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CTX Y10Cy CX CX CX YC YY FV uTl bEWa ȓjJ-8 Gc G??Q9E 9Wq CTX CTX Up i I A 9_ qr qr YY D.X 7s F??Y bc3_c iH CTX CTX A qr 10Cy YY EMq 7H AY mK9Z BY A2 P6L N7 CTX CTX a I I i qr rC CTX CTX 7O I FMM qr qr i I I3 CTX Z6 I L(K4 P:u Z6P CTX y8 Edwards adv Epstein Case No Case Management Statement Page of7 affirmative relief while simultaneously hiding behind his constitutional protections to remain silent and deny Mr Edwards any substantive response to a single relevant question Accordingly Mr Edwards is unable to provide a brief statement describing Mr Epsteins claims against him We contend that Mr Epsteins suit was initiated and maintained solely as an effort to intimidate Mr Edwards into abandoning his legitimate and fully justified efforts to vigorously prosecute damage claims on behalf of victims of Mr Epsteins pedophilia As to the issues on Mr Edwards counter-claim we are prepared to proceed to trial on the counter-claim at the earliest available date Mr Epstein has never been able to articulate any plausible theory of damages when repeatedly pressed by the Court to do so No legally viable theory exists Mr Edwards has been damaged by the expenditure of time effort resources and money to defend against Mr Epsteins spurious claims and has endured the public embarrassment of having been branded as a participant in one of historys largest and most notorious Ponzi schemes Settlement is viewed by Mr Edwards as highly unlikely No additional parties are anticipated to be added to the litigation In the event that the claim against Mr Edwards were to be disposed of by Summary Judgment in advance of trial Mr Edwards would seek leave to amend the counter claim to add a count for malicious prosecution arising out of the identical facts supporting the Edwards adv Epstein Case No Case Management Statement Page of7 pending claim for abuse of process The malicious prosecution claim is premature until such time as the claims against Mr Edwards have been disposed of in his favor There is a pending motion to assert a claim for punitive damages set for hearing on March We foresee no reasonable possibility of obtaining any significant admissions of fact or of documents from Mr Epstein that will avoid unnecessary proof since it has been Mr Epsteins obvious strategy from the inception of this litigation to use the litigation as a means by which to inflict the greatest possible burden on Mr Edwards We are prepared to limit the number of retained experts to testify support of the propriety of Mr Edwards actions and the total absence of a good faith basis to support Mr Epsteins claims to two per side We anticipate no expert testimony on compensatory damages We may call one expert to address issues in the punitive damage phase of the trial regarding Mr Epsteins pecuniary circumstances We are prepared to disclose experts within days following Mr Epsteins disclosure Mr Edwards has no objection to the use of juror notebooks but their utility is doubtful as this is not expected to be a document-intensive case Mr Edwards Motion for Summary Judgment was denied solely on the grounds that Mr Epstein had not completed his discovery He has now received over pages of e-mails and deposed multiple Ponzi scheme investors Neither the documentary evidence nor the testimony Edwards adv Epstein Case No Case Management Statement Page of7 link Mr Edwards in any way to participation in Mr Rothsteins Ponzi scheme The Motion for Summary Judgment should be rescheduled and granted Jack Scarola will serve as lead counsel on behalf of Mr Edwards Mr Edwards and third parties have motions for protective orders pending before the Court This subsection has been addressed above I This subsection has been addressed above Special Master Camey was appointed in the related bankruptcy proceeding to address discovery issues arising out of the issuance of a subpoena in this case to obtain documents formerly in the exclusive custody of the bankruptcy trustee Mr Edwards has repeatedly offered to stipulate to Judge Cameys appointment by this Court as Special Master to deal with identical issues which must ultimately be decided by this Court Copies of the documents which had previously been in the exclusive possession of the trustee have been transferred by the trustee to Mr Edwards The trustees involvement and the involvement of the bankruptcy court have now become irrelevant to this proceeding However Judge Camey is still proceeding with a privilege analysis as directed by the bankruptcy court and remains willing to serve as Special Master in this proceeding to facilitate resolution of discovery issues Mr Edwards continues to consent to this appointment Mr Epstein has declined and continues to decline to agree to the appointment of a Special Master Edwards adv Epstein Case No Case Management Statement Page of7 consistent with his utilization of the pending claim to inflict maximum damage on Mr Edwards who continues to prosecute NEW claims against Mr Epstein on behalf of additional victims The trial of the counter-claim from jury selection to a Phase II punitive damage verdict is estimated to take trial days Mr Edwards sees no need for further case management conferences and is ready for trial Relevant documents include the charging documents in the State prosecution of Mr Epstein his plea of guilty and sentencing documents the Federal Non-Prosecution Agreement all civil Complaints filed against Mr Epstein on behalf of his molestation victims all documents attached to and referenced in Mr Edwards Motion for Summary Judgment all time records reflecting time expended by Mr Edwards his associates and staff on the defense of the spurious and baseless claims against him all documents reflecting expenditures by and on behalf of Mr Edwards in defending the pending claim all media accounts referencing the claims against Mr Epstein Mr Rothstein and Mr Edwards Potential witnesses include all persons referenced in Mr Edwards Motion for Summary Judgment all attorneys who participated in presenting claims against Mr Epstein on behalf of his molestation victims and emotional distress witnesses Plaintiff anticipates calling two witnesses with expertise in legal ethics None Edwards adv Epstein Case No Case Management Statement Page of7 I HEREBY CERTIFY that a true and correct copy of the foregoing A been fu ished by Fax and U.S Mail to all counsel on the atta ff i of lU __ CL:/KLli Jack Scarnla Fl9rida Bar No Sfarc enney Scarola Barnhart Shipley P.A Palm Beach Lakes Boulevard est Palm Beach Florida Phone Fax Attorneys for Bradley Edwards Edwards adv Epstein Case No Case Management Statement Page of7 COUNSEL LIST Jack A Goldberger Esquire Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Phone Fax Farmer Jaffe Weissing Edwards Fistos Lehrman PL Andrews Avenue Suite Fort Lauderdale FL Phone Fax Marc Nurik Esquire Law Offices of Marc Nurik One Broward Blvd Suite Fort Lauderdale FL Phone Fax Joseph Ackerman Jr Esquire Fowler White Burnett P.A Phillips Point West Flagler Drive West Palm Beach FL Phone Fax
