goldberger, Esq.  
+Atterbury Goldberger et al.  
+250 Australian Avenue South  
+Suite 1400  
+West Palm Beach, FL 33401
+
+Marc S. Nurik, Esq.  
+Law Offices of Marc S. Nurik  
+One E. Broward Blvd., Suite 700  
+Fort Lauderdale, FL 33301
+
+Gary M. [REDACTED], Jr.  
+[REDACTED], Jaffe, Weissing,  
+[REDACTED], Fistos & Lehrman, P.L.  
+425 N. Andrews Ave., Suite 2  
+Fort Lauderdale, FL 33301
+
+NOTA CERTIFIED COPY

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marker2/court-epstein-v-rothstein/EFTA02770195/EFTA02770195.md

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+## IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F.
+
+JEFFREY EPSTEIN,
+
+Plaintiff/Counter-Defendant,
+
+v.
+
+SCOTT ROTHSTEIN individually and J. individually,
+
+Defendants/Counter-Plaintiffs.
+
+## NOTICE OF HE (Uniform Motion Calendar)
+
+PLEASE TAKE NOTICE that the undersigned has set down for hearing before the Honorable David F. M, one of the Judges of the above-styled Court, in Courtroom 9C at the Palm Beach County Courthouse, 205 North Dixie Highway, West Palm Beach, Florida on Wednesday, November 9, 2011 at 8:45 a.m., the following:
+
+## PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR CLARIFICATION REGARDING DISCOVERY
+
+I hereby certify that I have made a good faith attempt to resolve this matter prior to my noticing this Motion for hearing.
+
+PLEASE GOVERN YOURSELVES ACCORDINGLY.
+
+C V. rr n • 55 wC' P12 c>x• Ag t., CF --• :cf.; r-=
+
+r rn O
+
+In accordance with the Americans With Disabilities Act, if you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Krista Garber, ADA Coordinator, in the Administrative Office of the Court, Palm Beach County Courthouse, 205 North Dixie Highway, Room 5.2500, West Palm Beach, Florida 33401;
+
+telephone number (561) 355-4380 at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired call 711.
+
+## CERTIFICATE OF SERVICE
+
+An Altic I HEREBY CERTIFY that a true and correct copy of the foregoing sent via e-mail and U.S. Mail on this 4th day of November, 2011 to: Jack Scarola, Esq., Searcy Denney Scarola et al., 2139 Palm Beach Lakes Boulevard, West Palm Beach, FL 33409; lack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West "Palm Beach, FL 33401-5012; and Marc S. Nurik, Esq., Law Offices of Marc S. Nurik, One East Broward Boulevard, Suite 700, Fort Lauderdal s Plc)01. .
+
+> L. c rman, Jr. Florida Bar No. 235954 BURNETT, P.A. Attormor Plaintiff Jeffrey Epstein 901 Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: (561) 802-9044 Facsimile: (561) 802-9976

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marker2/court-epstein-v-rothstein/EFTA02770197/EFTA02770197.md

@@ -0,0 +1,77 @@
+## IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F.
+
+JEFFREY EPSTEIN,
+
+Plaintiff/Counter-Defendant,
+
+v.
+
+SCOTT ROTHSTEIN individually and J. individually,
+
+Defendants/Counter-Plaintiffs.
+
+/
+
+PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR CLARIFICATION REGARDING DISCOVERY
+
+T1 F
+
+Plaintiff/Counter-Defendant JEFFREY EPSTEIN ("Epstein"), by and through undersigned counsel, hereby moves for clarification of prior court directives regarding a stay of discovery until the pleadings are at issue. The grounds for this Motion are as follows:
+
+1. Initially on March 30, 2011, this Court entered an Order staying the issuance of subpoenas directed to the Trustee in the RRA bankruptcy. At that time, the court stated the pleadings needed to be addressed and directed Epstein to file an Amended Complaint.
+
+2. On July 13, 2011 at the hearing on Defendant Mt C' Motion to Dismiss the Amended Complaint, this Court stated that it "want[ed] to get a complaint out there that withstands the motion to dismiss before we go into all these privilege issues." (Hr'g Tr. 7/13/2011 at 155). The Court has also expressed the need to get the pleadings at issue before addressing discovery objections and other discovery issues.
+
+3. At the hearing on September 28, 2011 on Motion to Dismiss the Second Amended Complaint, this Court reiterated that it wanted to get the issues in the pleadings resolved before addressing discovery issues. The Court also expressed its concern over the viability of Counterclaim and wanted its viability addressed before hearing Motion to Add a Claim for Punitive. Damages. also has initiated and wishes to initiate discovery as more fully described below.
+
+4. • Now that Motion to Dismiss Epstein's Second Amended Complaint has • - • , been denied, Epstein wishes to proceed with discovery directed to his Second Amended Complaint, but is unsure if he can in light of the Court's stated intent to get the pleadings at issue first.
+
+5. Epstein would like to address some limited privilege issues:
+
+(a) has inappropriately claimed privileges relating to approximately' 198 communications with a "Confidential Source," a fictitious category of privilege created by which is not supported by law. There is no privilege for a private party in civil cases for a confidential source. See Fla. Stat. § 90.501 et seq. There is First Amendment privilege limited to journalists to protect their confidential sources. See Fla. Stat. § 90.5015. Therefore, Epstein would like to set for hearing a motion to compel the identification of "Confidential Source."
+
+(b) The Privilege Log does not identify the recipients of an alleged privileged communication with "Confidential Source," "RRA Staff," and "RRA Personnel." Such identifications violate a court order requiring compliance with the requirements for a Privilege Log set forth in TIG Insurance Corporation ofAmerica (TIG) v. M, 799 So.2d 339 (Fla. 4'h
+
+DCA 2001) to identify the parties to an alleged privilege communication. Consequently, Epstein would like to set a motion directed toward the sufficiency of the Privilege Log.
+
+6. Epstein wishes to proceed with discovery of 1= 1 alleged damages, but the Motion to Dismiss the Amended Counterclaim is pending, and Epstein is unclear whether those discovery requests should wait until that pleading is at issue.
+
+7. has filed an Amended Counterclaim and a Motion to Dismiss is presently pending. Epstein respectfully submits that discovery issues which presently wishes to pursue must wait until the Court determines if the Amended Counterclaim withstands Epstein's Motion to Dismiss.
+
+8. Presently, seeks to re-depose Epstein. At the hearing on July 13, 2011, this matter was deferred pending getting the pleadings to issue. Given the areas of inquiry wants to address in a follow-up deposition based on the Amended Counterclaim, Epstein submits Epstein's deposition should be postponed until MI Amended Counterclaim withstands a Motion to Dismiss, if it can. The trial court can and should stay discovery pending ruling on dispositive motions. Capco Properties, LLC v. Monterey Gardens of Pinecrest Condominium, 982 Sold 1211, 1215 (Fla. 3 DCA 2008); Chudasama v. Mazda Motor Corp., 123 F.3d 1353, 1368 (11th Cir. 1997).
+
+9. wants to depose individuals who Epstein believes do not have information bearing on the issues as presently framed. Those individuals are Ghislainc Maxwell, Howard Rubenstein, Ave = and Alan Dershowitz, who claims have information regarding victim issues, which allegedly took place before the present litigation. The relevancy
+
+of victim issues and extent of discovery into victim issues need to be deferred until [REDACTED]  
+Counterclaim withstands a Motion to Dismiss.
+
+10. Other potential areas of discovery may exist. Epstein requests clarification of what can be done now and what should wait until all the pleadings are at issue.
+
+11. Epstein represents that this Motion is made in good faith and not for the purposes of delay. Epstein also represents that he has and will attempt to make an effort to resolve this Motion without the need of a hearing.
+
+WHEREFORE, the Plaintiff/Counter-Defendant Jeffrey Epstein requests clarification of this Court's prior directives relating to discovery before the pleadings are at issue.
+
+**CERTIFICATE OF SERVICE**
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via e-mail and U.S. Mail on this 4<sup>th</sup> day of November, 2011 to: Jack Scarola, Esq., Searcy Denney Scarola et al., 2139 Palm Beach Lakes Boulevard, West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, P.A., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401-5012; and Marc S. Nurik, Esq., Law Offices of Marc S. Nurik, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301.
+
+Respectfully submitted,
+
+![]()Joseph L. Ackerman, Jr.  
+Florida Bar No. 235954
+
+[REDACTED] BURNETT, P.A.  
+901 [REDACTED] Point West  
+777 South Flagler Drive  
+West Palm Beach, Florida 33401  
+Telephone: (561) 802-9044  
+Facsimile: (561) 802-9976  
+Attorneys for Jeffrey Epstein, Plaintiff
+
+Epstein v. Rothstein and Case No. 502009CA040800XXXXMB/Divilill!
+
+and
+
+E. Knight Florida No. 607363 lipvil a I BURNETT, P.A. aza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131 Telephone: (305) 789-9200 Facsimile: (305) 789-9201 Attorneys for Jeffrey Epstein, Plaintiff

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marker2/court-epstein-v-rothstein/EFTA02770202/EFTA02770202.md

