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on his Motion for Protective Order Relating to His Deposition and Motion to Te 267rminate Deposition and Defendants Motion to Compel and Impose Sanctions sep Ackerman Jr Florida Bar No FOWLER WHITE Epstein Rothstein and Edwards 267Case No AG CERTIFICAFEOF SERVICE I HEREBY CERTIFY that a true and correct copy of the foregoing was sen via electronic mail and U.S Mail on this th day of January to Jack Scarola Esq Searcy Dell!leySc_arol_a Barnhart Shipley P.A Palm Beach.Lakes Blvd West Palm:Becich FL Jack Alan Goldberger Esq Att rbury Goldberger Weiss P;A Australian Ave So.ut4 Suile West Palm Beach,.FL Marc Nurik Esq Law Offices.of IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CIVIL DIVISION AG CASE NO Judge David Crow JEFFREY EPSTEIN Plaintiff/Counter-Defendant COPY tCt VED FOR FIUNG SCOTT ROTHSTEIN individually and BRADLEY EDWARDS indivi4ually JAN SHARON BOCK CLERK COMPTROLLER CIRCUIT CIVIL DIVISION Defendants/Counter Plaintiffs PLAINTIFF JEFFREY EPSTEINS MOTION FORPROTECTIVE ORDER RELATING TO ms DEPOSITION ANO-MOTION TO TERMINATE DEPOSITION Plaintiff Jeffrey Epstein moves the Court for entry of a protective order pursuant to Florida Rules of Civil Procedure to prevent Defendant Bradley Edwards Edwards from inquiring into certain areas_ at the second deposition of the Plaintiff and pursuant to Florida Rules of Civil Procedure to terminate the deposition of the Plaintiff for the reasons set forth below On December counsel to Edwards noticed the video deposition of the Plaintiff for January in West Palm Beach Florida to update the deposition of the Plaintiff based on filing of the Corrected Second Amended Complaint Edwards took a _videotape deposition of Plaintiff on March Since that time the Complaint has been amended The Corrected Second Amended Complaint contains a single count against Edwards for abuse of process see The pending abuse of process EXHIBIT I Epstein Rothstein and Edwards Case AG Motion for Protective Order/Motion to Terminate Deposition claim alleges inter alia that a Edwards filed the federal case of L.M Epstein Case No with counts and knew or should have known that the highly-charged sexual allegations were false and that this Complaint was prepared solely to be shown to induce investment in the Ponzi scheme and constitutes an abuse of_process and in order to bolster the cases to investors Edwards engaged in unreasonable and irrelevant discovery as specified in of the Corrected Second Amended Complaint Thus the issues raised by Epsteins Complaint are whether the federal L.M action and specified disc 267overy constitute the improper use of the civil process whether Edwards had ulterior motives for making improper use of the civil process and whether such conduct caused damage to Epstein No issues have been raised by the Plaintiff regarding the truth of allegations of sexual conduct The Plaintiff has not put his mental state in issue Much of Epsteins March deposition was devoted to extensive questioning wards counsel regarding whether Epstein sexually abused underage women e.g were there sexual assaults on an airplane on which he was a passenger Depo Epstein at whether nationally-:prominent acquaintances engaged in illegal sexual activities id at whether Mr Epstein ever sexually abused children and how many id at the number of times Mr Epstein solicited prostitution and the names of minors solicited id at whe er Mr Epstein pied guilty because he was guilty id at the number of times he fondled underage females engaged in oral sex with them and engaged in illegal sexual touching id at and whether he had a personal sexual preference for young women id at Epstein Rothstein an Edwards Case No AG Moti?n for Protective Order/Motion to Terminate Deposition On January the second deposition orEpstein began After asking some preliminary questions counsel for wards began a series of extensive estioning regarding Epsteins alleged sexual buse of underage women More specifically the following questions were asked a WhetherJhe 267Plaintiff has a sexual addiction Whether the Plaintiff has been treated for a sexual addiction Whether the Plaintiff has a sexill!,l preference for mino,rs Whether he has been counseled regarding his sexual preference for mmors Whether he has acted on this