Filing E-Filed PM JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendant IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO RESPONSE IN OPPOSITION TO EPSTEINS MOTION TO COMPEL E.W TO ANSWER QUESTIONS RELATING TO THE CRIME VICTIMS RIGHTS ACT AND TO REOPEN DISCOVERY Counter-Plaintiff Bradley Edwards by and through undersigned counsel hereby files this Response in Oppositions to Jeffrey Epsteins Motion to Compel E.W to Answer Questions Relating to the Crime Victims Rights Act and to Reopen Discovery and as grounds therefor states as follows Edwards contends that among Epsteins motives for filing and continuing this baseless and malicious lawsuit was Epsteins desire to intimidate Edwards into abandoning his clients claims in the Crime Victims Rights Act CVRA proceeding As the Court is aware one potential outcome of the CVRA proceeding is the invalidation of Epsteins Non-Prosecution Agreement NP A which shields Epstein from criminal liability in the Southern District of Florida FILED PALM BEACH COUNTY FL SHARON BOCK CLERK PM Case No Response in Opposition to Epsteins Motion to Compel E.W.s Deposition Page of5 Thus relevant and material discovery as to the CVRA proceeding is limited to what Epstein knew from the time he commenced this lawsuit in until voluntarily dismissing his claims in regarding the following a The existence of the NPA The fact that the NPA shielded Epstein from criminal liability in the Southern District of Florida The existence of the Crime Victims Rights Act proceeding to set aside the NPA and The fact that the potential invalidation of the NP A exposed Epstein to significant jail time Epstein however is attempting to question one of his victims regarding what she knew related to the CVRA proceeding Did E.W have the prosecutors cell phone number Did E.W receive a victims notification letter How many times did E.W meet with the Federal Bureau oflnvestigation None of these questions have any relevance to the above-described topics and most importantly Epstein did not know the answer to these questions in when he initiated his malicious lawsuit or from through when he continued his malicious prosecution These questions therefore have no relevance whatsoever to whether Epstein had probable cause to initiate or continue his claim against Bradley Edwards or whether he did so with malice They were directed solely at taking improper discovery in the ongoing CVRA proceeding without proper notice to all counsel in that proceeding Moreover although the subject Motion for Protective Order was filed on October approximately one month before the close of discovery Epstein failed to take any Case No Response in Opposition to Epsteins Motion to Compel E.W.s Deposition Page of5 action to set the motion for hearing or to compel E.W to answer the questions proffered on the record Epstein has therefore waived his right to compel any supplemental testimony regarding these irrelevant topics For the foregoing reasons as well as those stated by Jack Scarola Esq on the record at the October deposition of E.W the Motion to Compel should be denied JACKSCA OLA Flori9a No DAlID VITALE JR FI9ri Bar No A mey E-Mail jsx searcylaw.com and mmccann searcylaw.com Primary 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 also incorporates by reference the arguments contained in his Response in Opposition to Epsteins Motion to Reopen Discovery to Take Depositions a copy of which is attached hereto as Exhibit A Case No Response in Opposition to Epsteins Motion to Compel E.W.s Deposition Page of5 Bradley Edwards Esquire staff.efile pathtojustice.com Andrews Avenue Suite Fort Lauderdale FL Phone Fax COUNSEL LIST 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 Scott Link Esquire Eservice linkrocklaw.com Scott linkrocklaw.com Kara linkrocklaw.com Angela linkrocklaw.com Tanya linkrocklaw.com tina linkrocklaw.com Link Rockenbach P.A Palm Beach Lakes Boulevard Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com Case No Response in Opposition to Epsteins Motion to Compel E.W.s Deposition Page of5 One Broward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein 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 EPSTEINS MOTION TO REOPEN DISCOVERY TO TAKE DEPOSITIONS Counter-Plaintiff Bradley Edwards by and through undersigned counsel hereby files this Response in Oppositions to Jeffrey Epsteins Motion to Reopen Discovery to Take Depositions and as grounds therefor states as follows The Motion Fails to Meet the Courts Requirements to Reopen Discovery On November the Court entered its Order on Motion to Reconfirm Existing Pre-Trial Deadlines in which the Court ruled that additional discovery will only be permitted if the discovery requests are impacted by the Courts rulings on motions currently pending to be heard on November 29th December th and th At the hearing preceding the Order the Court