@@ -0,0 +1,375 @@
+#### IN THE CIRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+Case No.:50 2009 CA 040800XXXXMBAG
+
+JEFFREY EPSTEIN,
+
+Plaintiff,
+
+vs.
+
+SCOTT ROTHSTEfN individually, and J. individually,
+
+Defendants,
+
+Defendant J. Esq., offers the following specific facts as the undisputed material facts in this case. Each of the following facts is numbered separately and individually to facilitate Epstein's required compliance with Fla. R. Civ. P. 1.510(c) ("The adverse party shall identify . . . any summary judgment evidence on which the adverse party relies."). All referenced exhibits and attachments have previously been filed with the Court and provided to Epstein.
+
+### STATEMENT OF UNDISPUTED FACTS
+
+c.l .
+
+. jabtri,
+
+### Sexual Abuse of Children By Epstein
+
+Defendant Epstein has a sexual preference for young children. Deposition of Jeffrey Epstein, Mar. 17, 2010, at 110 (hereinafter "Epstein Depo.") (Deposition Attachment #1).1
+
+When questioned about this subject at his deposition, Epstein invoked his endment right to remain silent rather than make an incriminating admission. Accordingly, is entitled to the adverse inference against Epstein that, had Epstein answered, the answer would have been unfavorable to him. "[I]t is well-settled that the Fifth Amendment does not forbid adverse inferences against parties to
+
+2. Epstein repeatedly sexually assaulted more than forty (40) young girls on numerous occasions between 2002 and 2005 in his mansion in West Palm Beach, Florida. These sexual assaults included vaginal penetration. Epstein abused many of the girls dozens if not hundreds of times. Epstein Depo. at 109 ("Q: How many times have you engaged in oral sex with females under the age of 18?" A: [Invocation of the Fifth Amendment)); Deposition of Jane Doe, September 24, 2009 and continued March 11, 2010, at 527 (minor girl sexually abused at least 17 times by Epstein) (hereinafter "Jane Doe Depo") (Deposition Attachment #2); id. 564-67 (vaginal penetration by Epstein with his finger), 568 (vaginal penetration by Epstein with a massager); Deposition of L.M., September 24, 2009, at 73 (hereinafter "L.M. Depo") (Deposition Attachment #3) (describing the manner in which Epstein abused her beginning when LM was 13 years old, touching her vagina with his fingers and vibrator) at 74, line 12-13 (she was personally molested by Epstein more than 50 times), at 164, line 19-23 and 141, line 12-13 and 605, line 3-6 (describing that in addition to being personally molested by Epstein she was paid \$200 per underage girl she brought Epstein and she brought him more than seventy (70) underage girls - she told him that she did not want to bring him any more girls and he insisted that she continue to bring him underage girls); Deposition of E.W., May 6, 2010 (hereinafter "E.W. Depo") (Deposition Attachment #4) at 115-116, 131 and 255 (describing Epstein's abuse of her beginning at age 14 when he paid her for touching her vagina, inserting his fingers and
+
+civil actions when they refuse to testify in response to probative evidence offered against them." Baxter v. Palmigiano, 425 U.S. 308, 318 (1976); accord Vasquez v. State, 777 So.2d 1200, 1203 (Ha. App. 2001). The reason for this rule "is both logical and utilitarian. A party may not trample upon the rights of others and then escape the consequences by invoking a constitutional privilege — at least not in a civil setting." Fraser v. Security and Inv. Corp., 615 So.2d 841, 842 (Fla. App. 1993).
+
+using a vibrator and he also paid her \$200 for each other underage female E.W. brought him to molest. She brought him between 20 and 30 underage females); Deposition of Jane Doe #4, date (hereinafter "Jane Doe #4 Depo") (Deposition Attachment #5) at 32-34, and 136 (she describes first being taken to Epstein at 15 years old, "Being fingered by him, having him use a vibrator on [me), grabbing my nipples, smelling my butt, jerking off in front of me, licking my clit, several times.").
+
+3. At all relevant times has had a good faith basis to conclude and did conclude2 that Epstein was able to access a large number of underage girls through a pyramid abuse scheme in which he paid underage victims \$200-\$300 cash for each other underage victim that she brought to him. See Palm Beach Police Incident Report at 87 (hereinafter "Incident Report") (Exhibit "A").3 The Palm Beach Police Incident Report details Epstein's scheme for molesting underage females. Among other things, the Incident Report outlines some of the experiences of other Epstein victims. When S.G, a 14 year old minor at the time, was brought to Epstein's home, she was taken upstairs by a woman she believed to be Epstein's assistant. The woman started to fix up the room, putting covers on the massage table and bringing lotions out. The "assistant" then left the room and told S.G. that Epstein would be up in a second. Epstein walked over to S.G. and told her to take her clothes off in a stem voice. S.G. states in the report she did not know what to do, as she was the only one there. S.G. took off her shirt, leaving her bra on. Epstein, then in a towel told her to take off everything. S.G. removed her pants leaving
+
+<sup>2</sup> In support of all assertions concerning the actions took, what learned in the course of his representation of his clients, good faith bilind the founM ilor those beliefs, see Affidavit and specifically paragrap s and 25 of that Affidavit.
+
+<sup>3</sup> For clarity, depositions attached to this memorandum will be identified numerically as attachments #1, #2, #3, etc., while exhibits attached to this memorandum will be identified alphabetically as exhibits A, B, C, etc.
+
+on her thong panties. Epstein then instructed S.G to give him a massage. As S.G gave Epstein a massage, Epstein turned around and masturbated. S.G. was so disgusted, she did not say anything; Epstein told her she "had a really hot body." Id. at 14. In the report, S.G. admitted seeing Jeffrey Epstein's penis and stated she thought Epstein was on steroids because he was a A "really built guy and his wee wee was very tiny." Id. at 15.
+
+4. The exact number of minor girls who Epstein assaulted is nly to Epstein. However, • had a good faith basis to believe and did in fact believe that Epstein's victims were substantially more than forty (40) in number. In addition to the deposition excerpts from two of his many victims above about the number of underage girls brought to Epstein and the Palm Beach incident report, there is overwhelming proof that the number of underage girls molested by Epstein through his scheme was in the hundreds. See Complaint, Jane Doe 102 v. Epstein, (hereinafter Jane Doe 102 complaint) (Exhibit "B"); see also Deposition of Jeffrey Epstein, April 14, 2010, at 442, 443, and 444 (Epstein invoking the 5th on questions about his daily abuse and molestation of children) (Deposition Attachment #6).
+
+5. At all relevant times has had a good faith basis to believe and did in fact believe that Epstein and his attorneys knew of the seriousness. of the criminal investigation against him and corresponded constantly with the United States Attorney's Office in an attempt to avoid the filing of numerous federal felony offenses, which effort was successful. See Correspondence from U.S. Attorney's Office to Epstein (hereinafter "U.S. Attorney's Correspondence") (Composite Exhibit "C) (provided in discovery during the Jane Doe v. Epstein case).
+
+6. At all relevant times [REDACTED] has had a good faith basis to believe and did in fact believe that, more specifically, Epstein's attorneys knew of Epstein's scheme to recruit minors for sex and also knew that these minors had civil actions that they could bring against him. In fact, there was much communication between Epstein's attorneys and the United States Prosecutors in a joint attempt to minimize Epstein's civil exposure. For example, on October 3, 2007, Assistant U.S. Attorney [REDACTED] Villafaña sent an email (attached hereto as Exhibit "D") to Jay Lefkowitz, counsel for Epstein, with attached proposed letter to special [REDACTED] regarding handling numerous expected civil claims against Epstein. The letter reads in pertinent part,
+
+"The undersigned, as counsel for the United States of America and Jeffrey Epstein, jointly write to you to provide information relevant to your service as a Special [REDACTED] in the selection of an attorney to represent several young women who may have civil damages claims against Mr. Epstein. The U.S. Attorney's Office and the Federal Bureau of Investigation (jointly referred to as the "United States") have conducted an investigation of Jeffrey Epstein regarding his solicitation of minor females in Palm Beach County to engage in prostitution. Mr. Epstein, through his assistants, would recruit underage females to travel to his home in Palm Beach to engage in lewd conduct in exchange for money. Based upon the investigation, the United States has identified forty (40) young women who can be characterized as victims pursuant to 18 USC 2255. Some of those women went to Mr. Epstein's home only once, some went there as much as 100 times or more. Some of the women's conduct was limited to performing a topless or nude massage while Mr. Epstein masturbated himself. For other women, the conduct escalated to full sexual intercourse. As part of the resolution of the case, Epstein has agreed that he would not contest jurisdiction in the Southern District of Florida for any victim who chose to sue him for damages pursuant to 18 USC 2255. Mr. Epstein agreed to provide an attorney for victims who elected to proceed exclusively pursuant to that section, and agreed to waive any challenge to liability under that section up to an amount agreed to by the parties. The parties have agreed to submit the selection of an attorney to a Special [REDACTED] ...."
+
+7. At all relevant times [REDACTED] has had a good faith basis to believe and did in fact believe that L.M. was, in fact, a victim of Epstein's criminal abuse because L.M. was one of the
+
+minor females that the United States Attorney's Office recognized as a victim. L.M.'s sworn deposition testimony and the adverse inference drawn from Epstein's refusal to testify confirm that Epstein began sexually assaulting L.M. when she was 13 years old and continued to molest her on more than fifty (50) occasions over three (3) years. Epstein Depo., Attachment #1, at 17 ("Q: Did you . . . ever engage in any sexual conduct with L.M.?" A: [Invocation of the Fifth Amendment].); see also Epstein Depo., April 14, 2010, Attachment #6, at 456 ("Q: LM was an underage female that you first abused when she was 13 years old; is that correct?" A: [Invocation of Fifth Amendment].)
+
+8. Epstein was also given ample opportunity to explain why he engaged in sexual activity with L.M. beginning when L.M. was 13 years old and why he has molested minors on an everyday basis for years, and he invoked 'atb., amendment right rather than provide explanation. See Epstein Deposition 17, 2010, at 11-12, 30-31 (Deposition Attachment # 7).
+
+9. Epstein also sex ally assaulted E.W., beginning when she was 14 years old and did so on numerous occasions. See E.W. Depo., Attachment #4 at 215-216.
+
+10. Another of the minor girls Epstein sexually assaulted was Jane Doe; the abuse began when Jane Doe was 14 years old. Rather than incriminate himself, Epstein invoked the 5th amendment to questions about him digitally penetrating Doe's vagina, using vibrators on her vagina and masturbating and ejaculating in her presence. Epstein Depo., April 14, 2010, Attachment #6, at 420, 464, 468.
+
+11. When clients L.M., E.W., and Jane Doe were 13 or 14 years old, each was brought to Epstein's home multiple times by another underage victim. Epstein engaged in one or more of the following acts with each of the then-minor girls at his mansion: receiving a topless or completely nude massage; using a vibrator on her vagina; masturbating in her presence; ejaculating in her presence; touching her breast or buttocks or vagina or the clothes covering her sexual organs; and demanding that she bring him other underage girls. Epstein and his co-conspirators used the telephone to contact these girls to entice or induce them into going to his mansion for sexual abuse. Epstein also made E.W. perform oral sex on him and was to perform sex acts on (Epstein's live-in sex slave) in Epstein's presence. See Plaintiff Jane Doe's Notice Regarding Evidence of Similar Acts of Sexual Assault, filed in Jane Doe v. Epstein, No. 08-cv-80893 (S.D. Fla. 2010), as DE 197, (hereinafter "Rule 413 Notice") (Exhibit "E"); Jane Doe Depo., Attachment #2, at 379-380; L.M. Depo., Attachment #3, at 416; E.W. Depo, Attachment #4, at 205.
+
+12. At all relevant times Edwards has had a good faith basis to believe and did in fact believe that yet another of the minor girls Epstein sexually assaulted was C.L. When she was approximately 15 years old, C.L. was brought to Epstein's home by another underage victim. While a minor, she was at E1 home on multiple occasions. Epstein engaged in one or more of the following acts with her while she was a minor at his house - topless or completely nude massage on Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her presence; Epstein ejaculated in her presence; Epstein also demanded that she bring him other underage girls. See Rule 413 Notice, Exhibit "E"; Incident Report, Exhibit "A."
+
+13. At all relevant times has had a good faith basis to believe and did in fact believe that yet another girl Epstein sexually assault was A.H. When she was approximately 16 years old, she was brought to Epstein's home by another underage victim. While a minor, she
+
+was at Epstein's home on multiple occasions. Epstein engaged in one or more of the following acts with her while she was a minor at his house - topless or completely nude massage on Epstein; Epstein used a vibrator on her vagina; Epstein masturbated in her presence; Epstein ejaculated in her presence; Epstein touched her breast or buttock or vagina or the clothes covering her sexual organs; was made to perform sex acts on Epstein; made to perform sex acts on in Epstein's presence. Epstein also forcibly raped this underage victim, as he held her head down against her will and pumped his penis inside her while she was screaming "No". See Rule 413 Notice, Exhibit "E"; Incident Report, Exhibit "A", at 41 (specifically discussing the rape):
+
+"[A.H.] remembered that she climaxed and was removing herself from the massage table. [A.H.] asked for a sheet of er and drew the massage table in the bathroom and where Epstein, and she were. Epstein turned [A.H.] on to her stomach on the massage bed and inserted his penis into her vagina. [A.H.] stated Epstein began to pump, his penis in her vagina. [A.H.] became upset over this. She said her head was being held against the bed forcibly, as he continued to pump inside her. She screamed no, and Epstein stopped ...."
+
+"[A.H.] advised there were times that she was so sore when she left Epstein's house. [A.H.] advised she was ripped, torn, in her vagina area. [A.H.] advised she had difficulty walking to the car after leaving the house because she was so sore."