alleged addiction Who has treated ltj.m for the add tion Any consultants.that he has tained to address his alleged impaired public image as a result of the sex-reiated charges Whether he has solicited minors for sex in the Virgin Islands in New York in Arizona in Paris at any time or anywhere Some of these questions were asked in the first deposition As soon as a transcript has been receive_d of the deposition it will be filed as a upplement to this Motion When this line of questions began counsel for Epstein objected contending that the line of questioning was irrelevant harassing designed to embarrass the Plaintiff and not likely to lead to any discoverable evidence Counsel for Epstein requested that the Plaintiff Epstein Rothstein and Edwards Case No AG Motion for Protective Order/Motion to Terminate Deposition refrain from such questions advised counsel for Edwards that the Plaintiff was there to answer questions related to the Corrected Second Amended Complaint and requested that the sexually harassing questions be discontinued and that relevant material non-harassing questions be asked Counsel for Edwards declined to follow that request and commenced the objectionable que ions again Another opportunity given to counsel for _Edwards to cease that questioning _and to ask questions material to the lawsuit Counsel for Edwards did ask some questions that had some materiality to the lawsuit but then again went back into the areas of xual questioning When that occurred counsel for Epstein moved to terminate and suspend the deposition in accordance with Florida Rules of Civil Procedure and seek 267relief from this Court Mr Scarola counsel for Edwru:ds placed on the record that he intended to get i_nto other areas relating to the Plaintiffs finances to support his claiin for punitive damages when that motion has not been granted or at allegation has not been permitted _by the Court Mr Scarola specifically stated that he intended to continue the line of questio regarding sexual information in order to bring a RICO claim against the Plaintiff when such a claim cannot be brought by Edwards Therefore it must be for the basis of some other client or potential client or for use in the CVRA case which is prohibited and not appropriate for.discovery in this case Finally Mr Scarola also indicated that it was his intention to continue such a line of sexual questioning with regard to all three lawsuits handled by Edwards for victims who had filed a case against Jeffyey Epstein Țw??I G??b PӂkO Q?Z A߉?jG Rr Zq ГG?aʀ d?S Ij x4 B蹭e c?s8?s e?w9 m?V h?j Dξ a QG bC R?fᢃ?C?bu??m C?ίT vr8?BP??լ?i V?fJ?Cq 4wZ I?R y?M OdO"?j?4?Su I oʩ C?f 3S 1Y r??pË d??U?z OV5 3O c?h?v73?hQ P??Y u?o?4?xH Epstein Rothsteinand Edwards CaseNo AG Motion for Protective Order otion to Terminate Deposition I Clearly the examination by Mr Scarola is being conducted in bad faith and to unreasonably annoy embarrass and oppress the Plaintiff Counsel for Epstein has a good faith belief that Edwards and his counsel are attempting to utilize the deposition process in this case to advance their cause of action ip the Criminal Victim Rights Act claim against the United States in Jane Doe and Case No KAM pending in the United States District Court Southern District of Florida In that case on behalf of two clients of Edwards Mr Edwards is bringing a claim against the United States of America t_o invalidate the Non-Prosecution Agreement entered into between the government and the Plaintiff Such is an inappropriate use of the discovery process Cordis Corp OShea So 2d Fla th DCA Wal-Mart.Stores East L.P Endicott So Fla WeeklyD WL Fla st DCA Edwards should be prohi ited from asking any of the foregoing questions regarding alleged sexual misconduct or related or 267similar questions at Epsteins second depositions for two independent reasons either of which is legally sufficient to support the en of a protective order First Edwards questions regarding Mr Epsteins alleged sexual abuse_ of underage women are intended solely to harass and oppress Epstein and are not asonably calculated to lead to the discovery of admissible evidence dwards hi inflammable questions relating to sexual conduct and criminal misconduct are not and were not designed to and wo not provide any information relevant to Epsteins