Filing E-Filed PM JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendants I IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO RESPONSE IN OPPOSITION TO EPSTEINS MOTION IN LIMINE AS TO SEX OFFENDER REGISTRY INFORMATION Counter-Plaintiff Bradley Edwards by and through undersigned counsel hereby files this Response in Opposition to Epsteins Motion in Limine as to Sex Offender Registry Information and as grounds therefore states as follows Epsteins Net Worth is a Factual Issue in Dispute Epsteins Motion in Limine repeatedly claims that documents containing circumstantial evidence of Epsteins net worth are not relevant to any factual issue in dispute pursuant to the parties Joint Pre-Trial Stipulation That statement is clearly false Specifically Part of the Joint Pre-Trial Stipulation confirms that one of the issues of fact for determination at trial is hat amount if any should be assessed against Epstein for punitive damages as punishment for instituting or continuing his civil proceeding against Edwards and/or as a deterrent to others See Joint Pre-Trial Stipulation at FILED PALM BEACH COUNTY FL SHARON BOCK CLERK PM Edwards adv Epstein Response in Opposition to Epsteins Motion in Limine as to Sex Offender Registry Information Case No Although Epstein alleged that he was a billionaire in the Initial Complaint he has asserted his Fifth Amendment privilege as to all punitive damage net worth discovery Edwards is entitled to an adverse inference jury instruction as a result of these assertions and that request is the subject of a separate motion See Atlas Atlas So 2d Fla 4th DCA citing Baxter Palmigiano U.S Edwards intends to also use the detailed asset information in Epsteins sex offender registration as evidence of Epsteins substantial net worth As part of his registration in New York Epstein was required to list all homes vehicles and planes that he owns The registration page submitted by Epstein himself shows that Epstein owns seven residential properties dozens of vehicles and at least one airplane Certainly this is direct evidence that Epstein is a man of significant net worth and is consistent with his claimed status as a billionaire Epsteins sex offender registration information is therefore relevant to a factual issue in dispute the amount of punitive damages that may be awarded by the jury See Thigpen United Parcel Servs Inc So 2d Fla 4th DCA To be relevant evidence must tend to prove or disprove a material fact Epsteins Prejudice Argument is Circular Reasoning That Leads Directly Back to Him Epstein built the alleged prejudicial playing field he now complains of In the Initial Complaint Epstein claimed that Edwards had manufactured sexual abuse lawsuits on behalf of L.M E.W and Jane Doe lawsuits that were weak and had minimal value for the sole purpose of continuing Scott Rothsteins massive Ponzi scheme Initial Complaint at Epstein referred to himself as a victimized Palm Beach Billionaire as follows Edwards adv Epstein Response in Opposition to Epsteins Motion in Limine as to Sex Offender Registry Information Case No the Litigation Team which included Edwards took an emotionally driven set of facts involving alleged innocent unsuspecting underage females and a Palm Beach Billionaire and sought to turn it into a gold mine Rather than evaluating and resolving the cases based on the merits i.e facts which included knowledgeable voluntary and consensual actions by each of the claimants Id at emphasis added And Epstein referenced the Non-Prosecution Agreement which establishes his status as a convicted sex offender Id at So Epstein alleged that he was a billionaire confirmed the existence of the Non-Prosecution Agreement which required him to plead guilty to sex crimes and register as a sex offender and alleged that each of the claimants against him were liars Epsteins Complaint on which Edwards malicious prosecution counterclaim is premised therefore injected all of the prejudicial circumstances of which Epstein now complains Consistent with his burden of proof Edwards will establish that Epstein lacked probable cause to make these malicious allegations In defense of the malicious prosecution counterclaim Epstein has listed numerous media articles on which he apparently intends to rely These articles to which Edwards has raised no objection variably label Epstein as a convicted child molester and pedophile For example Epsteins Exhibit Describing Epstein as a Palm Beach sex offender Epsteins Exhibit Describing Epstein as a billionaire sex offender Epsteins Exhibit A The Shameful Way Feds Protected Convicted Pedophile Billionaire Jeffrey Epstein Epsteins Exhibit Feds Deceived Us About Billionaire Sex Offenders Sweetheart Deal Teen Victims Say Edwards adv Epstein Response in Opposition to Epsteins Motion in Limine as to Sex Offender Registry Information Case No Epsteins counsel has also made clear that he intends to establish Epsteins probable cause by in part showing that Edwards was attempting to unseal the Non-Prosecution Agreement Thus not only is Epstein responsible for every prejudicial allegation that he chose to make in the maliciously-filed Initial Complaint his defense of this case is putting at issue the very circumstances he claims are prejudicial which are instead relevant and material See State Gad So 3d Fla 2d DCA In order for relevant probative evidence to be deemed unfairly prejudicial it must go beyond the inherent prejudice associated with any relevant evidence Conclusion The amount of punitive damages if any that may be assessed against Epstein is an issue to be determined at trial The detailed asset information that Epstein provided as part of his registration as a sex offender is relevant and material evidence to that contested issue and there is no unfair prejudice from introducing this evidence because Epstein has already put his status as a convicted sex offender at issue through the filing of the Initial Complaint and his apparent defense strategy Thus Epsteins Motion in Limine should be denied Edwards adv Epstein Response in Opposition to Epsteins Motion in Limine as to Sex Offender Registry Information Case No I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve e::-rr to all Counsel on the attached list this J5 day Jae ola otjd7a Bar No avid Vitale Jr Florida Bar No Attorney E-Mails 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 Attorneys for Bradley Edwards Edwards adv Epstein Response in Opposition to Epsteins Motion in Limine as to Sex Offender Registry Information Case No 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 One Broward Blvd Suite Fort Lauderdale FL Phone Edwards adv Epstein Response in Opposition to Epsteins Motion in Limine as to Sex Offender Registry Information Case No Fax Attorneys for Scott Rothstein A A 4A E0 A4 DE a qr?q rq qrCX HhL Kg lg d?a d6U a M3 flW y??S m/y t0 I F/Z V/j 1a qC KS u?v vZ O5 a qr rCX qC 0V I I dc rM?M rM 10Cy n??m?n k?o?h I A I w?!ac qr MCX 10Cy ITy qr M3 Ґ??1rA5R h?H?T3P K?z X?K I 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