Filing E-Filed PM JEFFREY EPSTEIN Plaintiff/Counter-Defendant SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants/Counter-Plaintiff IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEINS REVISED OMNIBUS MOTION IN LIMINE Plaintiff/Counter-Defendant Jeffrey Epstein Epstein files his Revised Omnibus Motion in Limine and states INTRODUCTION To prevail on his Counterclaim for malicious prosecution Defendant/Counter-Plaintiff Bradley Edwards Edwards must prove that Jeffrey Epstein filed a civil proceeding against him without probable cause See Korman Kent So 2d Fla 4th DCA Edwards burden is onerous See Burns GCC Beverages Inc So 2d Fla In recent deposition testimony Edwards admitted that he has no evidence of Epsteins intent and he intends to attempt to meet his burden by introducing Epsteins assertions of the Fifth Amendment in response to questions about the validity of Edwards clients claims against Epstein Because Edwards strategy reflects his fundamental misunderstanding of what this case FILED PALM BEACH COUNTY FL SHARON BOCK CLERK PM is about and the legal significance of Epsteins assertions of the Fifth Amendment this Court must bar Edwards from introducing this testimony First Edwards plan to re-litigate the validity of his clients tort claims against Epstein demonstrates that he does not understand what this case is about This case is not and has never been about whether or not the claims filed in against Epstein by Edwards clients are true Rather this lawsuit is about whether or not Epstein lacked probable cause to allege not ultimately prove that Edwards participated in or had a connection to Rothstein Rosenfeldt and Adlers RRA Ponzi scheme after Edwards joined RRA Epstein is not alleging in this action that Edwards did anything improper in regard to the conduct of the litigation until after Edwards joined RRA Epsteins claims did not put into issue Epsteins alleged responsibility for the claims brought against him by Edwards clients Epsteins Motion to Amend Complaint D.E challenge Edwards basis for filing those claims or allege Edwards engaged in misconduct between the dates his clients first filed suit against Epstein and the date on which Edwards joined RRA Importantly Edwards state of mind is not relevant Only what Epstein knew and believed in December matters Rather the crux of Epsteins allegations was that after joining RRA Edwards misused the existing cases that he had previously pursued in a manner that was not unlawful sought inflammatory discovery that was not relevant to Edwards clients allegations against Epstein filed a meritless but attention-grabbing motion alleging fraudulent asset transfers by Epstein and commenced but did not serve a duplicative lawsuit on behalf of one of his clients-all of which on its face seemed in furtherance of Rothsteins Ponzi scheme The question to be tried then is whether at the time he filed suit against Edwards Epstein lacked probable cause-whether he lacked a reasonable belief based on facts and circumstances known to him in the validity of his claims founded upon Edwards apparent misconduct and Rothsteins indisputable misconduct while Edwards held himself out as a partner at Rothsteins firm See Wright Yurko So 2d Fla 5th DCA citation omitted Therefore evidence concerning the truth or falsity of Edwards clients tort claims Edwards state of mind and actual motivation for doing what he did after becoming a partner at RRA and Epsteins assertions of the Fifth Amendment in response to questions about those claims are not relevant to this question and should be excluded Second even if some of Epsteins assertions of the Fifth Amendment were relevant and this Court were to admit them into evidence Edwards overstates the effect of this testimony Edwards is not entitled to any presumption based on Epsteins testimony and the Court should protect the jury from drawing any inference in Edwards favor based solely on Epsteins assertion of the Fifth Amendment Third introducing Epsteins repeated assertions of the Fifth Amendment-as Edwards apparently intends to do-is prejudicial and reversible error RELEVANTFACTUALBACKGROUNDi Edwards Clients Actions Against Epstein Before joining RRA Edwards filed three lawsuits against Epstein On August Edwards sued Epstein in the Southern District of Florida on behalf of Jane Doe On September Edwards filed lawsuits against Epstein in the 15th Judicial Circuit on behalf ofL.M and E.W None of Edwards clients alleged they flew on Epsteins plane or met Epsteins wealthy famous and politically connected male acquaintances Edwards must also prove the other elements of his malicious prosecution Counterclaim Epstein is filing an Appendix in support of this Motion which he will supplement with the documents cited herein Edwards joined RRA no later than April At that point the tenor of the litigation changed On April Jane Doe moved to lift a protective order which was entered in Edwards Crime Victims Rights Act case against the United States and governed the disclosure of Epsteins non-prosecution agreement and to allow her counsel to place certain of its terms in the public record S.D Fla Case No at On April Doe amended her complaint and filed an eighteen-page Civil RICO Case Statement In the Case Statement she made new and inflammatory allegations such as it is common belief that the sexual acts against minors temporarily ceased in approximately November when Epstein learned that law enforcement authorities were investigating his crimes but if"Epstein through his criminal enterprise is given the opportunity to commit similar acts in the future upon his release from jail the enterprise will likely continue this illegal activity and the criminal enterprise had a definite structure similar to a mafia-type family S.D Fla Case No D.E at On April during a deposition in E.W case Edwards asked Epstein outrageous and irrelevant questions such as Mr Epstein did you ever care about any of the feelings of the minor girls that you were engaging in sex with and Isnt it true that at the time you were inserting your fingers into the vagina of these little kids all you cared about was your own sexual gratification See 15th Jud Cir Case No X-MB D.E On June Doe moved for an injunction restraining Epsteins supposed fraudulent transfer of assets the appointment of a receiver for Epsteins property and an order requiring Epstein to post a million bond S.D Fla Case No D.E Judge Marra subsequently denied the motion as meritless no relief of this character has been thought justified in the long history of equity jurisprudence and the motion is entirely devoid of evidence of Defendants alleged fraudulent transfers S.D Fla Case No D.E at On July Edwards sent a letter to counsel representing other alleged Epstein victims He said he intended to notice the depositions of Donald Trump and Bill Clinton among others even though none of his clients alleged she had any connection to either On July Edwards commenced a second action on behalf of L.M in the Southern District of Florida S.D Fla Case No D.E