outlined the standard by which any such additional discovery requests would be considered So what I am going to do is this Because there are issues that need to be addressed and Im hoping I will have orders out as soon as possible after those hearings are done is that I am going to require motions to be filed A copy of the Courts Order is attached hereto as Exhibit A EXHIBIT Edwards adv Epstein Case No Response in Opposition to Epsteins Motion to Reopen Discovery Page of8 on a discovery issue-by-discovery issue deposition by deposition so as to find out several things One is the need to talce that deposition and whether that need has been either clarified or required by virtue of a court order that will be entered subsequently to the commencement of Wednesdays hearings and thereafter on those days that I provided If it cannot be demonstrated to the Court that these witnesses need to be taken solely as a result the Courts ruling then those requests will be denied because again we were set to try the case next week So some-odd deposition unless they can be proven and shown to the Court as being required as a result of the rulings of the Court will not be entertained They should have been done before And if not done before I will need a reason for that as well Hearing Tr at and Thus Epstein has the burden to establish that a the new depositions are required solely as a result of a recent Court ruling and if so that the depositions could not have been talcen before Epsteins motion clearly fails to meet either requirement and therefore the motion should be denied A Epstein Has Been Aware of the Relevance of the Testimony of These Witnesses for Years and Could Have Deposed Them Long Before the Discovery Cutoff As an initial matter L.M was a named defendant in this lawsuit filed by Epstein Allegations regarding L.M.s role in the Ponzi scheme and her fabricated claim are replete Excerpts of the November hearing transcript are attached as Exhibit Perhaps understanding the Motions futility Epstein spends the first four pages arguing about Edwards damages and incredibly accusing Edwards of using L.M E.W and Jane Doe for his own personal gain As Epstein is all too aware the only person who has forced these victims to do anything against their will is Epstein and the suggestion that these victims have by now put behind them the atrocious sexual misconduct committed against them by Epstein is yet another example of Epsteins indifference to the permanent damage he inflicted on his child victims Edwards adv Epstein Case No Response in Opposition to Epsteins Motion to Reopen Discovery Page of8 throughout Epsteins Initial Complaint Any suggestion that L.M deposition is needed solely as a result of the Courts December ruling is therefore absurd Jane Doe is also named repeatedly throughout Epsteins malicious and baseless Initial Complaint and she was also alleged to be pursuing claims against Epstein that had minimal value Edwards first witness list filed June listed all named victims of Jeffrey Epstein as fact witnesses for trial which of course included Jane Doe As such any argument that Jane Does deposition is needed solely as a result of a recent Court ruling is also absurd Rather Epstein was obviously well-aware of the relevance of the testimony ofL.M and Jane Doe long before the Courts recent rulings There is no need however to accept Edwards argument to that effect Rather the Court need only consider the fact that in August Epstein requested and received dates to take L.M and Jane Does depositions in early October before the discovery deadline Epstein however voluntarily chose not to set either witness for deposition Thus Epstein clearly fails to meet the first requirement enunciated by the Court that the depositions be needed solely as a result of a recent ruling and the Motion should be denied on those grounds alone Epsteins Prior Counsel Failed to Set L.M and Jane Does Depositions Despite Requesting and Receiving Dates for Their Depositions in August The Motion should further be denied because although Epstein could have taken these depositions months ago he voluntarily chose not to so Edwards adv Epstein Case No Response in Opposition to Epsteins Motion to Reopen Discovery Page4 of8 Specifically on August Epsteins prior counsel requested deposition dates for L.M and Jane Doe the email also sought the depositions of E.W and Virginia Roberts That same day undersigned counsels office responded via email and stated that dates were available in early October and to call to clear specific dates for these depositions On August Edwards as counsel for L.M E.W and Jane Doe stated that he would accept service of subpoenas for his clients depositions On August after some back and forth email exchanges Epsteins prior counsel instructed undersigned counsels office to hold and for depositions On August Edwards