abuse of process claims in the instant case or Edwards defense of those claims Numerous questions regarding Epsteins allegedly iilegal sexual activities with minors and whether nationally-prominent acquaintances Epstein Rothstein and Edwards Case No AG Motion for Protective Order/Motion to Terminate Deposition engaged in illegal sexual activities would clearly not lead to the discovery of evidence relevant to the instant case and were asked solely to poison the well Such questions regarding sexual conduct are not likely to lead and are not intended to lead to the discovery of relevant evidence regarding whether the discovery conducted by Edwards as alleged in Epsteins pending Complaint abused process or whether the federai L.M action was filed for a legitimate reason and had a reasonable basis Epsteins testimony in Decemb.er as to whether he engaged in sexual misconduct is not probative of whe er Edwards had a good faith basis for filing the federal L.M action in July or whether Edwards had an ulterior motive in filing that action Any evidence 267that Edwards could glean from Epstein at a second deposition cannot be used by Edwards to bootstrap his argument that in July 267the filing of the federal L.M action was justifiable or that the discovery he conducted in Jane Doe E.W etc was legitimate Edwards litany of questions regarding Epsteins alleged sexual misconduct and that of his acquaintances is simply not relevant to any issue in the pending lawsuit for abuse of process On or about September Edwards propounded interrogatories requesting that Epstein disclose the number of minor females.with whom you have had physical contact in the last years and_ the circumstances of such contact lnterrog No the number of times in the last years when you havehad physicaJ contact with minor females id Interrog No the number of times you have witnessed Ghislaine Maxwell engage in sexual activity with minor females id Interrog No With regard to the last time you engaged in sexual activity with a minor state the identity the acts the location a description of Uie sexual activity id Interrog No and the name of every healthcare provider with Epstein Rothstein and Edwards Case No A040800XMB/Div AG Motion for Protective Order/Motion to Terminate Deposition whom you have treated or been evaluated for any sexual disorder Id Interrog No Epstein objected to the foregoing interrogatories on the ground that they sought irrelevant Qlformation and were propounded for purposes of harassment On December this Court entered an Order sustaining Epsteins objections Epsteins objections to Edwards Request for Admissions seekirig similar information were likewise sustained by this Court No circumstances have changed so as to render such iscovery relevant whether it is in the form of paper discovery or a second deposition of Epstein Subsequent Motions for Re-Hearing have also been filed and denied These Orders will be filed as a Supplement to this Motion Edwards modus operandi in asking 267dozens of sexually explicit questions at Epsteins deposition and the patently abusive nature of such questions is vividly demonstr ted by Edwards filing of a 42-page graphic gratuitous and utterly irrelevant Stat ment of Material Fact Although the Statement of Material Facts was ostensibly filed in support of Edwards Renewed Motion for Summary Judgment it is readily apparent that it serves no purpose other than to smear Epstein and poison the well as clearly demonstrated by the fact that although the Statement contains allegedly undisputed facts the Statement of Undisputed Facts is cited only a few times in Edwards renewed summary judgment motion and then only generally and with no citations to any specific facts in Edwards Statement.o_fMaterial Facts I Florida Rules of Civil Procedure affords the Court discretion to gr protective orders for good cause shown and to protect a party from annoyance embarrassment oppression or undue burden or expense See also Logitech Cargo JW Perry So 2d Fla 3d DCA Moreover the Court may determine the time place of a deposition and Epstein Rothstein and Edwards Case No AG Motion for Protective Order/Motion to Terminate Deposition circumstances of how a deposition can occur Fla Civ In this case the Court should prohibit Edwards from posing questions to Epstein