L.M.s complaint was pages long and asserted causes of action-all pursuant to U.S.C each of which carried with it a minimum statutory damages award of more than million in total Id The complaint alleged-for the first time and contrary to L.M prior testimony-that Epstein had forced L.M into oral sex Id Edwards the sole attorney listed on the complaint has recently admitted he did not sign it himself and that he does not know who signed it Whoever filed the complaint and commenced the action entered Epsteins last name as Espstein in the courts electronic filing system and the complaint was never served On August Edwards noticed Donald Trumps deposition for August On August Edwards re-noticed Donald Trumps deposition for September S.D Fla Case On August E.W moved for permission to enter and inspect Epsteins entire property 15th Jud Cir Case No D.E On August L.M noticed the depositions of Epsteins pilots Lawrence Paul Visoski Jr and David Hart Rogers 15th Jud Cir Case No X-MB D.E L.M requested they produce all original flight logs from January through present for any and all aircraft/airplanes/jets which they piloted or co-piloted that were owned or controlled by Jeffrey Epstein or Ghislaine Maxwell Id Again none of Edwards clients alleged she flew on Epsteins plane or asserted claims for the periods through or late through Pleadings News Reports Detailing The Scope Of Rothsteins Ponzi Scheme And The Central Role Of Edwards Cases In November and December RRA imploded criminal and civil pleadings and news reports revealed to the public the breathtaking scope ofRothsteins Ponzi scheme and Rothsteins investors in a complaint against Rothstein and in related news coverage accused Rothstein and others of using RRA cases against Epstein-Edwards cases against Epstein-in furtherance of the Ponzi scheme Specifically On November the South Florida Sun-Sentinel reported that Rothstein attracted investors by promising huge returns and selling settlements he said hed reached in sex discrimination and whistle-blower cases Sally Kestin Jon Burstein Brittany Wallman Scott Rothstein investment deals seemed too good to be true Fla Sun Sentinel Nov The article quoted Alan Sakowitz who said I was convinced it was all a Ponzi scheme and I notified the FBI in detail how Scotty was hiding behind a legitimate law firm to peddle fake settlements Id Sakowitz also told the Sun-Sentinel Available at t-plan sbnov03 that Rothstein boasted of having sophisticated eavesdropping equipment and that former cops would sift through potential defendants garbage On November the New Times Broward-Palm Beach reported that one way Rothstein enticed investors was by tricking them into believing that his firm was representing numerous underaged girls who had sex with Palm Beach billionaire and convicted child sex offender Jeffrey Epstein Bob Norman Scott Rothstein The Jeffrey Epstein and Bill Clinton Ploy New Times Broward-Palm Beach Nov The article said that Rothstein claimed that he had flight logs showing that Epstein flew extremely prominent people including former President Bill Clinton on his private jet with some of the plaintiffs and that Rothstein told investors that Epstein Clinton and other celebrities involved basically had no choice but to settle these cases and that it was a veritable treasure-trove Id The New Times said that investors then ponied up millions to invest in the settlements pay out a portion of those settlements to the victims and pocket the rest but Rothstein was fabricating the story and there was no indication that the former president who was at one time a real friend of Epsteins and other celebrity names bandied about by Rothstein were involved in any way Id Rothstein used the Epstein case as a showpiece as bait said William Scherer an attorney for a number of Rothstein investors Thats the way he raised all the money He would use legitimate cases as bait for luring investors into fictional cases All the cases he allegedly structured were fictional I dont believe there was a real one in there Id Available at and bill-clinton-ploy-64 On November the United States Attorneys Office for the Southern District of Florida filed a civil forfeiture action against certain property of Rothstein S.D Fla Case No D.E The complaint said Rothstein and others had been operating a Ponzi scheme since Id It alleged that Rothstein had sold investors interests in non-existent structured settlements Id r,r On November the South Florida Sun-Sentinel reported that the FBI confirmed Thursday what many have speculated since the Scott Rothstein scandal broke The flashy lawyer could not have defrauded investors of hundreds of millions without help I do not believe that this was a one-man show said John Gillies head of the FBI in South Florida Sally Kestin and Peter Franceschina FBI doubts Rothstein ran a Ponzi scheme alone Fla Sun-Sentinel Nov On November certain investors sued Rothstein and others The plaintiffs alleged Rothstein had operated a Ponzi scheme and fabricated structured settlements which he sold to investors 17th Jud Cir Case No D.E The plaintiffs alleged the purported settlements albeit fraudulent were based on actual cases being handled by RRA"-including specifically one of Edwards cases against Epstein One of the settlements involved herein was based upon facts surrounding Jeffrey Epstein the infamous billionaire financier In fact RRA did have inside information due to its representation of one of Epsteins alleged victims in a civil case styled Jane Doe Jeffrey Epstein pending in the Southern District of Florida Representatives of D3 were offered the opportunity to invest in a pre-suit court settlement against Epstein arising from the same set of operative facts as the Jane Doe case but involving a different underage female plaintiff See e-mail dated October referencing Epstein which is attached hereto and incorporate herein as Exhibit To augment his concocted story Rothstein invited D3 to his office to view the thirteen bankers boxes of actual case Available ssociates files in Jane Doe in order to demonstrate that the claims against Epstein were legitimate and that the evidence against Epstein was real In particular Rothstein claimed that his investigative team discovered that there were high-profile witnesses onboard Epsteins private jet where some of the alleged sexual assaults took place and showed D3 copies of a flight log purportedly containing names of celebrities dignitaries and international figures Because of these potentially explosive facts putative defendant Epstein had allegedly offered for settlement of the claims held by various young women who were his victims Adding fuel to the fire the investigative team representative privately told a D3 representative that they found three additional claimants which Rothstein did not yet know about Additionally Rothstein used RRAs representation in the Epstein case to pursue issues and evidence unrelated to the underlying litigation but potentially beneficial to lure investors into the Ponzi scheme For instance