+
+14. Without detailing each fact known about Epstein's abuse of the many underage has had a good faith basis to believe and did in fact believe at all relevant times that Epstein also abused other victims in ways closely similar to those described in the preceding paragraphs. Epstein's additional victims include the following (among many other) young girls: S.G.; A.D.; V.A.; N.R.; J.S.; V.Z.; J.A.; F.E.; M.L.; M.D.; D.D.; and D.N. These girls were between the ages of 13 and 17 when Epstein abused them. See Rule 413 Notice, Exhibit E; Deposition of E.W., Deposition Attachment #4.
+
+15. One of Mr. Epstein's household employees, Mr. Alfredo Rodriguez, saw numerous underage girls coming into Epstein's mansion for purported "massages." See Rodriguez Depo. at 242-44 (Deposition Attachment #8). Rodriguez was aware that "sex toys" and vibrators were found in Epstein's bedroom after the purported massages. Id. at 223-28. Rodriguez thought what Epstein was doing was wrong, given the extreme youth of the girls he saw. Id. at 230-31..
+
+16. Alfredo Rodriguez took a journal from Epstcin's computer that reflected many of the names of underage females Epstein abused across the country and the world, including locations such as Michigan, California, West Palm Beach, New York, New Mexico, and Paris, France. See Journal (hereinafter "The Journal" or "Holy Grail") (Exhibit "F") (identifying, among other Epstein acquaintances, females atcotifiguez f believes were underage under the heading labeled "Massages").
+
+17. Rodriguez was later e -in a criminal complaint with obstruction of justice in connection with trying to obtain \$50,000 from civil attorneys pursuing civil sexual assault cases against Epstein as payment for producing the book to the attorneys. See Criminal Complaint at 2, U.S. v. Rodriguez, No. 9:10-CR-80015-KAM (S.D. Fla. 2010) (Exhibit "G"). Rodriguez stated he needed money because the journal was his "property" and that he was afraid that Jeffrey Epstein would make him "disappear" unless he had an "insurance policy" (i.e., the journal). Id. at 3. Because of the importance of the information in the journal to the civil cases, Mr. Rodriguez called it "The Holy Grail."
+
+18. In the "Holy Grail" or "The Journal," among the many names listed (along with the abused girls) are some of the people that Epstein alleges in his Complaint had "no connection
+
+whatsoever" with the litigation in this case. See, e.g., Journal, Exhibit F, at 85 (Donald Trump); at 9 (Bill Clinton phone numbers listed under "Doug Bands").
+
+## Federal Investigation and Plea Agreement With Epstein
+
+19. In approximately 2005, the FBI and the U.S. Attorney's Office in the Southern District of Florida learned of Epstein's repeated sexual abuse of minor girls. They began a criminal investigation into federal offenses related to his crimes. See U.S. Attorney's Correspondence, Exhibit "C".
+
+20. At all relevant times has had a good faith basis to believe and did in fact believe that to avoid the Government learning about his abuse of minor girls, Epstein threatened his employees and demanded that they not cooperate with the government. Epstein's aggressive witness tampering was so severe that the United States Attorney's Office prepared negotiated plea agreements containing these charges. For example, in a September 18, 2007, email from AUSA Villafana to Lefkowitz (attached hereto as Exhibit "H"), she attached the proposed plea agreement describing Epstein's witness tampering as follows:
+
+## "UNITED STATES vs. JEFFREY EPSTEIN PLEA PROFFER"
+
+On August 21, 2007, FBI Special Agents E. Nesbitt Kuyrkendall and Jason Richards traveled to the home of Leslie Groff to serve her with a federal grand jury subpoena with an investigation pending in the Southern District of Florida. Ms. Groff works as the personal assistant of the defendant. Ms. Groff began speaking with the agents and then excused herself to go upstairs to check on her sleeping child. While upstairs, Ms. Groff telephoned the defendant, Jeffrey Epstein, and informed him that the FBI agents were at her home. Mr. Epstein instructed Ms. Groff not to speak with the agents and reprimanded her for allowing them into her home. Mr. Epstein applied pressure to keep Ms. Groff from complying with the grand jury subpoenaS that the agents had served upon her. In particular, Mr. Epstein warned Ms. Groff against turning over documents and electronic evidence responsive to the subpoena and pressured her to delay her
+
+appearance before the grand jury in the Southern District of Florida. This conversation occurred when Mr. Epstein was aboard his privately owned civilian aircraft in Miami in the Southern District of Florida. His pilot had filed a flight plan showing the parties were about to return to Teterboro, NJ. After the conversation with Ms. Groff, Mr. Epstein became concerned that the FBI would try to serve his traveling companion, with a similar nd jury subpoena. In fact, the agents were preparing to serve with a target letter when the flight landed in Teterboro. Mr. Epstein then redirected his airplane, making the pilot file a new flight plan to travel to the US Virgin Islands instead of the New York Ci area thereb keeping the Special Agents from serving the target letter on .• During the flight, the defendant harassing and pressuring her not to cooperate with the grand jury's investigation, thereby hindering and dissuading her from reporting the commission of a violation of federal law to a law enforcement officer, namely, Special Agents of the FBI. Epstein also threatened and harassed against cooperating against him as well. verbally harassed
+
+21. learned that the Palm Beach police department investigation ultimately led to the execution of a search warrant at Epstein's mansion in October 2005. See Police Incident Report, Exhibit "A".
+
+22. learned that at around the same time, the Palm Beach Police Department also began investigating Epstein's sexual abuse of minor girls. They also collected evidence of Epstein's involvement with minor girls and his obsession with training sex slaves, including pulling information.from Epstein's trash. Their investigation showed that Epstein ordered from Amazon.com on about September 4, 2005, such books as: SM101: A Realistic Introduction, by Jay Wiseman; SlaveCraft: Roadmaps for Erotic Servitude - Principles, Skills, and Tools, by Guy Baldwin; and Training with Miss Abernathy: A Workbook for Erotic Slaves and Their Owners, by Christina Abernathy. See Receipt for Sex Slave Books (Exhibit "I").
+
+23. The Palm Beach incident reports provided with the names of numerous witnesses that participated in Epstein's child molestation criminal enterprise and also provided
+
+with some insight into how far-reaching Epstein's power was and how addicted Epstein was to sex with children. See Incident Report, Exhibit "A".
+
+24. The Palm Beach Police Department also collected Epstein's message pads, which provided other names of people that also knew Epstein's scheme to molest children. See Message Pads (Exhibit "J") (note: the names of underage females have been redacted to protect the anonymity of the underage sex abuse victims). Those message pads show clear indication that Epstein's staff was frequently working to schedule multiple young girls between the ages of 12 and 16 years old literally every day, often two or three times per day. Id.
+
+25. In light of all of the information of numerous crimes committed by Epstein, learned that the U.S. Attorney's Office began preparing the filing of federal criminal charges against Epstein. For example, in addition to the witness tampering and money laundering charges the U.S. Attorney's Office prepared an 82-page prosecution memo and a 53 page indictment of Epstein related to his sexual abuse of children. On September 19, 2007, at 12:14 PM, AUSA Villafafia wrote to Ep= counsel,. Jay Lefkowitz, "Jay - I hate to have to be firm about this, but we need to wrap this up by Monday. I will not miss my indictment date when this has dragged on for several weeks already and then, if things fall apart, be left in a less advantageous'position than before the negotiations. I have had an 82-page pros memo and 53 page indictment sitting on the shelf since May to engage in these negotiations. There has to be an ending date, and that date is Monday." These and other communications are within the correspondence attached as Composite Exhibit "C."
+
+26. learned that rather than face the filing of federal felony criminal charges, Epstein (through his attorneys) engaged in plea bargain discussions. As a result of those discussions, on September 24, 2007, Epstein signed an agreement with the U.S. Attorney's Office for the Southern District of Florida. Under the agreement, Epstein agreed to plead guilty to an indictment pending against him in the 15th Judicial Circuit in and for Palm Beach County charging him with solicitation of prostitution and procurement of minors for prostitution: Epitein also agreed that he would receive a thirty month sentence, including 18 months of jail time and 12 months of community control. In exchange, the U.S. Attorney's Office agreed not to pursue any federal charges against Epstein. See Non-Prosecution Agreement (Exhibit "K").
+
+27. Part of the Non-Prosecution Agreement that Epstein negotiated was a provision in which the federal government agreed not to prosecute Epstein's co-conspirators. The coconspirators procured minor females to be molested by Epstein. One of the co-conspirators - -even participated in the sex acts with minors (including E.W.) and Epstein. See Incident Report, Exhibit "A", at 40-42, 49-51; Deposition of April 13, 2010, (hereinafter Depo.") at 11 (Deposition attachment #9).
+
+28. Under the Non-Prosecution Agreement, Epstein was to use his "best efforts" to enter into his guilty pleas by October 26, 2007. However, learned that Epstein violated his, agreement with the U.S. Attorney's Office to do so and delayed entry of his plea. See Letter from U.S. Attorney R. Alexander Acosta to Lilly Ann M, Dec. 19, 2007 (Exhibit "L").
+
+29. On January 10, 2008 and again on May 30, 2008 E.W. and L.M. received letters from the FBI advising them that "[t]his case is currently under investigation. This can be a lengthy process and we request your continued patience while we conduct a thorough investigation." Letters attached at Composite Exhibit "M". This document is evidence that the FBI did not notify E.W. and L.M. that a plea agreement had already been reached that would
+
+block federal prosecution of Epstein. Nor did the FBI notify E.W. and L.M. of any of the parts of the plea agreement. Nor did the FBI or other federal authorities confer with E.W. and L.M. about the plea. See id.
+
+30. In 2008, believed in good faith that criminal prosecution of Epstein was extremely important to his clients E.W. and L.M. and that they desired to be cedisykd by the FBI and/or other representatives of the federal government about the p on of Epstein. The letters that they had received around January 10, 2008, ed^ that a criminal investigation of Epstein was on-going and that they would government reached any final resolution of that investigation-. co : ned before the federal
+
+Agrees to Serve as Legal Counsel for Three Victims of Epstein's Sexual Assaults
+
+31. In about April 2008, J. Esq., was a licensed attorney in Florida, practicing as a sole practitioner. a oThter prosecutor, he was well versed in civil cases that involved criminal acts, including sexua assaults. Three of the many girls Epstein had abused L.M., E.W., and Jane Dptt, all requested that represent them civilly and secure appropriate moneey damages against Epstein for repeated acts of sexual abuse while they were minor girls. f the girls (L.M. and E.W.) also requested that represent them in connec a concern that the Federal Bureau of Investigation (FBI) and U.S. Attorney's Office might be arranging a plea bargain for the criminal offenses committed by Epstein without providing them the legal rights to which they were entitled (including the right to be notified of plea discussions and the right to confer with prosecutors about any plea arrangement). See
+
+Affidavit of J. =, Esq. at ¶1 - 2, ¶4 (hereinafter = Affidavit") (Exhibit "N").
+
+32. On June 13, 2008, attorney agreed to represent E.W.; on July 2, 2008, attorney agreed to represent Jane Doe; and, on July 7, 2008, attorney agreed to represent L.M. in connection with the sexual assaults committed by Epstein and to insure that their rights as victims of crimes were protected in the criminal process on-going against Epstein. Mr. and his three clients executed written retention agreements. See id. at ¶2.
+
+33. In mid June of 2008, contacted AUSA Villafafia to inform her that he represented Jane Doe #1 and, later, Jane Doe #2. AUSA Villafafia did not advise that a plea agreement had already been negotiated with Epstein's attorneys that would block federal prosecution. To the contrary, AUSA Villafafia mentioned a possible indictment. AUSA Villafafia did indicate that federal investigators had concrete evidence and information that Epstein had sexually molested Moy underage minor females, including E.W., LM, and Jane Doe. See id. at ¶4.
+
+34. also requested from the U.S. Attorney's Office the information that they had collected regarding Epstein's sexual abuse of his clients. However, the U.S. Attorney's Office, declined to provide any such information to It similarly declined to provide any,. such information to the other attorneys who represented victims of Epstein's sexual assaults. At the very least, this includes the items that were confiscated in the search warrant of Epstein's home, including dildos, vibrators, massage table, oils, and additional message pads. See Property Receipt (Exhibit "O").
+
+35. On Friday, June 27, 2008, at approximately 4:15 p.m., AUSA Villafafia received a copy of Epstein's proposed state plea agreement and teamed that the plea was scheduled for 8:30 a.m., Monday, June 30, 2008. AUSA Villafafia called to provide notice to his clients regarding the hearing. AUSA Villafafia did not tell Attorney that the guilty pleas in state court would bring an end to the possibility of federal prosecution pursuant to the plea agreement. See Affidavit, Exhibit "N", at ¶6.
+
+36. Under the Crime Victims' Rights Act (CVRA), 18 U.S.C. §,3771, victims of federal crimes — including E.W. and L.M. — are entitled to basic rights during any plea bargaining process, including the right to be treated with fairness, the right to confer with prosecutors regarding any plea, and the right to be heard regarding any plea. The process that was followed leading to the non-prosecution of Epstein violated these rights of E.W. and L.M. See Emergency Pem. for Victim's Enfor t'Sf Crime Victim's Rights, No. 9:08-CV-80736- KAM (S.D. Fla. 2008) (Exhibit "P"
+