confirmed that he would make L.M E.W and Jane Doe available on any date Epstein then set Virginia Roberts deposition for and E.Ws deposition for No depositions were set for On September Epstein unilaterally cancelled the deposition of Virginia Roberts after Ms Roberts had travelled to New York from Australia solely for purposes of sitting for the deposition Epstein failed to set L.M and Jane Doe for deposition on despite Edwards notice that he could make them available on that date As such no depositions were taken on Epstein also failed to take any depositions on Instead Epstein used only to take the deposition of E.W Edwards adv Epstein Case No Response in Opposition to Epsteins Motion to Reopen Discovery Page of8 Thus when the Court asks Epsteins counsel for the reason why L.M and Jane Does depositions have not been taken the answer is quite simple because Epstein chose not to take them Epsteins Current Counsel Chose Not to Set Any Depositions Prior to the Close of Discovery After Epsteins prior counsel failed to use either the or dates to take the depositions ofL.M and Jane Doe his current counsel made efforts to set witness depositions prior to the November discovery deadline Specifically on November Epsteins counsel requested deposition dates for a number of attorneys who had represented other Epstein victims Notably however Epsteins current counsel failed to request new deposition dates for either L.M or Jane Doe On November undersigned counsels office advised Epsteins counsel that it was available for depositions each day apart from Thanksgiving until the discovery cutoff on November th Thus Epstein could have set depositions on I or Epstein failed to set any depositions whether of the attorney witnesses or of L.M and Jane Doe on the dates given In total Epstein therefore declined to use twelve days provided by undersigned counsel to schedule the depositions ofL.M and Jane Doe prior to the discovery cut off As such the only reason these witnesses have not been deposed witnesses whose importance Edwards adv Epstein Case No Response in Opposition to Epsteins Motion to Reopen Discovery Page6 of8 Epstein has been aware of for years is because Epstein affirmatively chose not to depose them Epsteins current remorse over that litigation tactic certainly fails to meet the Courts requirements to reopen discovery particularly on the eve of trial in this eight year old case Conclusion For the foregoing reasons Epsteins Motion to Reopen Discovery should be denied I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve I tff to all Counsel on the attached list this _d __ day of I./JU;i JAciyisc Floripa ar No DAYJ VITALE JR Flo a Bar No Attorney E-Mail jsx searcylaw.com and mmccann searcylaw.com Primary 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 Motion to Reopen Discovery Page of8 Bradley Edwards Esquire staff.efile pathtojustice.com Andrews A venue Suite Fort Lauderdale FL Phone Fax COUNSEL LIST 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 Avenue Suite West Palm Beach FL Phone Attorneys for Bradley Edwards Scott Link Esquire Eservice linkrocklaw.com Scott linkrocklaw.com Kara linkrocklaw.com Angela linkrocklaw.com Tanya linkrocklaw.com tina linkrocklaw.com Link Rockenbach P.A Palm Beach Lakes Boulevard Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com Edwards adv Epstein Case No Response in Opposition to Epsteins Motion to Reopen Discovery Page of8 One Broward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendant I IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO ORDER ON MOTION TO RECONFIRM EXISTING Edwards adv Epstein Case No Order on Motion to Reconfirm Existing Pretrial Deadlines COUNSEL LIST Jack Scarola Esquire scarolateam searcy law com Searcy Denney Scarola Barnhart Shipley PA Palm Beach Lakes Boulevard West Palm Beach FL Phone Fax Attorneys for Bradley Edwards Bradley Edwards Esquire staff efile pathtojustice.com Andrews A venue Suite Fort Lauderdale FL I Phone Fax Nichole Segal Esquire njs FLAppeIIateLaw.com kbt FLAppellateLaw.com Burlington Rockenbach P.A Railroad Avenue Suite West Palm Beach FL Phone Attorneys for Bradley Edwards 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 Scott Link Esquire Eservice linkrocklaw.com Scott Iinkrocklaw.com Kara linkrocklaw.com Angela linkrocklaw.com Tanya linkrocklaw.com tina linkrocklaw.com Edwards adv Epstein Case No Order on Motion to Reconfirm Existing Pretrial Deadlines Link Rockenbach P.A Palm Beach Lakes Boulevard Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Marc Nurik Esquire marc nuriklaw.com One Broward Blvd St ite Fort Lauderdale FL I Phone Fax Attorneys for Scott Rothstein IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALH BEACH COUNTY FLORIDA case No JEFFREY EPSTEIN Plaintiff vs scorr RorHSTEIN individually BRADLEY EDWARDS individually Defendants/Counter-Plaintiffs TRANSCRIPT