RRA relentlessly pursued flight data and passenger manifests regarding flights Epstein took with other famous individuals knowing full well that no under age women were on board and no illicit activities took place RRA also inappropriately attempted to take the depositions of these celebrities in a deliberate effort to bolster Rothsteins lies Id r,r Like the FBI the investors alleged a Ponzi scheme cannot be operated without insider help Plaintiffs believe that additional members of RRA including its non lawyer investigators were used by Rothstein to perpetuate promote and facilitate the Ponzi scheme Id On November the United States Attorneys Office for the Southern District of Florida filed an amended civil asset forfeiture complaint against Rothsteins property The Government again alleged that Rothstein and others had been running a Ponzi scheme S.D Fla Case No D.E On November the South Florida Sun-Sentinel reported that Rothstein had said karma is going to get him but its going to get other people too Youre in a town full of thieves and at the end of the day everyone will see Ill leave it at that Brittany Wallman Scott Rothstein Youre in a townfull of thieves Fla Sun-Sentinel Nov On November The Miami Herald reported that Rothsteins law firm generated revenue of million in one recent year yet his 70-lawyer firm had a payroll of million prosecutors said Rothstein who owned half of Rothstein Rosenfeldt Adler used investors money from his Ponzi scheme to make up the shortfall they said Jay Weaver Scott Hiaasen Feds Scott Rothstein Ponzi scheme paid salaries at law firm The Miami Herald Nov On November Rothsteins investors filed an amended complaint against him in which they repeated their allegations concerning the central role Edwards cases played in Rothsteins Ponzi scheme See 17th Jud Cir Case No D.E On November the United States Attorneys Office for the Southern District of Florida filed a second amended civil asset forfeiture complaint against Rothsteins property Once again the Government alleged that Rothstein and others had been running a Ponzi scheme S.D Fla Case No D.E On December the FBI arrested Rothstein and the United States Attorneys Office for the Southern District of Florida filed a criminal information against him S.D Fla Case No D.E The information alleged that RRA was a criminal enterprise that from until November Rothstein and others had engaged in a pattern of racketeering activity that included mail fraud wire fraud money laundering and Available at havent_i_ hurt story.html conspiracy to launder money that Rothstein and his unidentified co-conspirators had operated a Ponzi scheme and obtained billion from investors by fraud and that Rothstein and his co-conspirators had created false and fictitious documents including confidential settlement agreements and made false statements to current investors in order to convince them to re-invest in additional purported confidential settlement agreements Id i,r Epstein Sues Edwards Based On The Information In The Public Record On December Epstein sued Edwards Rothstein and L.M for racketeering abuse of process fraud conspiracy to defraud and violating the Florida Civil Remedies for Criminal Practices Act 15th Jud Cir Case No D.E Epsteins complaint was informed by and referenced cited to or attached the facts pleadings and reports set forth above Id See also 15th Jud Cir Case No D.E r,r As Epstein explained in a subsequent motion to amend It is the essence of the Plaintiffs action that the Defendants used actual lawsuits against Epstein or fabricated others to market investments to third parties for a return on investment on the Epstein Cases It is not the intention or position of the Plaintiff to put into issue whether or not the actions alleged against Epstein by various Edwards clients are true or not Instead the essence of the complaint is to focus on the alleged misconduct of filing legal motions and other actions in pursuit of civil litigation unrelated to the merits or value of the cases brought against Epstein 15th Jud Cir Case No D.E at Discovery Establishes Additional Connections Between Edwards Rothstein And Rothsteins Ponzi Scheme Edwards testified that when he joined RRA he gave up his interest in the lawsuits filed against Epstein to the firms equity partners i.e Rothstein and Rosenfeldt Edwards Nov Tr at Rothstein subsequently gained access to discovery that Edwards obtained in his three cases against Epstein and used it to support his fairytale Edwards Nov Tr at In fact Edwards knew Rothstein had requested these discovery files Edwards Nov Tr at Edwards claimed he was told Rothstein wanted the files because he intended to try the cases against Epstein with Edwards Edwards Nov Tr at Edwards testified that he discussed with Rothstein legal issues related to the case against Epstein and that they had conversations about the cases covered by the attorney-client privilege and attorney work product doctrine Edwards Mar Tr at Edwards also testified that he corresponded with and took some instructions from Russ Adler-identified by Rothstein as one of his co-conspirators Edwards Nov Tr at Rothsteins June Tr at Adler attended at least one of Epsteins depositions Edwards Mar Tr at Edwards and Adler also met with other attorneys at RRA to discuss the discovery sought from and investigation into Epstein Edwards Oct Tr at Edwards also testified that he met with Rothstein and Adler to discuss the Epstein cases Edwards Mar Tr at This testimony squares with a document produced in this case showing that Rothstein was scheduled to attend an Epstein conference the week of July Additionally Rothstein testified that he spoke with Edwards and Adler about the Epstein cases Rothsteins June Tr at He testified that he knew he could use the Epstein cases for his Ponzi scheme based on his conversations with among others Adler and Edwards Rothsteins June Tr at Indeed Rothstein testified that he remembered speaking to Edwards at least briefly the day or the day of sic or the day before the actual investors due diligence was going on as to what was going on Rothsteins June Tr at Likewise in the investors case against him Rothstein testified that he socialized with Edwards and was not sure Edwards would have turned him in if he had discovered the Ponzi scheme Rothsteins Dec Tr at He also testified that either Brad Edwards or Russ Adler pointed out to me that one of the pieces of evidence they were using in the actual case was the flight manifest And I actually used that to make a fairly big show Rothsteins Dec Tr at After confirming the original manifests that were in evidence in the real case did not have sensational names on them he continued Its interesting you bring that up because the way I came up with Bill Clinton and Prince Andrew was Mr Adler and Mr Edwards both told me on different occasions that the reason the case when we were discussing the actual real case the reason it was becoming so quote unquote tasty was because they had information that Epstein had been flying Bill Clinton