+37. Because of the violation f the CVRA, on July 7, 2008, filed an action in the U.S. District Court for the Southern District of Florida, Case No. 9:08-CV-80736, seeking to enforce the rights of E.W. and L.M. That action alleged that the U.S. Attorney's Office had failed to provide E.W. and L.M. the rights to which they were entitled under the Act, including the right to be notified about a plea agreement and to confer with prosecutors regarding it. See id.
+
+38. On July 11, 2008, took E.W. and L.M. with him to the hearing on the CVRA action. It was only at this hearing that both victims learned for the first time that the plea deal was already done with Epstein and that the criminal case against Epstein had been
+
+effectively terminated by the U.S. Attorney's office. See Hearing Transcript, July 11, 2008 (Exhibit "Q").
+
+39. learned that Jane Doe felt so strongly that the plea bargain was inappropriate that she made her own determination •to appear on a television program and exercise her First Amendment rights to criticize the unduly lenient plea bargain Epstein received in a criminal case.
+
+40. The CVRA action that filed was recently administratively closed and filed a Motion to reopen that proceeding. See No. 9:08-CV-80736 (S.D. Fla.).
+
+## Epstein's Entry of Guilty Pleas to Sex Offenses
+
+41. Ultimately, on June 30, 2008, in the Fifteenth Judicial Circuit in Palm Beach County, Florida, defendant Epstein, entered pleas of "guilty" to various Florida state crimes involving the solicitation of minors for prostitution and the procurement of minors for the purposes of prostitution. See Plea Colloquy (Exhibit "R").
+
+42. As a condition of that plea, and in exchange for the Federal Government not prosecuting the Defendant, Epstein additionally entered into an agreement with the Federal Government acknowledging that approximately thirty-four (34) other young girls could receive payments from him under the federal• statute providing for compensation to victims of child sexual abuse, 18 U.S.C. § 2255. As had been agreed months before, the U.S. Attorney's Office did not prosecute Epstein federally for his sexual abuse of these minor girls. See Addendum to Non-Prosecution Agreement (Exhibit "S") (in redacted form to protect the identities of the minors involved).
+
+43. . Because Epstein became a convicted sex offender, he was not to have contact with any of his victims. During the course of his guilty pleas on June 30, 2008, Palm Beach Circuit Court Judge Deborah Dale Pucillo ordered Epstein "not to have any contact, direct or indirect" with any victims. She also expressly stated that her no-contact order applied to "all of the victims." Similar orders were entered by the federal court handling some of the civil cases against Epstein. The federal court stated that it "finds it necessary to state clearly that Defendant is under this court's order not to have direct or indirect contact with any plaintiffs . . . ." Order, Case No. 9:08-cv-80119 (S.D. Fla. 2008), [DE 238] at 4-5 (emphasis added); see also Order, Case No. 9:08-cv-80893, [DE 193] at 2 (emphasis added).
+
+# Files Civil Suits Agetnst Epstein
+
+44. had a good faith belief that his clients felt angry and betrayed by the criminal system and wished to prosecute and punish Epstein for his crimes against them in whatever avenue remained open to diem. On August 12, 2008, at the request of his client Jane Doe, Brad filed a civil suit against Jeffrey Epstein to recover damages for his sexual assault of Jane Doe. See Edwards Affidavit, "N" at ¶7. Included in this complaint was a RICO count that explained how Epstein ran a criminal conspiracy to procure young girls for him to sexually abuse. See Complaint, Jane Doe v. Epstein (Exhibit "Ti.
+
+45. September I I, 2008, at the request of his client E.W., Brad filed a civil suit against Jeffrey Epstein to recover damages for his sexual assault of E.W. See Complaint, E.W. v. Epstein (Exhibit "U").
+
+46. On September 11, 2008, at the request of his client L.M.., Brad filed a civil suit against Jeffrey Epstein to recover damages for his sexual assault of L.M. See Complaint, L.M. v. Epstein, (Exhibit "V").
+
+47. Jane Doe's federal complaint indicated that she sought damages of more than \$50,000,000. Listing the amount of damages sought in the complaint was in accord with other civil suits that were filed against Epstein (before any lawsuit filed by Edwards). See Complaint, Jane Doe #4 v. Epstein (Exhibit "W") (filed by Herman and Mermelstein, PA)..'
+
+48. At about the same time as filed his three lawsuits against Epstein, other civil attorneys were filing similar lawsuits against Epstein. For example, on or about April 14, 2008 another law firm, Herman and Mermelstein, filed the first civil action against Epstein on behalf of one of its seven clients who were molested by Epstein. The complaints that attorney Herman filed on behalf of his seven clients were similar in tenor and tone to the complaint that filed on behalf of his three clients. See id.
+
+49. Over the next year and a half, more than 20 other similar civil actions were filed by various attorneys against Epstein alleging sexual assault of minor girls. These complaints were also similar in tenor and tone to the complaint that filed on behalf of his clients. These complaints are all public record and have not been attached, but are available in this Court's files and the files of the U.S. District Court for the Southern District of Florida.
+
+50. In addition to the complaints filed against Epstein in Florida, a female in New York, Ava M, filed a lawsuit against Epstein in New York making similar allegations - that Epstein paid her for a massage then forced her to give him oral sex and molested her in other ways when she was only 16 years old. was born a male, and in her complaint she alleges that Epstein told her during the "massage", "I love how young you are. You have a fight butt like a baby". See Jeff Epstein Sued for "Repeated Sexual Assaults" on Teen, New York Post, October 17, 2007, by Dareh Gregorian, link at: http://w-ww.nvnost.com/p/news/regi onal/i tem\_44zIWyLUFH7R 1 OUtKYGPbP;jsessionid=6CA3 EBFIBEF68F5DE14BFB2CAA5C37E0. See Article attached hereto as Exhibit
+
+51. three complaints against Epstein contained 1 about sexual abuse than (as one example) a complaint filed by attorney Robert Josephs rg from the law firm of Podhurst Orseck. See Complaint, Jane Doe 102 v. Epstein (Exhibit "B"). As recounted in detail in this Complaint, Jane Doe 102 was 15 years old when Ghislaine Maxwell discovered her and lured her to Epstein's house. Maxwell and Epstein forced her to have sex with both of them and within weeks Maxwell and Epstein were flying her all over the world. According to the Complaint, Jane Doe 102 was forced to live as one of Epstein's underage sex slaves for years and was forced to have sex with not only Maxwell and Epstein but also other politicians, businessmen, royalty, academicians, etc. She was even made to watch Epstein have sex with three 12-year-old girls that were sent to him for his birthday by a citizen that is a friend of Epstein's. Luckily, Jane Doe 102 escaped to Australia to get away from Epstein and Maxwell's sexual abuse.
+
+52. learned that in addition to civil suits that were filed in court against Epstein, at around the same time other attorneys engaged in pre-filing settlement discussions with Epstein. Rather than face filed civil suits in these cases, Epstein paid money settlements to more than 15 other women who had sexually abused while they were minors. See articles regarding settlements attached hereto as Composite Exhibit "Y."
+
+### Epstein's Obstruction of Normal Discovery and Attacks on Nis Victims
+
+53. Once filed his civil complaints for his three clients, he began the normal process of discovery for cases such as these. He sent standard discovery requests to Epstein about his sexual abuse of the minor girls, including requests for admissions, request for production, and interrogatories. See Affidavit, Exhibit "N", at ¶¶11-19 and 25.
+
+Rather than answer any substantive questions about his sexual abuse and his conspiracy for procuring minor girls for him to abuse, Epstein invoked his 5th amendment right against selfincrimination. An example of Epstein's refusal to answer is attached as Composite Exhibit "Z" (original discovery propounded to Epstein and his responses invoking 5th amendment).
+
+54. During the discovery phase of the civil cases filed against Epstein, Epstein's deposition was taken at least five times. D ng all of those depositions, Epstein refused to answer any substantive questions about l abuse of minor girls. See, e.g., Deposition Attachments 1, 6 and 7.
+
+55. During these 4sitions, Epstein fiirther attempted to obstruct legitimate questioning by inserting a variety of irrelevant information about his case. As one of innumerable examples, on March 8, 2010, Mr. Horowitz, representing seven victims, Jane Doe's 2-8, asked, "Q: In 2004, did you rub Jane Doe 3's vagina? A: Excuse me. I'd like to answer that question, as I would like to answer mostly every question you've asked me here today; however, upon advice of counsel, I cannot answer that question. They've advised me I must assert my Sixth Amendment, Fifth Amendment and Fourteenth Amendment Rights against self--excuse me, against--under the Constitution. And though your partner, Jeffrey Herman, was disbarred after filing this lawsuit (a statement that was untrue], Mr. MR partner sits in jail for
+
+fabricating cases of a sexual nature fleecing unsuspecting Florida investors and others out of millions of dollars for cases of a sexual nature with--I'd like to answer your questions; however if I--I'm told that if I do so, I risk losing my counsel's representation; therefore I must accept their advice." Epstein deposition, March 8, 2010, at 106 (Deposition attachment #10).
+
+56. When had the opportunity to take Epstein's deposition, he only asked reasonable questions, all of which related to the merits of the cases against Epstein. All depositions of Epstein in which Mr. participated on behalf of his clients are attached to this motion. See Affidavit, Exhibit "N" at ¶I I and Deposition attachments #1, 6, 7, 10, 11, 12, and 13. Cf. with Deposition of Epstein taken by, an attorney representing BB (one in which was not participating), http://www voutt .corn/watch?v=V-dooEvYXx4; and ti \ http://www.youtube.com/watch?v=YCNiYltW-
+
+57. efforts too 'n brmation about Epstein's organization for procuring young girls was also biocke@ because Epstein's co-conspirators took the Fifth. Deposition of March 24, 2010 (hereinafter M Depo.") (Deposition attachment #14); Deposition of April 13, 2010, (Deposition attachment #9); Deposition of March 15, 2010 (hereinafter = Depo.") (Deposition attachment #15). Each of these co-conspirators invoked their respective rights against selfincrimination as to all relevant questions, and the depositions have been attached.
+
+58. At all relevant times has had a good faith basis to believe and did in fact believe was an employee of Epstein's and had been identified as a defendant in at least one of the complaints against Epstein for her role in bringing girls to Epstein's mansion to be abused. At the deposition, she was represented by Bruce Reinhart. She invoked the Fifth on
+
+all substantive questions regarding her role in arranging for minor girls to come to Epstein's mansion to be sexually abused. Reinhart had previously been an Assistant United States Attorney in the U.S. Attorney's Office for the Southern District of Florida when Epstein was being investigated criminally. by Reinhart's office. Reinhart left the United States Attorney's Office and was immediately hired by Epstein to represent Epstein's pilots and certain coconspirators during the civil cases against Epstein. See Affidavit, Exhibit "N" at ¶11.
+
+59. also had other lines of legitimate discovery blocked through the efforts of Epstein and others. For example, learned through deposition that Ghislaine Maxwell was involved in managing Epstein's affairs and companies: See deposition of Epstein's house manager Janusz Banziak, February 16, 2010 at page 14, lines 20-23 (Deposition Attachment #16); See deposition of Epstein's housekeeper October 20, 2009, page 9, lines 17-25 (Deposition Attachment #17); See deposition of Epstein's pilot Larry Eugene =0, October 6, 2009, page 102-103 (Deposition Attachment #18); See deposition of Alfredo Rodriguez, August 7, 2009, page 302-306 and 348 (Deposition Attachment #8); See also Prince Andrew's Friend, Ghislaine Maxwell, Some Underage Girls and A Very Disturbing Story, September 23, 2007 by Wendy Leigh, link at http://www.ntxlicectreations.corn/article.php?id=1895OHANNA . Exhibit "AA".
+
+60. Alfredo Rodriguez testified that Maxwell took photos of girls without the girls' knowledge, kept the images on her computer, knew the names of the underage girls and their respective phone numbers and other underage victims were molested by Epstein and Maxwell together. See Deposition of Rodriguez, Deposition attachment # 8 at 64, 169-170 and 236.
+
+61. In reasonable reliance on this and other information, served Maxwell for deposition in 2009. See Deposition Notice attached as Exhibit "BB." Maxwell was represented by Brett Jaffe of the New York firm of and Gresser, and understood that her attorney was paid for (directly or indirectly) by Epstein. She was reluctant to give her deposition, and tried to work with her attorney to take her deposition on terms that would be acceptable to both sides. The result was the attached confidentiality agreement, under which Maxwell agreed to drop any objections to the deposition, attached hereto as Exhibit "CC." Maxwell, however, contrived to avoid the deposition. On June 29, 2010, one day before was to fly to NY to take Maxwell's deposition, her attorney informed that Maxwell's mother was deathly ill and Maxwell was consequently flying to England with no intention of returning to the United States. Despitgthatassertion, Ghislaine Maxwell was in fact in the country on July 31, 2010, as s the wedding of Chelsea Clinton (former President Clinton's daughter) and x or in a photograph taken for OK magazine. Photos from Issue 809 of the piiblicati Seg i Weekly dated August 16, 2010 are attached hereto as Exhibit "DD" and Affidavit, Exhibit "N" at ¶12.
+
+62. Maxwell is not the only important witness to lie to avoid deposition by M. Upon review of the.message pads that were taken from Epstein's home in the police trash pulls, see, Exhibit "I" supra, many were from Jean Luc Brunel, a citizen and one of Epstein's closest pals. He left messages for Epstein. One dated 4/1/05 said, "He has a teacher for you to teach you how to speak Russian. She is 2x8 years old, not blonde. Lessons are free and you can have your I 51 today if you call." See Messages taken from Jean Luc Brunel are attached hereto as Exhibit "EE." In light of these circumstances of the case, this message reasonably suggested to
+