OF PROCEEDINGS DATE TAKEN Monday November 27th TIME PLACE BEFORE a.m a.m Dixie Highway Room lOC West Palm Beach Florida Donald Hafele Presiding Judge This cause came on to be heard at the time and place aforesaid when and where the following proceedings were reported by Sonja Hall Palm Beach Reporting Service Inc Palm Beach Lakes Boulevard Suite West Palm Beach FL APPEARANCES For Plaintiff LINK ROCKENBACH P.A Palm Beach Lakes Boulevard Suite West Palm Beach FL By KARA BERARD ROCKENBACH ESQUIRE For Bradley Edwards SEARCY DENNEY SCAROLA BARNHART SHIPLEY P.A Palm Beach Lakes Boulevard West Palm Beach FL By JACK SCAROLA ESQUIRE By DAVID VITALE JR MS ROCKENBACH Good morning Your Honor MR SCAROLA Good morning THE COURT Good morning Thank you for sending me the legal issues that need to be addressed and the anticipated amount of time that you are going to need I appreciate that This motion I have before me is to reconfirm and Edwards opposition to the existing pretrial deadlines which were set in contemplation of the case going to trial in December MR SCAROLA Almost sir THE COURT Pardon MR SCAROLA Almost Your Honor has it backwards It is Mr Edwards who is seeking to reconfirm the deadline Mr Epstein is objecting to that reconfirmation THE COURT My error sorry about that MR SCAROLA Thats all right A mistake that we all make repeatedly THE COURT Mr Edwards is seeking to confirm or reconfirm the existing deadlines Mr Epstein is objecting Okay All right So I guess the place to start is from Mr Edwards standpoint as the punitive plaintiff here Is there any discovery thats necessary from your standpoint at this juncture MR SCAROLA No sir THE COURT Ms Rockenbach MS ROCKENBACH Yes Your Honor If you recall your order that granted the motion to continue sets forth in it which is November 14th that both parties dont know how the Court will ultimately rule on critical issues which will require counsel to try to strategize and plan their respective cases under extreme uncertainty and duress And that was a quote from your order which you correctly identified And as a result Your Honor opened up additional days on your calendar so that we could hear those incredibly significant dispositive legal motions that are pending We are going to be before the Court on Wednesday and then next week on Palm Beach Reporting Service Inc ll Keeping these deadlines in place freezing this case in the position that it was in on the eve of trial and ready to be tried is the only way to prevent those kinds of last-minute delays There has been an avalanche of motions that have already been filed but we have plenty of time now to dispose of those motions And if there is a reasonable basis upon disposition of those motions for Your Honor to consider on a case-by-case basis and thats the only way it should be done an extension of a deadline or an exception to a deadline then Mr Epstein through his very able counsel has every means by which to present those issues on a case-by-case basis to the court But the deadlines previously set should be enforced Thank you Your Honor MS ROCKENBACH Your Honor I want to try this case on March 13th THE COURT We are going to try the case on March 13th MS ROCKENBACH Theres no question that both parties are respecting this courts order on November 17th setting that specifically But as Your Honor has identified these critical issues have yet to be ruled on by this Court And Mr Scarola makes my point in raising the three claimants that Mr Edwards previously represented and settled their cases Thats a very significant issue that this court will rule on on Wednesday to determine whether their testimony is even relevant I see that were getting a preview about the fabrication issues But I look forward to Wednesday and discussing it with the court The attorneys that Mr Scarola identifies as designated for years they were not They were fact witnesses and only recently identified as expert witnesses so appropriate discovery was propounded and their depositions were requested The new expert that Mr Edwards has listed brand-new expert is being deposed this Friday which incidentally is past the discovery cut-off date I think he was in Europe and that was the date that was provided He contradicts Mr Edwards answers to interrogatories about damages So this case there are no additional motions to be filed Your Honor has them all in addition to the responses What we do need is to proceed in an orderly fashion and allow these deadlines to be reset in conformance with a standard pretrial order for a March 13th trial setting THE COURT Thank you My intention was not to open the floodgates to allow wholesale discovery as pointed out and not it really wasn so much the Courts schedule but respective counsels vacation schedules which took up essentially a month of time where I wasnt able to set anything substantively during