around and Prince Andrews sic around the piece that was missing from the real case was the connection to the young girls Rothsteins Dec Tr at According to Rothstein as far as Clinton and Prince Andrew were concerned the connection to the young girls was fiction Rothsteins Dec Tr at EPSTEINS FIFTH AMENDMENT ASSERTION IS INADMISSIBLE PURSUANT TO THE FLORIDA EVIDENCE CODE OR AT A MINIMUM SHOULD BE PRECEDED BY A JURY INSTRUCTION THAT THERE IS NO NEGATIVE OR ADVERSE PRESUMPTION FROM INVOKING THIS CONSTITUTIONAL RIGHT Epsteins constitutional right to invoke the Fifth Amendment is inadmissible because it is irrelevant pursuant section Florida Statutes None of the topics on which Epstein invoked the Fifth Amendment are relevant to the only issues in this action of Epsteins damages caused by Rothstein or whether Epstein had probable See also Rothsteins Dec Tr at Rothstein testifying that he asked either Adler or Edwards to isolate the flight manifest for use with prospective investors cause when he sued Edwards Therefore any prior testimony or evidence in which Epstein invoked the Fifth Amendment must be excluded pursuant to section Additionally Edwards should not be permitted to ask Epstein similar irrelevant questions at trial that would expectantly lead to Epsteins assertion of his constitutional right The sole issues to be tried in this action are a the amount of damages that Rothstein should pay Epstein and whether Edwards can prove Epstein lacked probable cause for filing the underlying lawsuit against Edwards Edwards malicious prosecution counterclaim is limited to an analysis of the civil proceeding filed by Epstein against Edwards none of which relate to the merits of the cases filed by Edwards clients against Epstein Rather Epsteins claims pied against Edwards only allege that Edwards after he went to RRA misused the litigation process by taking unnecessary discovery filed a federal lawsuit solely for the purpose of mollifying investors and took other steps such as alleging fraudulent transfers and asking for a million bond that were perceived by Epstein to support a scheme to defraud investors that came to RRA Significantly Epsteins claims did not apply to the time period before Edwards joined RRA as a partner and do not apply to the cases filed in against Epstein The sole issue here is what Edwards did in the Epstein cases to incite investors while Edwards was a partner at RRA not whether the tort claims were false The elements of malicious prosecution in Florida include the commencement or continuance of an original judicial proceeding its legal causation by the present defendant against the present plaintiff who was the defendant in the original proceeding its bona fide termination in favor of the present plaintiff a lack of probable cause for such proceeding the presence of malice and damages conforming to legal standards resulting to the present plaintiff If the plaintiff is unable to prove any one of these elements the malicious prosecution action will fail Endacott Int Hospitality Inc So 2d Fla 3d DCA citing Alamo Rent-A-Car Inc Mancusi So 2d Fla Despite this distinction throughout discovery and during pretrial preparations it has become increasingly obvious that Edwards seeks to create a many-ringed circus of mini-trials within one trial in an effort to detract from the issue of whether Epstein had probable cause to have a reasonable belief that Edwards an RRA partner was involved in or connected to Rothsteins Ponzi scheme The filed tort claims are over While Edwards may or may not like the resolution of those claims this malicious prosecution action simply is not the forum to relitigate the tort claims or the allegations in the Epstein cases Indeed contrary to Edwards argument whether or not the allegations in those cases are true or not is not relevant to the issues for this trial Likewise the true motivation behind Edwards doing what he did while a partner at RRA is likewise not relevant In addition to being irrelevant to any material issue in this case Epsteins assertion of his Fifth Amendment right is inadmissible based on its prejudicial effect Any prior testimony and other evidence relating to Epsteins assertion of the Fifth Amendment must also be excluded because any remote or minimal probative value is clearly outweighed by the danger of unfair prejudice confusion of issues and the risks of misleading the jury See Fla Stat In weighing the probative value against the unfair prejudice it is proper for the court to consider the need for the evidence the tendency of the evidence to suggest an improper basis to the jury for resolving the matter e.g an emotional basis the chain of inference necessary to establish the material fact and the effectiveness of a limiting instruction Jones Alayon So 3d Fla th DCA quoting Johnson State So 3d Fla th DCA In Jones the Fourth District Court of Appeal held that evidence of the defendants post accident bad acts could have inflamed the jury and caused them to award damages to the plaintiff out of a desire to punish the defendant Id at See also Wright State So 3d Fla Unfair prejudice has been described as an undue tendency to suggest decision on an improper basis commonly though not necessarily an emotional one This rule of exclusion is directed at evidence which inflames the jury or appeals improperly to the jurys emotions citations and internal quotations omitted Stewart Draleaus So 3d Fla th DCA recognizing the inflammatory effects of evidence of a partys alcohol use in the context of an action arising from a car accident and holding such evidence inadmissible as unduly prejudicial where liability is admitted citing Neering Johnson So 2d Fla th DCA Datus State So 3d Fla th DCA explaining testimony which evokes sympathy for a victim may be inadmissible on the ground that its probative value is substantially outweighed by the risk of unfair prejudice Allowing Edwards to use the portions of any prior questioning to which Epstein asserted the Fifth Amendment or to ask questions that will inevitably lead to the assertion of the Fifth Amendment would be unfairly prejudicial confuse the issues invoke the jurys emotions and/or mislead the jury from the true issues in this action Because of the nature of the claims against Epstein in these other cases even instructing the jury on the actual elements of malicious prosecution or giving a limiting instruction would not stop the jury from being misled and/or confused resulting in only one emotional conclusion of finding against Epstein based on Epstein being accused in another case of sexual molestation of a minor See Thigpen United Parcel Servs Inc So 2d Fla th DCA describing the balancing test under Fla Stat as follows In weighing the claim of unfair prejudice against probative value the trial court is required to consider the need for the evidence the tendency of the evidence to suggest to the jury an improper basis for resolving the matter the chain of inference necessary to establish the material fact and the effectiveness of a limiting