Filing E-Filed PM IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendant I RESPONSE IN OPPOSITION TO JEFFREY EPSTEINS SUPPLEMENTAL MOTION FOR CONTINUANCE OF TRIAL Counter-Plaintiff Bradley Edwards Edwards by and through undersigned counsel hereby files this Response in Opposition to Plaintiff/Counter-Defendant Jeffrey Epsteins Supplemental Motion for Continuance of Trial and as grounds thereof states as follows On November Epstein filed his Supplemental Motion for Continuance of Trial which included the following incorrect assertions a Edwards changed his damages claim by adding reputational damages on October when he disclosed expert witness Bernard Jansen Ph.D Edwards Seventh Amended Witness List disclosed for the first time that certain fact witnesses would also provide expert witness testimony namely the attorneys who represented Epsteins child victims in sexual abuse litigation and Edwards Seventh Amended Witness List was the first time William Berger Esq was disclosed FILED PALM BEACH COUNTY FL SHARON BOCK CLERK PM Edwards adv Epstein Case No Response in Opposition to Epsteins Supplemental Motion for Continuance of Trial Reputational Damages As to the first issue Edwards has pled damages to his reputation in every malicious prosecution counterclaim that he has filed in this case beginning in a Amended Counterclaim at filed October Second Amended Counterclaim at filed November Third Amended Counterclaim at filed May and Fourth Amended Counterclaim at filed January Epstein has therefore been aware of the reputational damages claim for six years and any claim to the contrary is wholly without merit and is belied by the pleadings in this case Expert Witness Disclosure As to the second and third issues Epstein has been on notice since that the attorneys who represented his child victims were expected to provide both fact and opinion testimony in this case Specifically on December Edwards served his Answers to First Set of Expert Witness Interrogatories in which he stated as follows in response to Epsteins request for the disclosure of all experts whom you expect to call as an Expert witness at trial Bradley Edwards has not retained any experts at this time However it is expected that some or all of the attorneys who have prosecuted civil claims against Jeffrey Epstein arising out of his abuse of children will be called to testify on behalf of Edwards and may express opinions regarding the services rendered by Edwards on behalf of his clients Subsequent witness lists have consistently and repeatedly conveyed the same intent to rely upon the fact and opinion testimony of the attorneys who were simultaneously prosecuting child molestation claims jointly with Bradley Edwards against Epstein Despite these disclosures there was never a request to depose any of these attorneys at any Edwards adv Epstein Case No Response in Opposition to Epsteins Supplemental Motion for Continuance of Trial time prior to November That is Epstein has waited over years until less than weeks before the close of discovery and only approximately weeks before trial to seek discovery of these witnesses Moreover these disclosures cover William Berger Esquire who in was disclosed as an attorney who provided substantive services in the prosecution of sexual abuse claims against Jeffrey Epstein Specifically Edwards Answers to Epsteins Third Set of Interrogatories which were served on January included the following question and answer Identify all attorneys who worked on the client cases against Plaintiff/Counter Defendant Jeffrey Epstein including but not limited to the attorneys formerly at Rothstein Rosenfeldt Adler the attorneys at Farmer Jafe Weissing Edwards Fistos Lehrman PL outside attorneys and referring attorneys A Bradley Edwards Paul Cassell Matt eissing Steve Jaffee and Bill Berger rendered substantive services in the prosecution of claims against Jeffrey Epstein Russell Adler was in attendance at multiple depositions but was not an active participant Bradley Edwards was in fact specifically questioned about William Berger when deposed for the first time more than seven years ago in A time line of the entirety of Epsteins witness deposition efforts is attached as Exhibit A Edwards was also questioned about William Berger Esq at his March deposition more than seven years ago See Deposition Transcript at pages and Edwards adv Epstein Case No Response in Opposition to Epsteins Supplemental Motion for Continuance of Trial Conclusion For the foregoing reasons Counter-Plaintiff respectfully requests that this Court deny Epsteins Motion for Continuance of Trial and Supplement thereto and allow this eight year old case to finally proceed to trial I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve I I to all Counsel on the attached list