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 WDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO DEFENDANT/COUNTER-PLAINTIFFS THIRD SUPPLEMENT TO PROPOSED JURY INSTRUCTIONS AND VERDICT FORM Defendant/Counter-Plaintiff Bradley Edwards by and through undersigned counsel hereby files his Third Supplement to Proposed Jury Instructions and Verdict Form and as grounds therefor states as follows On December Epsteins counsel stipulated that all actions brought by Edwards on behalf ofL.M E.W and Jane Doe were brought in good-faith THE COURT Mr Link are you willing to stipulate that the actions brought by Mr Edwards on behalf of the three individuals that we have listed by way of either initials or Jane Dee that have been at center of this controversy were brought in good faith and that the allegations were well-founded MR LINK Theres a distinction and thats this Yes they were brought in good faith Can I say all of the allegations are true I cant say that Your Honor We never put them to the test because we couldnt FILED PALM BEACH COUNTY FL SHARON BOCK CLERK PM EDWARDS ADV EPSTEIN Case No Defendant/Counter-Plaintiffs Third Supplement to Proposed Jury Instructions and Verdict Form Page of4 I didnt represent Mr Epstein at that time so I think when you ask me would I say everything that was pied was true I cant say that THE COURT But you are saying youre willing to stipulate that they were all made in good faith MR LINK Yes sir absolutely THE COURT So stipulated Thank you That can be typed up and brought to the Courts attention if necessary during the pendency of litigation MR LINK Thank you Your Honor I hope my stipulation helped Transcript at excerpt attached hereto as Exhibit A Edwards therefore adds the following additional proposed jury instruction pursuant to the Courts order that the stipulation be typed up and brought to the Courts attention as necessary Jeffrey Epstein has conceded that Bradley Edwards had a good-faith basis to file all of the civil lawsuits alleging sexual abuse against Jeffrey Epstein on behalf of L.M E.W and Jane Doe By conceding that all of the lawsuits were filed in good faith Jeffrey Epstein has not conceded that he in fact committed any of the alleged acts against L.M E.W and Jane Doe only that Bradley Edwards had good-faith basis to reasonably believe that Jeffrey Epstein had in fact committed the alleged acts As to whether in fact he committed the alleged acts Jeffrey Epstein has asserted the right to remain silent EDWARDS ADV EPSTEIN Case No Defendant/Counter-Plaintiffs Third Supplement to Proposed Jury Instructions and Verdict Form Page of4 I HEREBY CERTIFY that a true and correct copy of the foregoing was sent via E-Serve to all Counsel on the attached list this 16th day of February Isl Tack Scaroa JACK SCAROLA Florida 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 Defendant/Counter-Plaintiffs Third Supplement to Proposed Jury Instructions and Verdict Form Page of4 Scott Link Esq Link Rockenbach P.A Scott linkrocklaw.com Kara linkrocklaw.com Palm Beach Lakes Boulevard Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein 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 Bradley Edwards Esquire staff.efile pathtojustice.com Andrews A venue Suite Fort Lauderdale FL Phone Fax COUNSEL LIST Marc Nurik Esquire marc nuriklaw.com One Broward Blvd Suite Fort Lauderdale FL Phone Fax Attorneys for Scott Rothstein IN THE CIRCUIT COURT OF THE FIITEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA Case No JEFFREY EPSTEIN Plaintiff/Counter-Defendant vs SCOIT ROTHSTEIN individually BRADLEY EDWARDS individually Defendants/Counter-Plaintiff VOLUME II TRANSCRI FT OF PROCEEDINGS DATE TAKEN Tuesday December 5th TIME a.m p.m PLACE Dixie Highway Room lOC West Palm Beach Florida BEFORE 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 THE COURT continue on with the discussion Mr Link you were in mid-thought MR SCAROLA I think Mr Goldberger is here to do the stay THE COURT Lets go ahead and take care of that Mr Goldberger MR GOLDBERGER Thank you for taking me out of order One of those days I have so much going on THE COURT I completely understand I thank you also for adjusting your schedule as well All right let me get my materials ready for that aspect of the case I think I am ready to go Please proceed MR GOLDBERGER Thank you Honor So we have a motion to stay your proceedings pending at this time I think its important for us to kind of discuss first with the Court what it is that we are seeking to have resolved before this case we would like to see it proceed And I bring that up because Mr Scarola in a prior hearing had mentioned that this is not just about the resolution of the CVRA Mr Epstein perhaps has other matters that he could potentially have criminal liability concerning in other jurisdictions that would not be covered by the NPA which is part of the CVRA THE COURT Lets put on the record exactly what youre speaking about so that if anyone needs to review this they understand these acronyms completely MR