instruction In the unlikely judicial determination allowing testimony or evidence of Epsteins invocation of his constitutional Fifth Amendment right this testimony should be preceded by an instruction that there is no negative or adverse inference from doing so If the Court does not exclude Epsteins prior testimony asserting the Fifth Amendment the Court should instruct the jury that there is no negative or adverse inference they should draw from Epsteins constitutional right to remain silent Courts have consistently held that there is no requirement to draw a negative inference from the assertion of the Fifth Amendment privilege See In re Carp 3d st Cir Baxter Palmigiano U.S In Doe ex rel Rudy-Glanzer Glanzer 3d th Cir the Ninth Circuit held that The Baxter holding is not a blanket rule that allows adverse inferences to be drawn from invocations of the privilege against self-incrimination under all circumstances in the civil context Rather lower courts interpreting Baxter have been uniform in suggesting that the key to the Baxter holding is that such adverse inference can only be drawn when independent evidence exists of the fact to which the party refuses to answer Thus an adverse inference can be drawn when silence is countered by independent evidence of the fact being questioned but that same inference cannot be drawn when for example silence is the answer to an allegation contained in a complaint In such instances when there is no corroborating evidence to support the fact under inquiry the proponent of the fact must come forward with evidence to support the allegation otherwise no negative inference will be permitted See LaSalle Bank F.3d at F.3d at citations omitted The Fourth District Court of Appeal has similarly limited such adverse inferences against parties to when they refuse to testify in response to probative evidence offered against them Fraser Sec Inv Corp So 2d Fla th DCA emphasis added see also Coquina Investments TD Bank NA 3d th Cir holding that the Fifth Amendment does not forbid adverse inferences against parties when they refuse to testify in response to probative evidence offered against them quoting Baxter Palmigiano U.S Likewise another court has held that because the privilege is constitutionally based the competing interests of the party asserting the privilege and the party against whom the privilege is asserted must be carefully balanced and the detriment to the party asserting it should be no more than is necessary to prevent unfair and unnecessary prejudice to the other side Nationwide Ins Co Richards 3d th Cir The Nationwide court also recognized that under certain circumstances an adverse inference from an assertion of ones privilege not to reveal information is too high a price to pay The tension between one partys Fifth Amendment rights and the other partys right to a fair proceeding is resolved by analyzing each instance where the adverse inference was drawn or not drawn on a case-by-case basis under the microscope of the circumstances of that particular civil litigation The inference may not be drawn unless there is a substantial need for the information and there is not another less burdensome way of obtaining that information The district court must determine whether the value of presenting the evidence is substantially outweighed by the danger of unfair prejudice to the party asserting the privilege Moreover the inference may be drawn only when there is independent evidence of the fact about which the party refuses to testify Id at citations omitted and emphasis added Similarly the topics on which Epstein has asserted the Fifth Amendment are not responsive to any material issue in this lawsuit so that no adverse inference should be permitted under Fraser Epsteins claims against Edwards were never about the merit of the tort cases that Edwards filed against Epstein prior to joining RRA Moreover to permit adverse inferences may actually be contrary to other evidence obtained during discovery For instance at his deposition Epstein asserted the Fifth Amendment when asked did sexual assaults ever take place on a private airplane on which you were a passenger Edwards wants to present this testimony to convince the jury that Epstein may have in fact known of such sexual assaults even though Edwards himself admitted that he took depositions of three pilots who had at various times flown Epstein and his passengers despite Edwards knowledge that none of his clients had testified that any improper conduct occurred on airplanes See Edwards Nov Tr at admitting that if his clients testified truthfully they admitted that there was no improper conduct on airplanes As another example one of Epsteins allegations in his Complaint against Edwards was that Edwards abused the litigation process when he attempted to take discovery in the tort lawsuits from well-known individuals in an attempt to force a higher settlement in accordance with the false representations that RRA was making to investors When asked about whether he ever socialized with these celebrities in the presence of females under the age of Epstein invoked his Fifth Amendment privilege Again Edwards will try to use this as an admission that he did so at trial to negate the probable cause shown by Edwards unusual litigation tactics See Epsteins March Tr at Bill Richardson David Copperfield Bill Mottola Alan Dershowitz Similarly under the Nationwide analysis there should be no adverse inference because the value if any of an adverse inference on these topics to the malicious prosecution counterclaim is substantially outweighed by the danger of unfair prejudice to Epstein as set forth above Again whether or not Epstein has procured minors for prostitution whether he ever had physical contact with Edwards clients in the Epstein cases or whether sexual assaults took place on private airplanes while he was a passenger have nothing to do with whether or not Edwards can meet his burden to prove his malicious prosecution counterclaim against Epstein Edwards cannot meet his burden to show entitlement to an adverse inference All three pilots ultimately also testified that there was no such conduct on any flights that they were on If any Fifth Amendment testimony is admitted it should be preceded by a jury instruction that the invocation of this constitutional right should not create a negative or adverse presumption If the Court decides to permit this evidence and to permit adverse inferences the Court should make it clear to the jury that adverse inferences are not the same as admissions or presumptions Courts have clearly distinguished between the two For instance in Palmas Bambu S.A E.I Dupont De Nemours Co Inc So 2d Fla 3d DCA the court held that an inference unlike a presumption is a logical and reasonable conclusion of fact not presented by direct evidence but which by process of logic and reason a trier of fact may conclude exists from the established facts Edwards cannot solely rely on Epsteins assertion of the Fifth Amendment as an admission or presumption