+that Brunel might have been procuring two eight-year-old girls for Epstein to sexually abuse. According to widely circulated press reports reviewed by MI Brunel is in his sixties and has a reputation throughout the world (and especially in the modeling industry) as a cocaine addict that has for years molested children through modeling agencies while acting as their agent — conduct that has been the subject of critical reports, books, several news articles, and a 60 Minutes documentary on Brunet's sexual exploitation of underage models. See htto://bradmillershero.bloasnot.com/2010/08/women-are-objects.himl, attached hereto as Exhibit
+
+63. learned that Brunel is alio meone that visited Epstein on approximately 67 occasions while Epstein was in j Exhibit "GG." tein's jail visitor log attached as
+
+64. learned that B curt ly runs the modeling agency MC2, a company for which Epstein provides financi s t. See Message Pad's attached as Exhibit "J" supra and Sworn Statement of MC2 employee Maritza Vasquez, June 15, 2010, "Maritza Vasquez Swom Statement" attached at Exhibit "HH" at 1-16.
+
+65. Employees of MC2 told that Epstein's numerous condos at 301 East 66 Street in New York were used to house young models. was told that MC2 modeling agency, affiliated with Epstein and Brunel brought underage girls from all over the world, promising them modeling contracts. Epstein and Brunel would then obtain a visa for these girls, then would charge the underage girls rent, presumably to live as underage prostitutes in the condos. See Maritza Vasquez Sworn Statement, Exhibit "HH" at 7-10, 12-15, 29-30, 39-41, 59- 60 and 62-67.
+
+66. In view of this information suggesting Brunel could provide significant evidence of Epstein's trafficking in young girls for sexual abuse, had Brunel served in New York for deposition. See Notice of Deposition of Jean Luc Brunel attached hereto as Exhibit "II." Before the deposition took place, Brunet's attorney (Tama Kudman of West Palm Beach) contacted EdWards to delay the deposition date. Eventually Kudman informed Edwards in January 2009 that Brunel had left the country and was back in France with no plans to return. This information was untrue; Brunel was actually staying with Epstein in West Palm Beach. See Banasiak deposition, deposition attachment #16 at 154-160 and 172-175; see also pages from Epstein's probation file evidencing Jean Luc Brunel (JLB) staying at his house during that relevant period of time attached Exhibit "JT'. As a rysult, Edwards filed a Motion for Contempt, attached hereto as Exhibit "KK" (Because Eps ( s\egli., f upon.) this case, the motion was never ruled
+
+67. was also infdin at Epstein paid for not only Brunet's representation during the civil process but also paid for legal representation for (Epstein's executive assistant and procurer of girls for him to abuse), Larry Visoski (Epstein's personal pilot), Dave Rogers (Epstein's personal pilot), Lany (Epstein's personal pilot), Louella (Epstein's housekeeper), (Epstein's live-in sex slave), Ghislaine Maxwell (Stager of Epstein's affairs and businesses), Mark Epstein (Epstein's brother), and Janusz Banasiak (Epstein's house manager) It was nearly impossible to take a deposition of someone that would have helpful information that was not represented by an attorney paid for by Epstein. See Affidavit, Exhibit "N" at ¶11.
+
+pasts-192988.html attached hereto as Exhibit "LL." 68. While Epstein and others were preventing any legitimate discovery into his sexual abuse of minor girls, at the same time he was engaging (through his attorneys) in brutal questioning of the girls who had filed civil suits against him, questioning so savage that it made local headlines. See Jane Musgrave, Victims Seeking Sex offender's Millions See Painful Pasts Used Against Them, Palm Beach Post News, Jan. 23, 2010, 'table at http://www.palmbeachoost.cominews/crime/victims-seeking-sex-offenders-masee-painfult/
+
+## Pursues Other Lines ofDiscgsrC,
+
+69. Because of Epstein's thwarting of discovery and attacks on clients, was forced to pursue other avenues of di . Edwards only pursued legitimate discovery designed to further the cases filed See Affidavit, Exhibit "N" at 111.
+
+70. possessed a legitimate basis for doing so: (a) Clinton was friends with Ghislaine Maxwell who was Epstein's longtime companion and helped to run Epstein's companies, kept images of naked underage children on her computer, helped to recruit underage children for Epstein, engaged in lesbian sex with underage females that she procured for Epstein, and photographed underage females in sexually explicit poses and kept child pornography on her computer; (b) it was national news when Clinton traveled with Epstein aboard Epstein's private plane to Africa and the news articles classified Clinton as Epstein's friend. (c) the complaint filed on behalf of Jane Doe No. 102 stated generally that she was required by Epstein to be sexually exploited by not only Epstein but also Epstein's "adult male peers, including royalty, notified Epstem'suomeys of his intent to take Bill Clinton's deposition.
+
+politicians, academicians, businessmen, and/or other professional and personal acquaintances" categories Clinton and acquaintances of Clinton fall, into. The flight logs showed Clinton traveling on Epstein's plane on numerous occasions between 2002 and 2005. See Flight logs attached hereto as Exhibit "MM." Clinton traveled on many of those flights with Ghislaine Maxwell, and a - all employees and/or co-conspirators of Epstein's that were closely connected to Epstein's child exploitation and sexual abuse. The documents clearly show that Clinton frequently flew with Epstein aboard his plane, then suddenly stopped - raising the suspicion that the friendship abruptly ended, perhaps because of events related to Epstein's sexual abuse of children. Epstein's personal phone directory from his computer contains e-mail addresses for Clinton along with 21 phone numbers for him, including those for his assistant (Doug Band), his schedulers, and what appear to be Clinton's personal numbers. This information certainly leads one to believe that Clinton.might well be a source of relevant information and efforts to obtain discovery from him were reasonably calculated to lead to admissible evidence. See Exhibits "B", "F" "AA", "DD", and "MM" and Affidavit, Exhibit "N" at ¶15.
+
+71. Bradley J. Esq., provided notice that he intended to take the deposition of Donald Trump. possessed a legitimate basis for doing so: (a) The message pads confiscated from Epstein's home indicated that Trump called Epstein's West Palm Beach mansion on several occasions during the time period most relevant to my clients' complaints; (b) Trump was quoted in a Vanity Fair article about Epstein as saying "I've known Jeff for fifteen years. Terrific guy," "He's a lot of fun to be with. It is even said that he likes beautiful women as much as I do, and many of them are on the younger side. No doubt about it --
+
+Jeffrey enjoys his social life." Jeffrey Epstein: International Moneyman of Mystery; He's pals with a passel of Nobel Prize—winning scientists, CEOs like Leslie Wexner of the Limited, socialite Ghislaine Maxwell, even Donald Trump. But it wasn't until he flew Bill Clinton, Kevin Spac,ey, and Chris Tucker to Africa on his private Boeing 727 that the world began to wonder who he is. By Landon Jr. (See article attached hereto as Exhibit "NN") (c) Trump allegedly banned Epstein from his Maralago Club in West Palm Beach because Ell. sexually assaulted an underage girl at the club; (d) Jane Doe No. 102's complaint alleged that Jane Doe 102 was initially approached at Trump's Maralago by Ghislaine Maxwell and recruited to be Maxwell and Epstein's underage sex slave; (e) Mark Epstein (Jeffrrey Epstein's brother) testified that Trump flew on Jeffrey Epstein's plane with him (the same plane that Jane Doe 102 alleged was used to have sex with underage girls); (f) Trump had been to Epstein's home in Palm Beach; (g) Epstein's phone directory from his computer contains 14 phone numbers for Donald Trump, including emergency numbers, car numbers, and numbers to Trump's security guard and houseman. Based on this information, reasonably believed that Trump might have relevant information to provide in the cases against Jeffrey Epstein and accordingly provided notice of a possible deposition. See deposition of Mark Epstein, September 21, 2009, at 48-50 (Deposition Attachment #19); See Jane Doe 102 v. Epstein, Exhibit "B"; Exhibit "F"; "Exhibit"!"; "N" and See Affidavit, Exhibit "N" at ¶13.
+
+72. provided notice that he intended to depose Alan Dershowitz. possessed a legitimate basis for doing so: (a) Dershowitz is believed to have been friends with Epstein for many years; (b) in one news article Dershowitz comments that, "I'm on my 20th book... The only person outside of my immediate family that I send drafts to is Jeffrey" The Talented Mr. Epstein, By Vicky on January, 2005 in Published Work, Vanity Fair (See article attached as Exhibit "OO"); (c) Epstein's housekeeper Alfredo Rodriguez testified that Dershowitz stayed at Epstein's house during the years when Epstein was assaulting minor females on a daily basis; (d) Rodriguez testified that Dershowitz was at Epstein's house at times when underage females where there being molested by Epstein (see Alfredo 'Rodriguez deposition at 278-280, 385, 426-427); (e) Dershowitz reportedly assisted in attempting to persuade the Palm Beach State Attorney's Office thatbecause the underage females alleged to have been victims of Epstein's abuse lacked credibility and could not be believed that they were at Epstein's house, when Dershowitz himself was an eyewitness to their presence at the house; (0 Jane Doe No. 102 stated generally that Epstein forced her to be sexually exploited by not only Epstein but also Epstein's "adult male peers, including royalty, politicians, academicians, businessmen, and/or other professional and personal acquaintances" — categories that Dershowitz and acquaintances of Dershowitz fall into; (g) during the years 2002-2005 Alan Dershowitz was on Epstein's plane on several occasions according to the flight logs produced by Epstein's pilot and information (described above) suggested that sexual assaults may have taken place on the plane; (h) Epstein donated \$30 Million one year to the university at which Dershowitz teaches. Based on this information, had a reasonable basis to believe that Dershowitz might have relevant information to provide in the cases against Jeffrey Epstein and accordingly provided notice of a possible deposition. See DershoWitz letters to the State Attorney's office attached as Exhibit "PP"; Deposition of Alfredo Rodriguez at 278-280; Flight Logs Exhibit "MM"; Exhibits "B" and "OO"; and Affidavit, Exhibit "N" at 114.
+
+73. Epstein's complaint alleges that provided notice that he wished to take the, deposition of Tommy Mattola. That assertion is untrue. Mr. Mattola's deposition was set by the law firm of Searcy Denny Scarola Barnhart and Shipley. See Affidavit, Exhibit "N" at¶16.
+
+74. gave notice that he intended to take David Copperfield's deposition. possessed a legitimate basis for doing so. Epstein's housekeeper and one of the only witnesses who did not appear for deposition with an Epstein bought attorney, Alfredo Rodriguez, testified that David Copperfield was a guest at Epstein's house on several occasions. His name also appears frequently in the message pads confiscated from Epstein's house. It has been publicly reported that Copperfield himself has had allegations of sexual misconduct made against him by women claiming he sexually abused them, and one of Epstein's sexual assault victims also alleged that Copperfield had touched her in an improper sexual way while she was at Epstein's house. Mr. Copperfield likely has relevant information and deposition was reasonably calculated to lead to the discovery of admissible evidence. See Affidavit, Exhibit "N" at 117.
+
+75. Epstein also takes issue with identifying Bill as a possible witness. was properly identified as a possible witness because Epstein's personal pilot testified to joining Epstein at Epstein's New Mexico Ranch. There was information indicating that Epstein had young girls at his ranch which, given the circumstances of the case, raised the reasonable inference he was sexually abusing these girls as he had abused girls in West Palm Beach and elsewhere. had also returned campaign donations that were given to him by Epstein, indicating that he believed that there was something about Epstein
+
+with which he did not want to be associated. was not called to testify nor was he ever subpoenaed to testify. See Affidavit, Exhibit "N" at 1118.
+
+76. learned of allegations that Epstein engaged in sexual abuse of minors on his private aircraft. See Jane Doe 102 Complaint, Exhibit "B." Accordingly, pursued discovery to confirm these allegations.
+
+77. Discovery of the pilot and flight logs was proper in the cases brought by against Epstein. Jane Doe filed a federal RICO claim against Epstein that was an active claim through much of the litigation. The RICO claim alleged that Epstein ran an expansive criminal enterprise that involved and depended upon his plane travel. Although Judge Marra dismissed the RICO claim at some point in the federal litigation, the legal team representing En clients intended to pursue an appeal of that dismissal. Moreover, all of the subjects mentioned in the RICO claim remained relevant to other aspects of Jane Doe's claims against Epstein, including in particular her claim for punitive damages. See Affidavit, Exhibit "N" at 119.
+
+78. Discovery of the pilot and flight logs was also proper in the cases brought by against Epstein because of the need to obtain evidence of a federal nexus. client Jane Doe was proceeding to trial on a federal claim under 18 U.S.C. § 2255. Section 2255 is a federal statute which (unlike relevant state statutes) established a minimum level of recovery for victims of the violation of its provisions. Proceeding under the statute, however, required a "federal nexus" to the sexual assaults. Jane Doe had two grounds on which to argue that such a nexus existed to her abuse by Epstein: first, his use of telephone to arrange for girls to be abused; and, second, his travel on planes in interstate commerce. During the course of the litigation,
+
+anticipated that Epstein would argue that Jane Doe's proof of the federal nexus was inadequate. These fears were realized when Epstein filed a summary judgment motion raising this argument. In response, the other attorneys and representing Jane Doe used the flight log evidence to respond to Epstein's summary judgment motion, explaining that the flight logs demonstrated that Epstein had traveled in interstate commerce for the purpose of facilitating his sexual assaults. Because Epstein chose to settle the case before trial Marra did not rule on the summary judgment motion.
+
+79. had further reason to believe and did I fac lieve that the pilot and flight logs might contain relevant evidence for the cases, against Epstein. Jane Doe No. 102's complaint outlined Epstein's daily sexual exploitation and abuse of underage minors as young as 12 years old and alleged that Epstein's plane was used to transport underage females to be sexually abused by him and his friends. The flight logs accordingly were a potential source of information about either additional girls who were victims of Epstein's abuse or friends of Epstein who may have witnessed or even participated in the abuse. Based on this information, reasonably pursued the flight logs in discovery.
