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Y9/C 9CX 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 Electronic Service List Jack Scarola Esq Searcy Denney Scarola et al Palm Beach Lakes Blvd West Palm Beach FL JSX SearcyLaw.com MEP Searcylaw.com Jack Goldberger Esq Atterbury Goldberger Weiss PA Australian Ave South Suite West Palm Beach FL jgoldberger agwpa.com Marc urik Esq East Broward Blvd Suite Fort Lauderdale FL marc nuriklaw.com Bradley Edwards Esq Farmer Jaffe Weissing Edwards Fistos Lehrman Andrews Avenue Suite Fort Lauderdale Florida bje.efile pathtojustice.com Lilly Ann Sanchez Esq LS Law Firm Four Seasons Tower 15th Floor Brickell A venue Miami Florida lsanchez thelsfirm.com Fred Haddad Esq Financial Plaza Suite Fort Lauderdale FL Dee FredHaddadLaw.com JEFFREY EPSTEIN Plaintiff vs SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants I IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO JUDGE CROW PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEINS AFFIDAVIT IN SUPPORT OF ms MOTION FOR A PROTECTIVE ORDER AND IN CORPORA TED MEMORANDUM OF LAW I Jeffrey Epstein having been first duly sworn depose and state the following That I am over years old and have personal knowledge of the facts and circumstances surrounding this case That on December Bradley Edwards served me with two separate discovery requests in the above-referenced case seeking to discover my financial net worth That this financial net worth discovery under these circumstances would violate my right to financial privacy as guaranteed by the Constitution of the State of Florida That this financial net worth discovery is designed to embarrass harass and oppress me based upon the following a That Edwards has engaged in and continues to engage in a systematic course of conduct designed to locate potential plaintiffs who might retain him and/or his firm in litigation against me That Edwards continues to actively prosecute a case against the United States of America in Federal Court with the intention of nullifying an agreement between the United States of America and myself That to achieve these goals Edwards uses highly aggressive tactics including Extra-judicial interviews with foreign and domestic press including but not limited to The Palm Beach Post The Buffington Post Conchita Sarnoff The Guardian The Telegraph and The Fort Lauderdale Sun-Sentinel ii Inflammatory postings on the internet including postings on Edwardss firms website and Facebook pages Using emotionally charged pejoratives when referring to me 1v Using my purported relationships with high profile celebrities and personalities to gamer media attention such as but not limited to Englands Prince Andrew Former President Bill Clinton and Law Professor Alan Dershowitz and Noticing some of these same high profile celebrities and personalities for deposition That I had a good faith basis to file the lawsuit against Scott Rothstein Bradley Edwards and L.M That during my deposition on January Mr Scarola on behalf of his client used this opportunity to ask irrelevant harassing and embarrassing questions over and above the repeated objections of my counsel That at said deposition Mr Scarola stated that his questions were relevant and necessary because they were intended to support a RI CO claim that he intended to bring on behalf of Edwards However the fact that this claim has not been brought is proof that the questions asked by Mr Scarola were merely intended for no other purpose than to harass embarrass and oppress me That Edwardss actions in other litigation in which he has been the attorney of record irrefutably proves that even where the Court orders the proper protections from further widespread dissemination of the produced documents in collateral litigations these orders are in essence meaningless and do not prevent Edwards from misusing the documents requested Specifically Edwards circumvented the terms of an agreed-to negotiated Joint Stipulation in Doe Epstein by seeking to disclose confidential negotiations between my counsel and the U.S Attorney that I was compelled by the court to produce where said production was predicated on the protections from public disclosure through the negotiated Joint Stipulation That if permitted such unfettered access to my financial information business ventures and business associates Edwards will continue his well established pattern of seeking harassing oppressive and embarrassing discovery requests and misuse of same especially in light of the fact that he is still seeking potential plaintiffs to bring further lawsuits against me In an effort to render such discovery unnecessary I am willing to stipulate to my financial net worth being in excess of one hundred million dollars FURTHER AFFIANT SAYITH NAUGHT JEFFREY EPSTE THIS PORTION INTENTIONALLY LEFT BLANK I State of New York County of New York Before me the undersigned authority this day personally appeared Jeffrey Epstein who produced as Identification and who first being duly sworn says that all of the matters contained herein are true and correct Sworn and Subscribed before me this January HARRY I BELLER Notary Public State of New Vorlc Qualified in Rockland County Jr Comm1ss1on Expires Feb