on elements that Edwards must prove to prevail on his malicious prosecution claim such as lack of probable cause Coquina Investments Rothstein No WL S.D Fla Sept is particularly instructive In Coquina the plaintiffs made investments in with Edwards partner Scott Rothstein and sued TD Bank for allegedly aiding and abetting Rothsteins fraud At trial the plaintiff called TD Banks former regional vice president as a witness who asserted his Fifth Amendment privilege to questions regarding his role in the Rothstein fraud The court instructed the jury that Mr Spinosas assertion of his Fifth Amendment privilege is not a proper basis for finding TD Bank liable in this case and that the assertion of the privilege and any adverse inferences from it could only be considered by the jury in conjunction with other evidence to be presented Id at On post-verdict motions the court confirmed that a jury can only draw an adverse inference against a party as to a particular fact when independent evidence exists of the fact to which the party refuses to answer In other words a judgment cannot rest solely on the adverse inference Id at Other courts holdings are consistent with the reasoning from the Coquina court The Seventh Circuit has held citing Baxter Palmigiano U.S that an assertion of the Fifth Amendment privilege must be weighed in light of other evidence rather than leaving directly and without more to the conclusion of guilt or liability LaSalle Bank Lake View Seguban 3d th Cir Likewise in National Acceptance Co of America Bathalter 2d th Cir the Seventh Circuit held that the failure to answer the allegations of a civil complaint based on an assertion of the Fifth Amendment privilege could not be construed as an admission of those allegations See also Centennial Life Ins Co Nappi Supp N.D N.Y An adverse inference against the party invoking the Fifth Amendment by itself is insufficient to establish the absence of a genuine issue of material fact Here Edwards intends to ask the jury to draw a negative or adverse presumption based on Epsteins assertion of his constitutional right to remain silent At his deposition on November Edwards admitted that he had no evidence of Epsteins state of mind or the facts and circumstances known to Epstein regarding probable cause to file his Complaint other than Epstein himself See Edwards Nov Tr Given his lack of evidence Edwards is trying to rely on Epsteins invocation of the Fifth Amendment privilege against self incrimination in order to dispel Epsteins probable cause for having a reasonable belief that Edwards overly zealous litigation tactics as an RRA partner indicated that Edwards was involved with Rothsteins Ponzi scheme See Edwards Nov Tr at Edwards testifying that he argued Epsteins invocation of the Fifth Amendment as an admission in a federal action and stating thats going to happen in this case too Clearly Epsteins exercise of his right to remain silent has nothing to do with his perception and reasonable belief that Edwards actions were connected to Rothsteins Ponzi scheme and investor-luring Coquina Investments Rothstein No WL S.D Fla Sept and other similar cases have made it clear that invocation of the Fifth Amendment cannot be the sole basis for a verdict or judgment As a result if this Court concludes that Epsteins Fifth Amendment assertions has some relevance to Edwards burden of proving Epstein had no probable cause to believe Edwards involvement with RRA partner Rothstein then any admission of this testimony must be preceded by an instruction to avoid jury confusion emotional conclusion or misleading from the true issues for their determination THIS COURT SHOULD EXCLUDE CERTAIN OF THE EXHIBITS IDENTIFIED ON EDWARDS TRIAL EXHIBIT LIST The Exhibits Should Be Excluded Pursuant To Florida Statute Sections and The vast majority of the exhibits identified on Edwards November Amended Exhibit List D.E should be excluded because they are irrelevant to the case at hand pursuant to Florida Statute section To the extent Edwards could argue that any of the exhibits are relevant any alleged probative value is substantially outweighed by the danger of unfair prejudice confusion of issues misleading the jury or needless presentation of cumulative evidence Fla Stat Dailey Multicon Dev Inc So 2d Fla 4th DCA Unfair prejudice has been described as an undue tendency to suggest decision on an improper basis commonly though not necessarily an emotional one This rule of exclusion is directed at evidence which inflames the jury or appeals improperly to the jurys emotions Wright State So 3d Fla Byrd BT Foods Inc So 2d Fla 4th DCA See also Canales Compania De Vapores Realma S.A So 2d Fla 3d DCA holding any probative value of testimony about marriage proposal plaintiff purportedly made offering money to woman to marry him so that he could avoid deportation on issue of plaintiffs credibility was far outweighed by its prejudicial effect DeSantis Acevedo So 2d Fla 3d DCA finding probative value of the defendants cross-examination of the plaintiff and his main witness about prior unrelated incidents that insinuated that both the plaintiff and the witness had been dishonest was outweighed by prejudicial nature of questions For instance Edwards identifies an Amazon receipt for a purchase of an erotic book Exhibit sex offender registrations Exhibits and a massage table Exhibit messages from a notepad in Epsteins home Exhibits flight logs Exhibits phone records Exhibits photos and videos of Epsteins home Exhibits and school records and yearbooks from the plaintiffs in the lawsuits which Edwards filed against Epstein Exhibits and None of these are relevant to whether Epstein lacked probable cause for filing his claims against Edwards or any element of Edwards Counterclaim for malicious prosecution Similarly Edwards lists jail visitation records Exhibit probation records Exhibits and probable cause affidavits and search warrants Exhibits victim statements Exhibit and other documents relating to the plaintiffs in Edwards lawsuits against Epstein Exhibits and Epsteins criminal cases Exhibits Again none of these are relevant to the elements in Edwards malicious prosecution counterclaim These are just examples On November Epstein filed his Objections to Edwards Amended Exhibit List D.E identifying all of the exhibits which Epstein claims are irrelevant pursuant to Florida Statute section indicated by under the objections column and which are unfairly prejudicial misleading to the jury and confusing pursuant to Florida Statutes section indicated by under the objection column All of these should be excluded Edwards inclusion of these exhibits on his Amended Exhibit List as well as others that fall into these categories demonstrates that Edwards goal in this litigation is to re-litigate his prior cases against Epstein which have already settled and to try this case based on prejudicial and inflammatory allegations which have no bearing on the malicious prosecution counterclaim Exhibits Relating to Prior Convictions and Criminal Matters Should