+
+80. In the fall of 2009, Epstein gave a recorded interview to Rush, a reporter with the New York Daily News about pending legal proceedings. In that interview, Epstein demonstrated an utter lack of remorse for his crimes (but indirectly admitted his crimes) by stating:
+
+- People do not like it when people make good and that was one reason he (Epstein) was being targeted by civil suits filed by young girls in Florida;
+- He (Epstein) had done nothing wrong;
+
+- He (Epstein) had gone to jail in Florida for soliciting prostitution for no reason;
+- If the same thing (i.e., sexual abuse of minor girls) had happened in New York, he (Epstein) would have received only a \$200 fine;
+- J. was the one causing all of Epstein's problems (i.e., the civil suits brought by Jane Doe and other girls);
+- L.M. came to him as a prostitute and a drug user (i.e., came to Epstein for sex, rather than Epstein pursuing her);
+- All the girls suing him are only trying to get a meal ticket;
+- The only thing he might have done wrong was to maybe cross the line a little too closely;
+- He (Epstein) was very upset that had subpoenaed Ghisline Maxwell, that she was a good person that did nothing wrong (i.e., had done nothing wrong even though she helped procure young girls to satisfy Epstein's sexual desires);
+- With regard to Jane Doe 102 v. Epstein, which involved an allegation that Epstein had repeatedly sexually abused a 15-year-old girl, forced her to have sex with his friends, and flew her on his private plane nationally and internationally for the purposes of sexually molesting and abusing her, he (Epstein) flippantly said that the case was dismissed, indicating that the allegations were ridiculous and untrue.
+
+See Affidavit of Michael J. Fisten attached hereto as Exhibit "QQ."
+
+81. The Rush interview also demonstrated perjury (a federal crime) on the part of Epstein. Epstein lied about not knowing Rush. See Epstein Deposition, February 17, 2010, taken in L.M. v. Jeffrey Epstein, case 50-2008-CA-028051, page 154, line 4 through 155 line 9, (Deposition attachment #7), wherein Jeffrey Epstein clearly impresses that he does not recognize Rush from the New York Daily News. This impression was given despite the fact that he gave a lengthy personal interview about details of the case that was tape recorded with Rush.
+
+## Epstein's Harassment of Witnesses Against Him
+
+82. At all relevant times has a good faith basis to believe and did in fact believe that Epstein engaged in threatening witnesses. See Incident Report, Exhibit "A" at p. 82, U.S. Attorney's Correspondence, Exhibit "C" - Indictments drafted by Federal Government against Epstein; and Affidavit, Exhibit "N" at ¶11. A
+
+83. orders entered against Epstein (s C, supra), learned that Epstein continued to harass his victims. For example. Ja e Doe had a trial set for her civil case against him on July 19, 2010. As that trial date approached, defendant Epstein intimidated her in violation of the judicial no-contact orders. On July 1, 2010, he had a "private investigator" tail Jane Doe — following her every move, stopping when she stopped, driving when she drove, refusing to pass when she pulled over. When Jane Doe ultimately drove to her home, the "private investigator" then parked in his car approximately 25 feet from Jane Doe house and flashed his high beam lights intermittently into the home. Even more threateningly, at about 10:30 p.m., when Jane Doe fled her home in the company of a retired police officer employed by Jane Doe's counsel, the "private investigator" attempted to follow Jane Doe despite a request not to do so. The retired officer successfully took evasive action and placed Jane Doe in a secure, undisclosed location that night. Other harassing actions against Jane Doe also followed. See Motion for Contempt filed by in Jane Doe v. Epstein detailing the event, including Fisten Affidavit attached to Motion, Composite Exhibit "RR." Despite three no contact
+
+### Epstein Settlement of Civil Claims A,eainst Him for Sexual Abuse of Children
+
+84. The civil cases filed against Epstein on behalf of L.M., E.W., and Jane Doe were reasonably perceived by to be very strong cases. Because Epstein had
+
+sexually assaulted these girls, he had committed several serious torts against them and would be liable to them for appropriate damages. See Preceding Undisputed Facts. Because of the outrageousness of Epstein's sexual abuse of minor girls, reasonably expected that Epstein would also be liable for punitive damages to the girls. Because could show that Epitein had molested children for years and designed a complex premeditated scheme to procure different minors everyday to satisfy his addiction to sex with minors, the punitive damages would have to be sufficient to deter him from this illegal conduct that he had engaged in daily for years. Epstein was and is a billionaire. See Complaint, ¶49 (refrrring to "Palm Beach Billionaire:'); see also Epstein Deposition, February 17, 2010, at 172-176 (Deposition Attachment #7) (taking the Fifth when asked whether he is a billionaire). Accordingly, reasonably believed the punitive damages that would have to be awarded against Epstein would have been substantial enough to punish him severely enough for his past conduct as well as deter him from repeating his offenses in the future. See Affidavit, Exhibit "N" at 119.
+
+85. On July 6, 2010, rather than face trial for the civil suits that had been filed against him by L.M., E.W., and Jane Doe, defendant Epstein settled the cases against him. The terms of the settlement are confidential. The settlement amounts are highly probative in the instant action as Epstein bases his claims that was involved in the Ponzi scheme on Epstein's inability to settle the L.M., E.W., and Jane Doe cases for "minimal value". His continued inability to settle the claims for "minimal value" after the Ponzi scheme was uncovered would be highly probative in discrediting any causal relationship between the Ponzi scheme and settlement negotiations. See Affidavit, Exhibit "N" at ¶21.
+
+Non-Involvement in Fraud by Scott Rothstein
+
+86. From in or about 2005, through in or about November 2009, Scott Rothstein appears to have run a giant Ponzi scheme at his law firm of Rothstein, Rosenfeldt and Adler P.A. ("RRA"). This Ponzi scheme involved Rothstein falsely informing investors that settlement agreements had been reached with putative defendants based upon claims of sexual harassment and/or whistle-blower actions. Rothstein falsely informed the investors that the potential settlement agreements were available for purchase. Plea Agreement at 2, United States v. Scott W. Rothstein, No. 9-60331-CR-COHN (S.D. Fla. Jan. 27, 2010) attached hereto as Exhibit "SS."
+
+87. It has been alleged that among other cases that Rothstein used to lure investors into his Ponzi scheme were the cases against Epstein that were being handled by J. had no knowledge of the fraud 1!' any such use of the Epstein cases. See Esq. Affidavit, Exhibit "N" at ¶9.
+
+4 88. J. , Ett in about April 2009 and left RRA in November 2009 — a period of less than rZar. would not have joined RRA had he been aware that Scott Rothstein was running a giant Ponzi scheme at the firm. left RRA shortly after learning of Rothstein's fraudulent scheme. Id. at ¶8.
+
+89. At no time prior to the public disclosure of Rothstein's Ponzi scheme did know or have son to believe that Rothstein was using legitimate claims that was prosecuting against Epstein for any fraudulent or otherwise illegitimate purpose. Id. at ¶20.
+
+90. never substantively discussed the merits of any of his three cases against Epstein with Rothstein. See Deposition of taken March 23, 2010, at 110-16. (hereinafter Depo") (Deposition Attachment #22).
+
+91. On July 20, 2010, received a letter from the U.S. Attorney's Office for the Southern District of Florida — the office responsible for prosecuting Rothstein's Ponzi scheme. The letter indicated that law enforcement agencies had determined that was "a victim (or potential victim)" of Scott Rothstein's federal crimes. The letter informed of his rights as a victim of Rothstein's fraud and promised to keep informed about subsequent developments in Rothstein's prosecution. See Letter attached hereto as Exhibit
+
+92. Jeffrey Epstein filed a complaint with the Florida Bar against Esq., raising allegations that and others were nvolved in the wrongdoing of Scott Rothstein. After investigating the claim, the Florida is issed this complaint. See Affidavit, Exhibit "N" at ¶23.
+
+# Epstein Takes the Filth When Asked SubstantivdiQuestions About His Claims Against
+
+93. On March 17, 2010, defendant Epstein was deposed about his lawsuit against Rather than answer substantive questions about his lawsuit, Epstein repeatedly invoked his Fifth Amendment privilege. See Epstein Depo. taken 3/17/10, Deposition Attachment #1.
+
+94. In his deposition, Epstein took the Fifth rather than answer the question: "Specifically what are the allegations against you which you contend Mr. ginned up?" Id. at 34.
+
+95. In his deposition, Epstein took the Fifth rather than name people in California that had tried to depose to increase the settlement value of the civil suit he was handling. Id. at 37.
+
+96. In his deposition, Epstein took the Fifth rather than answer the question: "Do you know former President Clinton personally." Id.
+
+97. In his deposition, Epstein took the Fifth rather than answer the question: "Are you now telling us that there were claims against you that were fabricated by Mr. Id. at 39.
+
+98. In his deposition, Epstein took the Fifth rather than answer the question, "Well, which of Mr. la cases do you contend were fabricated." Id.
+
+99. In his deposition, Epstein took the Fifth rather than answer the question: "What is the actual value that you contend the claim of E.W. against you has?" Id. at 45.
+
+100. In his deposition, Epstein took the Fifth rather than answer a question about the actual value of the claim of L.M. and Jane Doe against him. Id.
+
+101. In his deposition, taken prior to the settlement of clients claims against Epstein, Epstein took the Fifth rather than answer the question: "Is there any pending claim against you which you contend is fabricated?" Id. at 71.
+
+102. In his deposition, Epstein took the Fifth rather than answer the question: "Did you ever have damaging evidence in your garbage?" Id. at 74.
+
+103. deposition, Epstein took the Fifth rather than answer the question: "Did sexual asseuiilever take place on a private airplane on which you were a passenger?" Id. at 88.
+
+104. In his deposition, Epstein took the Fifth rather than answer the question: "Does a flight log kept for a private jet used by you contain the names of celebrities, dignitaries or international figures?" Id. at 89.
+
+105. In his deposition, Epstein took the Fifth rather than answer the question: "Have you ever socialized with Donald Trump in the presence of females under the age of 18?" Id. at 89.
+
+106. In his deposition, Epstein took the Fifth rather than answer the question: "Have you ever socialized with Alan Dershowitz in the presence of females under the age of 18." Id. at 90..
+
+107. In his deposition, Epstein took the Fifth rather than answer the question: "Have you ever socialized with Mr. Mottola in the presence of females under the age of 18?" Id. at 91- 92.
+
+108. In his deposition, Epstein took the Fifth rather than answer the question: "Did you ever socialize with David Copperfield in the presence of females under the age of 18?" Id. at
+
+109. In his deposition, Epstein took the Fifth rather than answer the question: "Have you ever socialized with Mr. Richardson [Governor of New Mexico and formerly U.S. Representative and Ambassador to the United Nations] in the presence of females under the age of 18." Id. at 94.
+
+110. In his deposition, Epstein took the Fifth rather than answer the question: "Have you ever sexually abused children?" Id. at 95.
+
+11 I. In his deposition, Epstein took the Fifth rather than answer the question: "Did you have staff members that assisted you in scheduling appointments with underage females; that is, females under the age of 18." Id. at 97-98.
+
+112. In his deposition, Epstein took the Fifth rather than answer the question: "On how many occasions did you solicit prostitution." Id. at 102.
+
+113. In his deposition, Epstein took the Fifth rather than answer the question: "How many minors have you procured for prostitution?' Id. at 104.
+
+114. In his deposition, Epstein took the Fifth rather than answer the question: "Have you ever coerced, induced or enticed any minor to engage in any sexual act with you?" Id. at 107. A.
+
+115. In his deposition, Epstein took the Fifth rather than answ many times have you engaged in fondling underage females?" Id. at t AR ,estion: "How
+
+116. In his deposition, Epstein took the Fifth rather t t. answer the question: "How many times have you engaged in oral sex with females under the age of 18?" Id. at 110.
+
+117. In his deposition, Epstein took the Fifth rather than answer the question: "Do you have a personal sexual preference for children?" / at.I11-12.
+
+118. In his deposition, Epstein k t Fifth rather than answer the question: "Your Complaint at page 27, paragraph 49, says Rat `RIZA and the litigation team took an emotionally driven set of facts involving alleged innocent, unsuspecting, underage females and a Palm Beach billionaire, and sought to turn it into a goldmine,' end of quote. Who is the Palm Beach billionaire referred to in that sentence?" Id. at 112-13.
+
+119. In his deposition, Epstein took the Fifth rather than answer the question: "Who are the.peopie who are authorized to make payment [to your lawyers] on your behalf?" Id. at 120.
+
+120. In his deposition, Epstein took the Fifth rather than answer the question: "Is there anything in L.M.'s Complaint that was filed against you in September of 2008 which you contend to be false?" Id. at 128.
+
+### CERTIFICATE OF SERVICE
+
+I HEREBY CERTIFY that on November r,;010 a copy of the foregoing has been served via Fax and U.S. Mail to all those on the attached service list.
+
+By:
+
+Jack Scarola Searcy, Denney, Scarola, Barnhart & Shipley 2139 Palm Beach Lakes Blvd West Palm Beach, F 33409 (561) 686- (561
+
+OLA ar No.: 169440
+
+## SERVICE LIST
+
+E. Knight, Esq. L. Ackerman, Esq. BURNET1' P.A. 901 Point West 777 South Flaglcr Drive Wcst Palm Beach, FL 33401
+
+Jack Alan Goldberger, Esq. Atterbury Goldberger et al. 250 Australian Avenue South Suite 1400 West Palm Beach, FL 33401
+
+Marc S. Nurik, Esq. Law Offices of Marc S. Nurik One E. Broward Blvd., Suite 700 Fort Lauderdale, FL 33301
+
+Gary M. Jr. Jaffe, Weissing, Fistos & Lehrman, P. 425 N. Andrews Ave., Su Fort Lauderdale, FL )330
+
+04

