In his Motion Edwards argued that The order resetting the trial did not alter any pretrial deadlines including the discovery cutoff date and Edwards objected to any effort to expand existing deadlines Id On November the Court agreed with Edwards and granted Edwards Motion finding that to the extent that wholesale additional discovery will not be permitted but individual discovery requests may be allowed on a matter-by-matter basis only if the discovery requests are impacted by the Courts ruling on motions currently pending to be heard D.E e.s Despite having asked this Court to enforce the discovery cutoff deadlines on December Edwards moved for leave to serve Requests for Admissions Edwards argues that Epsteins response to his Request for Judicial Notice of a New York sex offender registry triggered the need for the additional discovery in order for Epstein to authenticate the website printout and confirm its accuracy D.E Specifically Edwards proposed Requests for Admission would ask Epstein to admit the following a Admit that the printout of your New York State Sex Offender registration page attached to Edwards Request for Judicial Notice Pursuant to Florida Statutes Section and dated November is authentic Admit that the information contained in the printout of your New York State Sex Offender registration page attached to Edwards Request for Judicial Notice Pursuant to Florida Statutes Section and dated November is accurate ARGUMENT Inadmissible and Pre;udicial First Epstein objects to any reference to or admissibility of the New York State Sex Offender registration information at trial because it is irrelevant and prejudicial Fla Stat The non-admissibility issue is the subject of a separate Motion Edwards Motion Fails to Meet Court Requirements to Reopen Discovery and Seeks Preferential Treatment Second and procedurally Edwards cannot have it both ways As the Court made clear in its November Order and at a subsequent hearing resulting in a significantly prejudicial and adverse ruling to Epstein discovery is closed Specifically Epstein requested leave to disclose his expert witness Culver Skip Smith I Esq based on this Courts rulings at extensive pretrial hearings held November December and December On January at Edwards urging to again enforce the original pretrial deadlines this Court denied Epsteins Motion for Leave to Disclose Expert Witness and referred to the pretrial deadlines with no prejudice analysis D.E In urging the Courts denial Edwards cited this Courts requirements regarding reopening discovery but individual discovery requests may be allowed on a matter by matter basis only if the discovery requests are impacted by the Courts ruling on motions currently pending to be heard D.E e.s In fact there can be no dispute that it has been Edwards who has repeatedly opposed any extension of pretrial deadlines Edwards counsel knew for years of the registration site and had previously indicated he wanted it for purposes of identifying Epsteins assets through those sex offender registration disclosures Tr Edwards longstanding Plaintiff/Counter-Defendant Jeffrey Epsteins Motion in Limine as to Sex Offender Registry Information Excerpts of the December hearing transcript are attached as Exhibit A knowledge of the registration site and potential hearsay obstacles is not this Courts problem to remedy Edwards had many years to seek these discovery requests/admissions and his current trial evidentiary conundrum was simply not caused by any ruling by this Court on motions pending for the November/December pretrial hearings There is simply no justification for Edwards belated request Edwards has provided no legitimate reason for this Court to extend an expired discovery deadline to permit Edwards to serve Requests for Admissions that Edwards easily could have propounded anytime during the preceding eight years This is particularly true where the Court just recently denied Epsteins well-founded request for relief from the discovery deadline based entirely on the eight-year duration of this matter Epsteins well-founded hearsay objection to Edwards Request for Judicial Notice does not warrant extension of the discovery cutoff Epsteins objection certainly was not caused by any ruling of this Court but rather by the obvious impropriety of seeking to introduce into evidence irrelevant and unduly prejudicial New York State Sex Offender registration information at a malicious prosecution trial Epsteins hearsay objection as to admissibility was readily foreseeable and if granted would not create unknown or unanticipated discovery issues about Epsteins assets or net worth issues that already have been litigated extensively in this case If Epstein was not granted leave to disclose a vital trial expert witness with no prejudice cited by Edwards surely the pretrial discovery cutoffs should apply equally to Edwards written discovery Requests for Admissions Epstein is Not the Proper Person to Authenticate or Confirm Information Third the proposed Requests for Admission ask Epstein to authenticate information and confirm its accuracy over which Epstein has no control i.e New York State records Florida Statutes section provides Requirement of authentication or identification Authentication or identification of evidence is required as a condition precedent to its admissibility The requirements of this section are satisfied by evidence sufficient to support a finding that the matter is question is what its proponent claims In order to authenticate the New York Sex Offender registration information Edwards is required to call a witness with personal knowledge Fla Stat use public records to self-authenticate Fla Stat or assert official publications Fla Stat Edwards attempt to avoid the Florida Evidence Code by propounding the tardy discovery requests should be rejected CONCLUSION Epstein respectfully requests that Edwards Motion be denied Edwards asked for confirmation of the pretrial deadlines and must be held to that request There was no court ruling on motions currently pending to be heard on November December or December which caused the need for Edwards untimely discovery requests If the Court grants Edwards late Request for Admission and requires Epstein to substantively answer Epstein would consistently assert his Fifth Sixth and Fourteenth Amendment rights Fisher United States U.S Hoffman United States U.S CERTIFICATE OF SERVICE I certify that the foregoing document has been furnished to the attorneys listed on the Service List below on January through the Courts e-filing portal pursuant to Florida Rule of Judicial Administration Jack Scarola 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 Nichole Segal Searcy Denny Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard Burlington Rockenbach P.A Courthouse Commons Suite West Railroad A venue West Palm Beach FL mep searcylaw.com jsx searcylaw.com scarolateam searcylaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards West Palm Beach FL njs FLAppellateLaw.com kbt FLAppellateLaw.com Co-Counsel for Defendant/Counter-Plaintiff Bradley Edwards Bradley Edwards Marc Nurik Edwards Pottinger LLC Law Offices of Marc Nurik Andrews Avenue Suite One Broward Boulevard Suite Ft 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 EXHIBIT A IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No JEFFREY EPSTEIN Plaintiff/Counter-Defendant vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually Defendants/Counter-Plaintiff I VOLUME I TRANSCRIPT OF PROCEEDINGS DATE TAKEN TIME PLACE BEFORE Tuesday December 5th a.m p.m Dixie Highway Room l0C 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 Palm Beach Reporting Service Inc sex-offender registrations MR SCAROLA May we stop there THE COURT Yes MS ROCKENBACH Before we stop Your Honor was about to rule on through THE COURT Sixty through is sustained for the reasons that Ive already earlier indicated on the record Sixty-three Epsteins sex offender registrations MR SCAROLA Yes as part of Mr Epsteins sex offender registration particularly in the state of New York Im not sure the extent to which it applies elsewhere he was obliged to disclose his ownership interest in vehicles airplanes and residences that is he had to list all of those things And one of the ways that we have identified Jeffrey Epsteins assets is through those sex offender registration disclosures that he was obliged make and did make So it has to do with punitive damages in addition perhaps to something else But it has to do with punitive damages in Palm Beach Reporting Service Inc particular THE COURT I will take a look at that when the time comes if it comes at all Thank you Booking photographs Again same ruling as I made on the other matters regarding the criminal aspects of the case MR SCAROLA This would simply be a photograph Your Honor THE COURT Whats its relevancy MR SCAROLA Im not sure Mr Epstein is going to be here THE COURT Are you planning to subpoena 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