Also Be Excluded Certain exhibits on Edwards Amended Exhibit List D.E should also be excluded as it is well-settled law that evidence of prior convictions acquittals or arrests is irrelevant in a civil action and thus inadmissible Eggers Phillips Hardware Co So 2d Fla Kelley Mutnich So 2d Fla 4th DCA As such Epsteins conviction as well as any testimony or evidence of any other criminal investigation is inadmissible This includes for example documents relating to Epsteins June conviction Exhibits his criminal plea colloquy Exhibits the Palm Beach State Attorneys Offices criminal file for Epstein Exhibit probable cause affidavits Exhibits reports from the Palm Beach Police Department Exhibits grand jury subpoenas Exhibit a criminal score sheet Exhibit probation records Exhibit property searches and surveillance Exhibits and other exhibits identified on Edwards Amended Exhibit List that relate to the criminal investigation and proceedings Again these are just examples Other Exhibits Should be Excluded as Inadmissible Hearsay In addition to being irrelevant many of the exhibits listed above are inadmissible hearsay The documents which Epstein alleges contain hearsay are identified by the number in the objection column of his Objections to Edwards Amended Exhibit List D.E Hearsay is a statement other than one made by the declarant while testifying at the trial or hearing offered in evidence to prove the truth of the matter asserted Fla Stat In fact many of these documents contain double hearsay so that even if Edwards could establish an exception for the first layer of hearsay the documents still contain inadmissible hearsay Many of these documents contain contents that are entirely based upon prior statements made by individuals and other extrinsic documents all of which undeniably do not fall into an exception See Reichenberg Davis So 2d Fla 5th DCA The problem here is that in both reports the authors simply related the substance of what the witnesses had told the authors These witnes statements even though contained within the business records do not fall within the exception because they were not based upon the personal knowledge of an agent of the business Id at see also Harris Game and Fresh Water Fish Com So 2d Fla 1st DCA Van Zant State So 2d Fla 1st DCA Accordingly any hearsay documents and any reference or testimony related thereto should be excluded Certain Exhibits Should Be Excluded As Inadmissible Opinion Testimony Other documents on Edwards Amended Exhibit List identified by the number in the objections column of Epsteins Objection D.E irrefutably contain opinion statements about Epstein who is party to and possible witness in this case rendering it improper opinion testimony about the credibility of a witness Alvarado State So 2d Fla 3d DCA In Childers State So 2d Fla 1st DCA the court was faced with a similar issue and in denying the admission of the information/documents avowed admission of the notice would have been similar to admitting an opinion by the State concerning Juniors character truthfulness and credibly Such opinion testimony regarding a witness reputation for truthfulness us clearly inadmissible See Antone State So.2d Fla holding improper a question of a witness which sought to elicit the individual and personal view of the witness Hernandez State So.2d Fla 4th DCA holding that it was reversible error to admit testimony of police officers and teacher that sexual abuse victim was truthful A witness invades the jurys exclusive province when that witness gives his or her personal views of the credibility of another witness Alvarado State So.2d Fla 3d DCA holding that an opinion of a witness concerning his or her belief as to the truthfulness of another witness clearly inadmissible Morrison State So.2d Fla holding that it was improper to allow personal opinion to establish reputation for truthfulness without laying a foundation based on knowledge of the witness reputation in community for truthfulness Wyatt State So.2d Fla 3d DCA holding that section Florida Statutes does not permit opinion testimony regarding evidence of character Ehrhardt Florida Evidence at Opinion testimony concerning a persons character has traditionally been inadmissible on the basis that it is too unreliable it will be tainted by the underlying prejudice and bias of the person expressing the opinion on expressing the opinion Id at Exhibits Should Be Excluded For Other Reasons As Well Other exhibits are overbroad and vague so that they should also be excluded At least some of the overbroad exhibits are identified by in the objection column on Epsteins Objections to Edwards Amended Exhibit List D.E It is impossible to tell whether other exhibits are overbroad because they are so vague For instance all emails produced by Defendant and/or all emails produced by Plaintiff in this case Exhibit is so vague that Epstein cannot tell what is included and as of this date Edwards has not provided a copy of the exhibit so that Epstein has reserved the objection Likewise the flight logs are overbroad see e.g Exhibits as they appear to contain information for every single flight in a particular time period Finally other documents should be excluded as confidential information of third parties and Epsteins confidential financial information These are identified to the extent possible by in the objections column on Epsteins Objections to Edwards Amended Exhibit List D.E THIS COURT SHOULD PRECLUDE THE USE OF ANY DEROGATORY ADJECTIVES WHEN REFERENCING EPSTEIN Throughout this proceeding Edwards has continually referenced Epstein by the use of provoking and offensive misnomers such as billionaire pedophile or convicted child molester Such commentary is inappropriate and at trial would irrefutably be done solely to impermissibly inflame the jury or appeal improperly to the jurys emotions Wright State So 3d Fla Such name-calling constitutes improper conduct by counsel and reversible error Schubert Allstate Ins Co So 2d Fla th DCA defense counsels inflammatory and improper remarks to jury about plaintiff his witnesses and counsel warranted new trial Improper comments by trial counsel even when not objected to at trial constitute reversible error if they impair the jurys calm and dispassionate consideration of the evidence and result in an unfair trial Moore Taylor Concrete Supply Inc So 2d Fla pt DCA Nelson Reliance Ins Co So 2d Fla th DCA As such preventing Edwards from doing so at the outset can avoid such issues Likewise Epsteins criminal conviction and status as a registered sex offender is inadmissible by law Eggers Phillips Hardware Co So 2d Fla Kelley Mutnich So 2d Fla th DCA Epsteins conviction as well as any testimony or evidence of any other criminal investigation is inadmissible as it is impermissibly being offered as relevant solely to prove bad character and would unduly inflame and prejudice the minds of the jury against Epstein as would any pejorative that Edwards may choose to use a Fla Stat As explained above Edwards seeks to depict Epstein as