marker2/court-epstein-v-rothstein/EFTA02770202/EFTA02770202.metadata.json

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marker2/court-epstein-v-rothstein/EFTA02770245/EFTA02770245.md

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+## IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY CIVIL DIVISION
+
+CASE NO.: 502009CA040800 AG
+
+JEFFREY EPSTEIN,
+
+Plaintiff(s), vs.
+
+SCOTT ROTHSTEIN, etc., et al.,
+
+Defendant(s).
+
+## ORDER SETTING HEARING
+
+THIS CAUSE came before the Court in upon the Plaintiff/Cpiitte\* Defendant, JEFFREY EPSTEIN's Motion for Clarification Regarding Discovery, and the Court having reviewed the matter, it is
+
+ORDERED AND ADJUDGED that a hearing on Plaintiff/Counter-Defendant, JEFFREY EPSTEIN's Motion for Clarification Regarding Discovery is scheduled in the above-entitled matter for Monday, December 19, 2011 at 2:00 p.m. before the undersigned, at the Palm Beach County Courthouse, 205 N. Dixie Highway, Courtroom 9C, West Palm Beach, FL 33401. (15 mins. reserved)
+
+- O Pa 7PS Ce r ^11 np ig • .503 43 '• • Ca, a... 0A n en • Car . Po• r • csi rr, Ciro?, me in ' rn ..en trrcrCi.
+
+In accordance with the Americans With Disabilities Act, persons in need of a special accommodation to participate in this proceeding shall, within reasonable time prior to any proceeding, contact the Administrative Office of the Court, 205 No Highway, Room 5.25, West Palm Beach, Florida 33401, telephone (561) 355-2431, 1-800-955-87 or 1.800-955.8770 (V), via Florida Rclay Service.
+
+## Please Note:
+
+- r s14/
+- 1. The JA cannot cancel this hearing unless the issue is resolved.
+- 2. No add-ons are permitted without contacting the .JA.
+- 3. Any Memorandums submitted are limited to 10 double spaced pages and must reference the hearing date.
+- 4. Any materials submitted are due at least 7 days prior to the hearing.
+- 5. The moving party is required to bring to the hearing a proposed order with copies and envelopes for all counsel/parties.
+
+2011. M I 4 DONE AND ORDERED at West Palm Be rida this - —ay of November,
+
+CIRCUIT COURT JUDGE
+
+Copy furnished: JACK SCAROLA, ESQUIRE, 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409 L. ACKERMAN, JR., ESQUIRE, 777 S. Flagler Dr., 901 Point West, West Palm Beach, FL 33401 JACK GOLDBERGER, ESQUIRE, 250 Australian Ave. S., Suite 1400, West Palm Beach, FL 33401 MARC NURIK ESQUIRE, One E. Broward Blvd., Suite 700, Ft. Lauderdale, FL 33301 E. KNIGHT, ESQUIRE, 1395 Brickell Ave., 14th Floor, Miami, FL 33131

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marker2/court-epstein-v-rothstein/EFTA02770246/EFTA02770246.md

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+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA  
+IN AND FOR PALM BEACH COUNTY
+
+CIVIL DIVISION
+
+CASE NO.: 502009CA040800 AG
+
+JEFFREY EPSTEIN,
+
+Plaintiff(s),  
+vs.
+
+SCOTT ROTHSTEIN, etc., et al.,
+
+Defendant(s).
+
+FILED  
+2011 NOV 17 PM 4:06  
+SHARON R. BOCK, CLERK  
+PALM BEACH COUNTY, FL  
+CIRCUIT CIVIL 5
+
+ORDER ON PLAINTIFF/COUNTER-DEFENDANT EPSTEIN'S  
+MOTION FOR CLARIFICATION
+
+THIS CAUSE having come before the Court upon the Plaintiff/Counter-Defendant, JEFFREY EPSTEIN's Motion for Clarification, and the Court having heard argument of counsel, and being otherwise fully advised in the premises, it is hereby
+
+CONSIDERED, ORDERED AND ADJUDGED that discovery will not be postponed until [REDACTED] J. EDWARDS' Amended Counterclaim withstands a Motion to Dismiss. The Court makes no other rulings in regard to purported discovery and will rule on those issues on an issue by issue basis.
+
+DONE AND ORDERED this 17<sup>th</sup> day of November, 2011 at West Palm Beach, Palm Beach County, Florida.
+
+![]()Copy furnished:  
+JACK SCAROLA, ESQUIRE, 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409  
+[REDACTED] L. ACKERMAN, JR., ESQUIRE, 777 S. Flagler Dr., 901 [REDACTED] Point West, West Palm Beach, FL 33401  
+JACK GOLDBERGER, ESQUIRE, 250 Australian Ave. S., Suite 1400, West Palm Beach, FL 33401  
+MARC NURIK, ESQUIRE, One E. Broward Blvd., Suite 700, Ft. Lauderdale, FL 33301  
+GARY M. [REDACTED], JR., ESQUIRE, 425 N. Andrews Ave., Suite 2, Ft. Lauderdale, FL 33301

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marker2/court-epstein-v-rothstein/EFTA02770247/EFTA02770247.md

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+## IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY CIVIL DIVISION
+
+rn r -A .711) g:3 0 0
+
+CASE NO.: 502009CA040800 AG .43% 14. %
+
+JEFFREY EPSTEIN, c%4
+
+Plaintiff(s), S vs.
+
+SCOTT ROTHSTEIN, etc., et al.,
+
+Defendant(s).
+
+## ORDER ON PLAINTIFFS RENEWED MOTION FOR PROTECTIVE ORDER RELATING TO HIS DEPOSITION
+
+THIS CAUSE having come before the Court upon the Plaintiff's Renewed Motion for Protective Order Relating to His Deposition, and the Court having heard argument of counsel, and being otherwise fully advised in the premises, it is hereby
+
+CONSIDERED, ORDERED AND ADJUDGED that the Motion is denied. However, the Defendant/Counter-Claimant, J. may not use as a basis for further deposition of the Plaintiff the fact that his Counterclaim is not at issue at present. Furthermore, the Court does not rule on any "privilege" issues and counsel should raise those objections at the time of the deposition. If the Plaintiff believes that the deposition is proceeding in a bad faith manner or discovery is attempted in regard to issues which are either burdensome, oppressive or merely harassing, Plaintiff has the right to his remedies pursuant to Florida Rules of Civil Procedure, including but not limited to terminating the deposition and seeking a protective order as to specific questions in the deposition. Furthermore, this Court does not place any limitations on the manner,
+
+method or mode of the taking of the deposition, including the fact that it may be taken by video.
+
+DONE AND ORDERED this'day of at West Palm Beach, Palm Beach County, Florida.
+
+Copy furnished:
+
+JACK SCAROLA, ESQUIRE, 2139 Palm Beach Lakes Blvd., Waia Beach, FL 33409 L. ACKERMAN, JR., ESQUIRE, 777 S. Flagler Dr., 901 Phillips Point West, West Palm Beach, FL 33401 • JACK GOLDBERGER, ESQUIRE, 250 Australian Ave. S., Suite 1400, West Palm Beach, FL 33401 MARC NUR11..UIRE, One E. Broward Blvd., Suite 700, Ft. Lauderdale, FL 33301 GARY M. , JR., ESQUIRE, 425 N. Andrews Ave., Suite 2, Ft. Lauderdale, FL 33301
+
+V:SI Y
+
+/lv
+
+DAVID F. CIRCUIT COURT JUDGE

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marker2/court-epstein-v-rothstein/EFTA02770249/EFTA02770249.md

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+IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA  
+IN AND FOR PALM BEACH COUNTY
+
+CIVIL DIVISION
+
+CASE NO.: 502009CA040800 AG
+
+JEFFREY EPSTEIN,
+
+Plaintiff(s),  
+vs.
+
+SCOTT ROTHSTEIN, etc., et al.,
+
+Defendant(s).
+
+SHARON R. BOCK, CLERK  
+PALM BEACH COUNTY, FL  
+CIRCUIT CIVIL 5
+
+**FILED**
+
+2011 NOV 21 PM 3:52
+
+ORDER ON PLAINTIFF/COUNTER-DEFENDANT EPSTEIN'S  
+MOTION TO DISMISS AMENDED COUNTERCLAIM
+
+THIS CAUSE having come before the Court upon the Plaintiff/Counter-Defendant, JEFFREY EPSTEIN's Motion to Dismiss Amended Counterclaim, and the Court having heard argument of counsel, and being otherwise fully advised in the premises, it is hereby
+
+CONSIDERED, ORDERED AND ADJUDGED that the Motion is granted with leave to amend within twenty (20) days. The Counter-Plaintiff shall set forth with more specificity the alleged improper or perverted use of process and ulterior motive or purposes. Count II fails to allege a specific bona fide termination of prior prosecution and also incorporates all previous allegations.
+
+DONE AND ORDERED this 21<sup>st</sup> day of November, 2011 at West Palm Beach, Palm Beach County, Florida.
+
+![]()Copy furnished:  
+JACK SCAROLA, ESQUIRE, 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409  
+[REDACTED] L. ACKERMAN, JR., ESQUIRE, 777 S. Flagler Dr., 901 [REDACTED] Point West, West Palm Beach, FL 33401  
+JACK GOLDBERGER, ESQUIRE, 250 Australian Ave. S., Suite 1400, West Palm Beach, FL 33401  
+MARC NURIK, ESQUIRE, One E. Broward Blvd., Suite 700, Ft. Lauderdale, FL 33301  
+GARY M. [REDACTED], JR., ESQUIRE, 425 N. Andrews Ave., Suite 2, Ft. Lauderdale, FL 33301

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marker2/court-epstein-v-rothstein/EFTA02770250/EFTA02770250.md