GOLDBERGER So the first matter we have Your Honor is what has been referred to as the CVRA case That is the Crime Victims Reporting sic Act And that matter is being litigated in federal court in the Southern District of Florida court 1B before Judge Marra MR SCAROLA Excuse me Since we are doing this for purposes of the record I think that you may have mistaken CVRA is not crime victims reporting act It is the Crime Victims Rights MR GOLDBERGER Thank you very much I appreciate that Mr Scarola So that matter concerning the CVRA case is pending before Judge Marra in the Southern District of Florida In that matter Mr Edwards as the attorney for three individuals C.W T.M and Jane Doe Number who happen to be involved in this case are seeking the unprecedented remedy of setting aside Mr Epsteins non-prosecution agreement For the record we need to establish that theres a non-prosecution agreement in place that prevents the US Attorneys Office for the Southern District of Florida in going forward on any criminal prosecution of Mr Epstein related to certain enumerated offenses if Mr Epstein complies with his non-prosecution agreement Mr Epstein has compiled with all parts of that non-prosecution agreement He has served a sentence that was part of that non-prosecution agreement and he going about his life In an unprecedented action Mr Edwards on behalf of these individuals is seeking to set aside that non-prosecution Palm Beach Reporting Service Inc EXHIBIT I THE COURT I think thats what Mr Link has offered MR SCAROLA I thought that thats what it was but I want that thats an important stipulation There ought not to be any ambiguity THE COURT Mr Link are you willing to stipulate that the actions brought by Mr Edwards on behalf of the three individuals that we have listed by way of either initials or Jane Dee that have been at center of this controversy were brought in good faith and that the allegations were well-founded MR LINK Theres a distinction and thats this Yes they were brought in good faith Can I say all of the allegations are true I cant say that Your Honor We never put them to the test because we couldnt I didnt represent Mr Epstein at that time so I think when you ask me would I say everything that was pled was true I cant say that THE COURT But you are saying youre willing to stipulate that they were all made in good faith MR LINK Yes sir absolutely THE COURT So stipulated Thank you That can be typed up and brought to the Courts attention if necessary during the pendency of litigation MR LINK Thank you Your Honor I hope my stipulation helped THE COURT All right we are up to number MS ROCKENBACH I think we were at I wish we were at THE COURT We did MS ROCKENBACH We did THE COURT I indicated that is the next highlighted one That again is a matter judicial notice and depending upon whatever evidentiary value it may have those are just answers in affirmative defenses in the civil cases against him MS ROCKENBACH Your Honor Im sorry I think we also objected to THE COURT I dont have it highlighted MR SCAROLA I dont have it highlighted on mine either THE COURT Responses to requests for production requests for admission answers to interrogatories in this matter And then theres a list of about or so cases MS ROCKENBACH Those were not this case before you in division AG And this case number you can THE COURT Youre talking about AB MS ROCKENBACH Yes These are all OB cases cases I presume they are Your Honor perhaps Mr Scarola can tell us the relevance but they would not be relevant to this action Bringing in discovery from other lawsuits seems to be creating mini-trials again within this suit THE COURT Well depending upon the nature of the discovery and obviously depending upon its relevance to the lawsuit that we are dealing with here things like requests for admissions may be pursuant to the law transferable to a similar case Answers to interrogatories the same thing Those things that are stated under oath have a more concrete type of affect than those that are not stated under oath So whats your position Mr Scarola MR SCAROLA Let me just state broadly Your Honor that as has been acknowledged in earlier argument before the Court there is clearly an issue with regard to motive and intent on Jeffrey Epsteins part And it is our theory of the case that Jeffrey Epstein singled out Bradley Edwards because he was leading a joint prosecution effort that included a number of other lawyers prosecuting multiple other cases and that Brad was singled out not only because of his leadership role but because he faced a particular vulnerability And what Mr Epstein was attempting to do was to extort Bradley Edwards into either abandoning or compromising the interest of his clients and backing off on the prosecution of the Crime Victims Rights Act case which Mr Edwards was prosecuting on a pro bone basis almost independently 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 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 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