this _1 __ day of __ N_D_V E-Mail jsx searcylaw.com and ann searcylaw.com Pr mary E-Mail _scarolateam searcylaw.com Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard West Palm Beach Florida Phone Fax Attorneys for Bradley Edwards Edwards adv Epstein Case No Response in Opposition to Epsteins Supplemental Motion for Continuance of Trial COUNSEL LIST Scott Link Esq Link Rockenbach P.A Scott linkrocklaw.com Kara linkrocklaw.com Palm Beach Lakes Boulevard Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein William Chester Brewer Esquire wcblaw aol.com wcblawasst gmail.com Australian A venue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Jack A Goldberger Esquire jgoldberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Nichole Segal Esquire njs FLAppellateLaw.com kbt FLAppellateLaw.com Burlington Rockenbach P.A Railroad A venue Suite West Palm Beach FL Phone Attorneys for Bradley Edwards Bradley Edwards Esquire staff.efile pathtojustice.com Andrews Avenue Suite Fort Lauderdale FL Edwards adv Epstein Case No Response in Opposition to Epsteins Supplemental Motion for Continuance of Trial Phone Fax Fred Haddad Esquire Dee FredHaddadLaw.com Fred FredHaddadLaw.com Fred Haddad P.A One Financial Plaza Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Tonja Haddad Coleman Esquire tonja tonjahaddad.com efiling tonjahaddad.com Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com One Broward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein EXHIBIT A HISTORY OF EPSTEINS DEPOSITION CONDUCT DATE WITNESS ES DATE DEPO TAKEN OF SCHEDULED NOTICE Scott Rothstein c/o Marc Murkin Esq Michael Fisten Richard Fandry Herbert Stettin Trustee in Bankruptcy for Cancelled Rothstein Rosenfeldt Adler PA Gary Farmer corrected Apparently misdated and Cancelled should be Mike Fisten Russell Adler Cancelled Ken Jenne Cancelled Scott Rothstein Gary Farmer Cancelled Debra Villegas Cancelled A.J Discala YES on Thane Richie Cancelled Michael Legamaro Cancelled Dean Kretschmar YES on Herbert Stettin Trustee for Bankruptcy for RRA Cancelled Mike Fisten corrected Russell Adler corrected Cancelled Herbert Stettin Trustee in Bankruptcy for RRA Cancelled Scott Rothstein corrected YES Ken Jenne corrected Cancelled Debra Villegas corrected Cancelled Dean Kretschmar Re-Notice YES Cancellation of Russell Adler Cancelled Cancellation of Herb Stettin Cancelled Cancellation of Ken Jenne Cancelled Cancellation of Debra Villegas Cancelled Cancellation of Gary Farmer Cancelled Cancellation of Michael Legamaro Cancelled Cancellation of Thane Ritchie Cancelled A.J Discala YES on Thane Ritchie Cancelled A.J Discala Re-Notice YES on Michael Legamaro YES RIC Herbert Stettin Trustee in Bankruptcy for Cancelled RRA A.J Discala Re-Notice YES on Russell Adler YES AJ Discala Re-Notice YES on AJ Discala Re-Notice YES Cara Holmes Cancelled Cara Holmes Re-Notice Cancelled Cancellation of Cara Holmes Cancelled Bradley YES Edwards Bradley Edwards YES Bradley Edwards Amended YES Bradley Edwards YES Attorney Coleman requested deposition dates for witnesses LM EW Jane Dow and Virginia Roberts Mr Edwards attorney responded with dates available in the first weeks of October and to call to clear specific dates Ms Coleman asked Mr Edwards to confirm that he would accept service for the clients LM EW and Jane Doe Mr Edwards confirmed that he would accept service Mr Edwards requested that Ms Coleman specify which dates in early October she choses to take depositions Ms Coleman selected dates between Oct and October Mr Edwards counsel provided dates and Ms Coleman instructed Mr Edwards counsel to hold and Mr Edwards confirmed that he would make his clients available on any date Courtney Moody YES Bradley Edwards YES Re-Notice Courtney Moody YES Virginia Roberts NO Cancelled unilaterially by Epsteins counsel on EW in prison YES Epsteins counsel noticed Virginia Roberts for and EW in prison for On they unilaterally cancelled Virginia Roberts deposition Epsteins counsel never used and never set anyone for The only date they made use of was the date EW was deposed No other depositions were attempted to be set until a request was made on to depose Dr James Jansen and a request was made on to depose attorneys A A 4A E0 A4 DE a qr?q rq qrCX HhL Kg lg d?a d6U a M3 flW y??S m/y t0 I F/Z V/j 1a qC KS u?v vZ O5 a qr rCX qC 0V I I dc rM?M rM 10Cy n??m?n k?o?h I A I w?!ac qr MCX 10Cy ITy qr M3 Ґ??1rA5R h?H?T3P K?z X?K I v"x i X5 EO5 5a r?q CX 9r Cy rq rqC M3 ş?:c p/p0 5H V)V 6T Y2 G5 qrM?r?qr?r9 q?10Cy rCX qr l1 X?l 3K fm?Q Z2f CX CX gT L??T 2E Cy 3P EM3 J4T L?h??M q?ᡚ?Y r??O?rJt CTX i P!e i I CTX rC YY I 1e 2j CTX X0T1i k3v Jh/e0h1 H(K W/Q0 CTX j?!k 5B r2 CTX A A A 4v z"p A A A0A?A AK CTX A A?!k CX qCX YCX i!d A fi8 l8 yuZ 6L pH m?c 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