that period and had to thereafter wait Because there is time that opens up and I know or at least counsel that represented Mr Epstein in the past they typically were amenable to setting things and getting hearings set if the court had time open Mr Scarola and his office have always been very accommodating in that regard So it was not with the anticipation that we are going to open the floodgates for discovery to essentially recommence Again its a case I know the counterclaim was filed a little bit later than that but it is an old case has an appellate history that needs to get tried in March S,o what I am goin_g t_o do is this Because tliere are iSSUE,S i:liai need to be a dressed amir hoping I wlii have Ofd ars Ut as soon as pos,s bl a iel tlios_e hearings are done is that i am going_ to require motions to be filed on _a di cover iss1Je.:.b,Y discovery issue depo by deposition _as_ to find out sever.if things cine is the need to take that deposition ai:,d hetlier at need hats been either clarified or requhi,,d b"y virtue of a court order thai will be entered subse9uef!tlY to th commen ement o_f Wednesdays hearings and thereafter on:tllos days_ that I provided Palm Beach Reporting Service Inc I it carini be demon tr_ated to the cou that fliese witnesses need to be taken soie.J as a r,esult the sour s_ ling th_en l:h i:e9ue,;ts will be denied because J;in we we!e set to try tlie case next week And but for the legal issues that remained and the fact that the Court did not want to put anyones back against the wall including itself in the short period of time that we had between trial and the hearings that had been set and those were just for a one-day period and not enough time it was not contemplated that discovery was going to be open again at least on the wholesale basis ci;j1 some odcl c!ep?s;t:ion unless they _rcive and shown to the Court as rifijqii c1 as a resu11 of tlie ruTigs of the;C:2 ilno be ente talned Tliey shouii:I have 267been do9e before ilnd if not i?ff re I wil_l need a reas ri for that weli MS ROCKENBACH Thank you Your Honor And so for clarification that motion that Your Honor is referencing would be filed after Your Honors rulings on November 29th or December 5th or December 7th THE COURT Meaning any motions that will be filed after the Court rulings relative to whether or not those deponents or the discovery was occasioned by the Courts ruling MS ROCKENBACH Correct THE COURT correct We dont know what that is going to be as of yet MS ROCKENBACH Thank you And as far as the pretrial the joint pretrial stipulation Your Honor my point in that was not knowing how the Court will rule on critical issues requires it causes extreme uncertainty with regard to the issues to be tried Mr Scarola Mr Edwards filed a unilateral pretrial stipulation I am going to ask the Court to allow us to reconvene following the hearings that are pending before and scheduled before Your Honor so that we can arrive at a joint pretrial stipulation Those issues are going to be significantly impacted by the courts legal rulings THE COURT Im sorry I didnt follow that MS ROCKENBACH Im sorry Joint pretrial stipulation is due was due In our response to Mr Edwards unilateral pretrial stipulation we noted that based on the fact that Your Honor is going to be making significant legal rulings on November 29th December 5th and December 7th it was impossible for us to frame the issues to be tried in this case There are pending legal motions that Your Honor is going to be ruling on probably on Wednesday So my request is that we be allowed additional time following those hearings to reconvene and arrive at a joint pretrial stipulation THE COURT All I can say is the elements of malicious prosecution are well set out in Florida law MS ROCKENBACH Agreed THE COURT And so anticipating witnesses to testify as to those issues shouldnt be an extraordinary tasks at this point in time What I was going to say is I recognize that those lists might be tailored in accordance with the courts rulings but it shouldnt hold back just like pending motions in lirnine that are in every case subsequent to either filed or filed before or after the pretrial is filed and heard And it may reduce increase or whatever the number of witnesses but it wouldnt change the issues that have to be tried as it relates to a malicious prosecution action MS ROCKENBACH I would tend to agree with Your Honor However the recent filings by Mr Edwards show that perhaps there are a mixing or misunderstanding of those legal elements as compared to a defamation case So I think this will be cleared up on Wednesday when Your Honor sees our motions hears our arguments and substantively rules on the pending real issues to be tried And Palm Beach Reporting Service Inc 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 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