regarding his or his friends alleged sexual activities with underage women As a relief the Plaintiff Jeffrey Epstein moves for the entry of a protective order preventing counsel for Edwards from asking any questions relating to sexual allegations alleged sexual acts and questions relating to alleged illegal sexual activities Pursuant to Florida Rules of Civil Procedure a Plaintiff Jeffrey Epstein requests the Court to impose sanctions on the Defendant/Counter-Plaintiff Bradley Edwards WHEREFORE for the above stated reasons Plaintiff Jeffrey Epstein moves for entry of a protective order for an order suspending the deposition and/or terminating it for sanctions and for such other relief as the Court deems proper irt the circumstances ose Ackerman Jr Florida Bar No FOWLER.WHITE Epstein Rothstein a:nd Edwards Case No AG Motion for Protective Order/Motion to Terminate Deposition FOWLER WHITE I I JEFFREY EPSTEIN I Plaintiff vs SC TT ROTHSTEIN individually LEY EDWARDS individually and L.I individually Defendant IN THE CIRCUIT COURT OF TIIE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO MOTION TO COMPEL AND IMPOSE SANCTIONS Defendant/CounterplainHff BRADLEY J_ EDWARDS E:DW ARDS by through his iundersigned attorneys moves this Honorable Court to compel the deposition testimony of Plttiff/Countenlefendant JEFFREY EPSTEIN EPSTEIN and in support would show I I by prior Order of thiS Court EPSTEiN was required over his ol!jection to submit to deposition hi this matter I the duly noticed deposition commenced as scheduled at approximately a.m on uazy i I at approximately a.m after having repeatedly recessed the proceedings to conduct private conferences and having repeatedly refused to answer relevant and material qu tions dm,cdy related to the claims previously brought by him and the claim currently I pending against EDWARDS EPSTEIN unilaterally and without good cause terminated the I epos1tion i EXHIBIT I I Ed ards adv Epstein Ca No Edr ards Motion to Compel Impose Sanctions the proceedings and the circumstances of the termination will be accmately reflected in the trans ript to be provided to the Court immediately upon receipt the unjustified tenninati of the depositioo is part ofEPSTEINs overall strategy to brolong these proceedings and use them to inflict maximum damage on EDWARDS by divbrtmg hjs attention from his professional and personal responsibilities including his pro ecution of pending claims against EPSTEIN in this action and on behalf of clients in Federal co it is further his obvious pUipose to attempt to punish EDWARDS so as to deter him and others from seeking to hold EPSTEIN ci iUy and criminally responsible for his serial ab le of minors EPSTEINs vast wealth renders financial sanctions practically meaningless as a me ns to require him to conform his conduct to the rules of procedure this action nevertheless both EDWARDS and bis counseJ should be compensated for all loss sustained and costs incurred in the taking of the aborted deposition and the prosecution of this motion I EPSTEIN should be compelled immediately to make himself available to coric;:lude the deposition at the sole convenience of EDWARDS and bis counsel EPSTEIN should be held in indirect civil contempt of court a day coerc.ive jail sent nee should be imposed against him and as required by applicable law in the context of civil cori the sentence should suspended upon comlition that the compensatory fme is paid and the deposition is propErrly and timely concluded Ed ards,adv Epstein Ca No Ed ai"ds Motion to Compel Impose Sanctions lHEREBY CERTIFY that a true and correct copy of the forego has been furnished by and U.S Mail to all Counsel on the attached list thi day of Jan I I I I I I I i I arNo Denney Scarola Barnhart Shipley Palm Beach Lakes Boulevard est Palm Beach Florida Phone Fax Attorney for EDWARDS Ed ards adv Epstein Ca No EdTards Motion to Compel Impose Sanctions I COUNSELLIST I JackA Goldberger Esquire Attpibury Goldberger Yeiss P.A Atistralian-Avenue 267South Suite tPalmBeach,FL fhdne Farlner Jaffe Weis Edw ds Fistos Le nnan PL A1h-ews Avenue Suite Fort Lauderdale FL Phdne Fax1 I Maic Nurik Esquire OnJ Broward v:d Suite Fort Lauderdale FL Ph Faxc slph A kerman Jr Esquire Fovher White Burnett P.A If Phillips int West Flagler Drive Palm Beach,.FL Pho Faxl I i