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+IN THE CIRCUIT COURT OF THE  
+FIFTEENTH JUDICIAL CIRCUIT, IN AND  
+FOR PALM BEACH COUNTY, FLORIDA
+
+CASE NO.: 502009CA040800XXXXMBAG
+
+JEFFREY EPSTEIN,
+
+Plaintiff(s),
+
+vs.
+
+SCOTT ROTHSTEIN, individually,  
+██████████ J. ██████████, individually, and  
+L.M., individually,
+
+Defendant(s).
+
+FILED  
+11 NOV 22 PM 3:54  
+SHARON R. BOCK, CLERK  
+PALM BEACH COUNTY, FL  
+CIRCUIT CIVIL 4
+
+NOTICE OF HEARING
+
+**YOU ARE HEREBY NOTIFIED** that the undersigned has called up for hearing the  
+following:
+
+**DATE:** November 28, 2011
+
+**TIME:** 8:45 a.m.
+
+**JUDGE:** Honorable David F. ██████████ (Palm Beach County Courthouse)
+
+**PLACE:** 205 N. Dixie Highway, West Palm Beach, FL 33401
+
+**ROOM #:** 9-C
+
+**SPECIFIC MATTERS TO BE HEARD:**
+
+██████████ MOTION TO SCHEDULE HEARING ON  
+██████████ RENEWED MOTION FOR SUMMARY JUDGMENT
+
+Moving counsel certifies that he or she contacted opposing counsel and attempted to  
+resolve the dispute without hearing.
+
+Fax and U.S. Mail to all Counsel on the attached list, this I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by
+
+> JAC Flo Sa AROL ar No.: 169440 y Denney Scarola Barnhart & Shipley 9 Palm Beach Lakes Boulevard est Palm Beach, Florida 33409 Phone:. (561) 686-6300 Fax: (561) 383-91. Attorney for Bradley J.
+
+adv. Epstein Case No.: 502009CA040800XXXXMBAG Notice of Hearing
+
+10 day of November, 2011.
+
+AS H\
+
+[REDACTED] adv. Epstein  
+Case No.: 502009CA040800XXXXMBAG  
+Notice of Hearing
+
+**COUNSEL LIST**
+
+Jack A. Goldberger, Esquire  
+jgoldberger@agwpa.com; smahoney@agwpa.com  
+Atterbury, Goldberger & Weiss, P.A.  
+250 Australian Avenue South, Suite 1400  
+West Palm Beach, FL 33401  
+Phone: (561)-659-8300  
+Fax: (561)-835-8691  
+Attorneys for Jeffrey Epstein
+
+[REDACTED], Jaffe, Weissing, [REDACTED], Fistos & Lehrman, PL  
+425 N. Andrews Avenue, Suite 2  
+Fort Lauderdale, FL 33301  
+Phone: (954)-524-2820  
+Fax: (954)-524-2822  
+Attorneys for Jeffrey Epstein
+
+[REDACTED] L. Ackerman, Jr., Esquire  
+[REDACTED]; LRoberts@fowler-white.com  
+[REDACTED] Burnett, P.A.  
+901 [REDACTED] Point West  
+777 S Flagler Drive  
+West Palm Beach, FL 33401-6170  
+Phone: (561)-802-9044  
+Fax: (561)-802-9976  
+Attorneys for Jeffrey Epstein
+
+Marc S. Nurik, Esquire  
+marc@nuriklaw.com  
+Law Offices of Marc S. Nurik  
+One E Broward Blvd., Suite 700  
+Fort Lauderdale, FL 33301  
+Phone: (954)-745-5849  
+Fax: (954)-745-3556  
+Attorneys for Scott Rothstein
+
+"If you are a person with a disability who needs any accommodation in order to participate in this proceeding, you are entitled, at no cost to you, to the provision of certain assistance. Please contact Krista Garber, Americans with Disabilities Act Coordinator, at least 7 days before your scheduled court appearance, or immediately upon receiving this notification if the time before the scheduled appearance is less than 7 days; if you are hearing or voice impaired, call 711."
+
+"Si usted es una persona minusvidida que necesita algiin acomodamiento para poder participar en este procedimiento, usted tiene derecho, sin tener gastos propios, a que se le provea cierta ayuda. Tenga la amabilidad de ponerse en contacto con Krista Garber Americans with Disabilities Act Coordinator" por lo menos 7 dias antes de la cita fijada para su comparecencia en los tribunales, o inmediatamente despuis de recibir esta notification si el tiempo antes de la comparecencia que se ha programado es menos de 7 dias; si usted tiene discapacitacion del oido o de la voz, (lame al 711."
+
+"Si ou se yon moun ki enfim ki bezwen akomodasyon pou w ka patisipe nan pwosedi sa, ou kalifye san ou pa gen okenn lajan pou w peye, gen pwovizyon pou jwen kik id. Tanpri kontakte nan 7 jou anvan dat ou gen randevou pou parit nan tribinal la, oubyen imedyatman apre ou fin resevwa konvokasyon an si le ou gen pou w park nan tribinal la mwens ke 7 jou; si ou gen pwoblim pou w tande oubyen pale, rele 711."

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marker2/court-epstein-v-rothstein/EFTA02770254/EFTA02770254.md

@@ -0,0 +1,51 @@
+IN THE CIRCUIT COURT OF THE  
+FIFTEENTH JUDICIAL CIRCUIT, IN AND  
+FOR PALM BEACH COUNTY, FLORIDA
+
+CASE NO.: 502009CA040800XXXXMBAG
+
+JEFFREY EPSTEIN,
+
+Plaintiff(s),
+
+vs.
+
+SCOTT ROTHSTEIN, individually,  
+[REDACTED] J. [REDACTED], individually, and  
+L.M., individually,
+
+Defendant(s).
+
+FILED  
+11 NOV 22 PM 3: 54  
+SHARON R. BOCK, CLERK  
+PALM BEACH COUNTY, FL  
+CIRCUIT CIVIL 4
+
+**MOTION TO SCHEDULE HEARING ON DEFENDANT/COUNTER-PLAINTIFF'S  
+RENEWED MOTION FOR SUMMARY JUDGMENT**
+
+Defendant/Counter-plaintiff, [REDACTED] J. EDWARDS, moves this Honorable Court to set the Defendant/Counter-plaintiff's Renewed Motion for Summary Judgment for hearing and in support of this motion would show that the Plaintiff/Counter-defendant's counsel has been unresponsive and uncooperative in multiple attempts to set these matters without the need for Court intervention.
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Fax and U.S. Mail to all Counsel on the attached list, this 18<sup>th</sup> day of November, 2011.
+
+![]()Jack Scarola  
+Florida Bar No.: 169440  
+Search Denney Scarola Barnhart & Shipley  
+2139 Palm Beach Lakes Boulevard  
+West Palm Beach, Florida 33409  
+Phone: (561) 686-6300  
+Fax: (561) 383-9451  
+Attorney for [REDACTED] J. [REDACTED]
+
+adv. Epstein Case No.: 502009CA040800XYJCXMBAG Motion to Schedule Defendant/Counter-plaintiff's Renewed Motion for SJ for hearing
+
+## COUNSEL LIST
+
+Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: (561) 659-8300 Fax: (561) 835-8691
+
+Farmer, Jaffe, Weissing, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954) 524-2820 Fax: (954) 524-2822
+
+Marc S. Nurik, Esquire Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954) 745-5849 Fax: (954) 745-3556
+
+L. Ackerman, Jr., Esqu Burnett, P. 901 Point West 777 S Flagler Drive West Palm Beach, FL 33401-6170 Phone: (561) 802-9044 Fax: (561) 802-9976

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marker2/court-epstein-v-rothstein/EFTA02770256/EFTA02770256.md

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+## IN THE CIRCUIT COURT OF THE 151° JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA
+
+CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F.
+
+JEFFREY EPSTEIN,
+
+Plaintiff/Counter-Defendant,
+
+v.
+
+SCOTT ROTHSTEIN individually and J. individually,
+
+Defendants/Counter-Plaintiffs.
+
+## ',C PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR ENLARGEMENT OF TIME TO RESPOND TO DISCOVERY
+
+fit rn
+
+Plaintiff/Counter-Defendant JEFFREY EPSTEIN ("Epstein"), by and through undersigned counsel and pursuant to the Florida Rules of Civil Procedure, hereby moves for an enlargement of time to respond to the discovery requests propounded by Defendant/Counter-Plaintiff J.
+
+on October 28, 2011. The grounds for this Motion are as follows:
+
+- 1. On October 28, 2011, the Defendant/Counter-Plaintiff J. be
+
+served by facsimlectid U.S. Mail the following discovery requests on counsel for Epstein:
+
+- Arl"••\ Request to Produce to Jeffrey Epstein
+  - b) Interrogatories to Plaintiff
+- 2. The deadline for responding to the discovery requests is November 28, 2011.
+- 3. Due to the intervening holiday and the press of other business, Plaintiff requests an extension of fourteen (14) days within which to serve responses to the discovery requests.
+
+4. In addition, counsel for the Plaintiff understood all discovery was stayed pending all pleadings being at issue. On or about November 17, 2011, the Court ruled discovery will not be postponed until MF Counterclaim withstands a Motion to Dismiss.
+
+5. The Defendant/Counter-Plaintiff will not sustain any prejudice as a result of a short extension being granted to Plaintiff to respond to these discovery requests.
+
+6. Undersigned counsel certifies that this request is made in good faith and not for the purpose of delay. The undersigned counsel further certifies that he has and will continue to make an effort to resolve this matter without the need of a hearing.
+
+WHEREFORE, the PlaintifVCounter-Defendant Jeffrey Epstein respectfully requests that this Court grant an extension of fourteen (14) days, up to and including December 12, 2011, in which to serve his responses to the discovery requests.
+
+## CERTIFICATE OF SERVICE
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via U.S. Mail on this 28th day of November, 2011 to: Jack Scarola, Esq., Searcy Denney Scarola et al., 2139 Palm Beach Lakes Boulevard, West Palm Beach, FL 33409; Jack Alan Goldberger, Esq., Atterbury, Goldberger & Weiss, PS., 250 Australian Avenue South, Suite 1400, West Palm Beach, FL 33401- 5012; and Marc S. Nurik, Esq., Law Offices of Marc S. Nurik, One East Broward Boulevard, Suite 700, Fort Lauderdale, FL 33301.
+
+Respectfu ly submitted,
+
+\ oset. Ackerman, Jr. Florida Bar No. 235954 BURNETT, P.A.
+
+BURNETT, P.A. 901 Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: (561) 802-9044 Facsimile: (561) 802-9976 Attorneys for Plaintiff, Jeffrey Epstein
+
+and
+
+E. Knight Florida No. 607363 M ari BUFtNETT, P.A. aza, 14th Floor 1395 Brickell Avenue Miami, Florida 33131 Telephone: (305) 789-9200 Facsimile: (305)789-9201 Attorneys for Plaintiff, Jeffrey Epstein

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marker2/court-epstein-v-rothstein/EFTA02770259/EFTA02770259.md

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+#291874/mep
+
+IN THE CIRCUIT COURT OF THE  
+FIFTEENTH JUDICIAL CIRCUIT, IN AND  
+FOR PALM BEACH COUNTY, FLORIDA
+
+CASE NO.: 502009CA040800XXXXMBAG
+
+JEFFREY EPSTEIN,
+
+Plaintiff(s),
+
+vs.
+
+SCOTT ROTHSTEIN, individually,  
+██████████ J. ██████████, individually, and  
+L.M., individually,
+
+Defendant(s).
+
+2011 NOV 29 PM 3:23  
+SHARON R. BOCK, CLERK  
+PALM BEACH COUNTY  
+CIVIL
+
+**RE-NOTICE OF TAKING VIDEO DEPOSITION**
+
+TO: All counsel on the attached Counsel List
+
+PLEASE TAKE NOTICE that the undersigned attorneys will take deposition(s) of:
+
+**NAME AND ADDRESS**
+
+Jeffrey Epstein
+
+**DATE AND TIME**
+
+December 14, 2011  
+9:30 a.m.
+
+**LOCATION**
+
+Searcy Denney, et al  
+2139 Palm Beach Lakes  
+Boulevard, WPB
+
+VIDEOGRAPHER: To be arranged by Phipps Reporting
+
+upon oral examination before Phipps Reporting, a Notary Public; or any other officer authorized by law to take depositions in the State of Florida. The oral examination is being taken for the purpose of discovery, for use at trial, or for such other purposes as are permitted under the applicable Statutes or Rules.
+
+[REDACTED] adv. Epstein  
+Case No. 502009CA040800XXXXMBAG  
+Notice of Taking Video Deposition  
+Page 2
+
+I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by  
+Fax and U.S. Mail to all Counsel on the attached list, this 23<sup>rd</sup> day of November, 2011.
+
+![](_page_1_Picture_93.jpeg)
+
+Jack Scarola  
+Florida Bar No.: 169440  
+Searcy Denney Scarola Barnhart & Shipley  
+2139 Palm Beach Lakes Boulevard  
+West Palm Beach, Florida 33409  
+Phone: (561) 686-6300  
+Fax: (561) 383-9451  
+Attorney for [REDACTED] J. [REDACTED]
+
+cc: Phipps Reporting
+
+**E-TRANSCRIPT, ASCII, CD AND/OR DVD REQUESTED**
+
+**AMERICANS WITH DISABILITIES ACT**
+
+In accordance with the Americans With Disabilities Act, persons in need of a special accommodation to participate in this proceeding should contact the Human Resources Manager, Searcy Denney Scarola Barnhart & Shipley, P.A., no later than seven days prior to the proceeding. Please telephone (561) 686-6300.
+
+adv. Epstein Case No. 502009CA040800XXXXMBAG Notice of Taking Video Deposition Page 3
+
+## COUNSEL LIST
+
+Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. Phone: (561)-659-8300 Fax: (561)-835-8691 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401
+
+Jaffe, eissing, Fistos & Fort Lauderdale, FL 33301 Lehrman, PL 425 N. Andrews Avenue, Suite 2 Phone: (954)-524-2820 Fax: (954)-524-2822
+
+S 9
+
+L. Ackerman, Jr., Esquire Burnett, P.A. 901 Point West 777 S Flagler Drive West Palm Beach, FL 33401-6 '7i) Phone: (561)-802-9044 Fax: (561)-802-9976
+
+Marc S. Nurik, Esquire marc®nuriklaw.com Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954)-745-5849 Fax: (954)-745-3556

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