someone culpable of numerous federal criminal offenses allegedly involving sexual misconduct with minor females to further his pursuits in this case and in the Doe case Consequently such inapposite commentary from Edwards his counsel or his witnesses is impermissible THIS COURT SHOULD EXCLUDE REFERENCES TO ANY CASES AGAINST EPSTEIN WHICH WERE NOT PROSECUTED BY EDWARDS While it is foreseeable that a limited amount of the information regarding Edwards prosecution of the three cases against Epstein such as the fact that they existed could potentially be germane to the issues in this case it would be impermissible to use such information to impermissibly inflame the jury or appeal improperly to the jurys emotions or solely to prove bad character Wright So 3d at Byrd So 2d at Moreover any mention of or use of information from any other case is absolutely improper as such evidence has no bearing on the malicious prosecution counterclaim and is unfairly prejudicial Honeywell Intern Inc Guilder So 3d Fla rd DCA Long Term Care Found Inc Martin So 2d Fla th DCA allegations in a different lawsuit against defendant were not relevant and were highly prejudicial since under section Florida Statutes any relevance the complaint might have had was outweighed by the unfair prejudice against the defendant It is inconsistent with the notions of fair trial for the state to force a defendant to resurrect a prior defense against a crime for which the defendant is not on trial Jacobs Atl Coast Ref Inc So 3d Fla th DCA finding that because the prior case was settled none of the allegations therein were proven As seen from Edwards November Amended Exhibit List D.E and Seventh Amended and Supplemental Witness List D.E it is apparent that he intends to use as much information from other cases as possible solely to impermissibly inflame the jury and appeal to the jurys emotions or solely to prove bad character See Wright So 3d at Byrd So 2d at If the introduction of the evidence tends in actual operation to produce a confusion in the minds of the jurors in excess of the legitimate probative effect of such evidence if it tends to obscure rather than illuminate the true issue before the jury then such evidence should be excluded City of Miami Calandra So 2d Fla 3d DCA citing Perper Edell So 2d Fla see also Agrofollajes SA EI Du Pont De Nemours Co So 3d Fla 3d DCA probative value outweighed by prejudicial effect when evidence improperly becomes focus of trial Maldonado Allstate Ins Co So 2d Fla 2d DCA probative value of bicyclists status as an illegal alien was outweighed by unfair prejudice confusion of the issues and misleading of the jury as the evidence and instruction concerning status as an illegal alien improperly changed the focus of the jurys attention A trial courts discretion in determining the relevancy of evidence is limited by the rules of evidence and applicable case law Thigpen United Parcel Servs Inc So 2d Fla th DCA citing Johnson State So 2d Fla Hayes Wal-Mart Stores Inc So 2d Fla th DCA DeVille State So 2d Fla th DCA Dixon State So 2d Fla th DCA Reed State So 2d Fla th DCA Relevant evidence is inadmissible if its probative value is substantially outweighed by the danger of unfair prejudice Fla Stat Here these extrinsic cases are not relevant to the malicious prosecution counterclaim against Epstein and are intended only to mislead the jury THE COURT SHOULD EXCLUDE TESTIMONY OR EVIDENCE THAT EPSTEIN policy of this state favors amicable settlement of disputes and the avoidance of litigation This policy is implemented by excluding evidence of an offer to compromise and a release or covenant not to sue tortfeasors While the disposition of the cases that Edwards was prosecuting against Epstein on behalf of three plaintiffs may in certain limited respects be germane to this litigation any other settlements are not Furthermore this evidence should be excluded under section Florida Statutes As seen from both Edwards Seventh Amended and Supplemental Witness List D.E and his Amended Exhibit List D.E it is apparent that he intends to use as much information from other cases as possible solely to impermissibly inflame the jury or appeal improperly to the jurys emotions or solely to prove bad character Wright State So 3d Fla Byrd BT Foods Inc So 3d Fla 4th DCA Ifthe introduction of the evidence tends in actual operation to produce a confusion in the minds of the jurors in excess of the legitimate probative effect of such evidence if it tends to obscure rather than illuminate the true issue before the jury then such evidence should be excluded City of Miami Calandra So 2d Fla 3d DCA citing Perper Edell So 2d Fla See also Agrofollajes S.A E.I Du Pont De Nemours Co Inc So 3d Fla 3d DCA probative value outweighed by prejudicial effect when evidence improperly becomes focus of trial Maldonado Allstate Ins Co So 2d Fla 2d DCA probative value of bicyclists status as an illegal alien was outweighed by unfair prejudice confusion of the issues and misleading of the jury as the evidence and instruction concerning status as an illegal alien improperly changed the focus of the jurys attention CONCLUSION For the reasons stated above and in reliance upon the applicable law cited herein Jeffrey Epstein respectfully requests that this Court enter an Order in Limine precluding Bradley Edwards his counsel and his witnesses from making any argument statement evidence or comment as well as precluding from use at trial the items/witnesses/arguments listed above CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on November through the Courts e-filing portal pursuant to Florida Rule of Judicial Administration LINK ROCKENBACH PA Palm Beach Lakes Boulevard Suite West Palm Beach Florida fax By Isl Scott Link Scott Link FBN Kara Berard Rockenbach FBN Angela Many FBN Primary Scott linkrocklaw.com Primary Kara linkrocklaw.com Primary Angela linkrocklaw.com Secondary Tina linkrocklaw.com Secondary Troy linkrocklaw.com Secondary Tanya linkrocklaw.com Secondary Eservice linkrocklaw.com Trial Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein SERVICE LIST Jack Scarola Nichole Segal Searcy Denny Scarola Barnhart Shipley P.A Burlington Rockenbach P.A Palm Beach Lakes Boulevard Courthouse Commons Suite West Palm Beach FL West Railroad A venue mep searcylaw.com West Palm Beach FL jsx searcylaw.com njs FLAppellateLaw.com scarolateam searcylaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Bradley Edwards Marc Nurik Edwards Pottinger LLC Law Offices of Marc Nurik Andrews Avenue Suite One Broward Boulevard Suite Fort Lauderdale FL Ft Lauderdale FL brad epllc.com marc nuriklaw.com staff.efile pathtojustice.com Counsel for Defendant Scott Rothstein Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Jack A Goldberger Atterbury Goldberger Weiss P.A Australian A venue Suite West Palm Beach FL goldberger agwpa.com smahoney agwpa.com Co-Counsel for Plaintiff/Counter-Defendant Jeffrey Epstein 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 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