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Epstein Release Interview Victim Statements Evidence Maxwell
← Back to Epstein v. Rothstein, No. 50-2009-CA-040800-XXXX-MB (Fla. 15th Cir. Ct. 2009)
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_j Notwithstanding three Court Orders mandating him to do so Edwards has failed to provide responsive documents or otherwise file any proper privilege log with respect to the items requested that are directly related to the prosecution and defense of this matter See Ordersftom this Court dated April May andAugust attached hereto as part of composite Exhibit A Undeniably in his Malicious Prosecution Count in his Fourth Amended Counterclaim Edwards specifically alleges that while prosecuting the cases against Epstein at RRA he had not engaged in any unethical illegal or improper conduct nor has EDWARDS taken any actiori inconsistent with the duty he has to vigorously represent the interests of his clients EPSTEIN has Iio reasonable basis to believe otherwise and has never had any reasonable basis to believe otherwise See Edwards sFourth Amended Counterclaim i As such and as demonstrated more fully below,an Order compelling Edwards to comply with.this Courts orders is warranted MEMORANDUM OF LAW Florida law permits litigants ample latitude in discovery Rule of the Florida Rules of Civil Procedure memorializes this broad scope and provides that Parties may obtain discovery regarding any matter not privileged that is relevant to the subject matter of the pending action whether:it relates to the claim or defense of the parfy seeking discovery or the claim or defense of any other party including the existence description nature custody condition and location of any books documents or other tangible things and the identity and location of persons having knowledge of any discoverable matter It is not ground for objection that the information soughtwill be inadmissible atthe trial if the information sought appears reasonably calculated to lead fo the discovery of admissible evidence FLA.R.CIV emphasis added As such as long as the discoyerytequested.is relevant to the cause of action as to any claim or defense and is not otherwise subject to a privilege it is discoverable Here Edwards has a single remaining claim against Epstein for Malicious fonja Haddad P.A SE th Street Fort Lauderdale FL _j Prosecution and has therefore not only made the actions of both him and his law partners at RRA the subject of this litigation but also necessary to prove either his assertions in his cause of action or Epsteins defense thereto This Court has repeatedly agreed yet notwithstanding three Orders coinpeHinghim to do so Edwards not only failed to provide the items 267reqtiested but also failed to provide a privilege log as mandated It is well-settled la that if a pariy alleges that information requested from it is protected by privilege then a privilege:log must be prepared and attached to the response or the privilege is waived See Insurance Corp of America Johnson So 2d Fla 4th DCA stating that failure to provide a reason for privilege and prepare a privilege log constitutes waiver of the privilege emphasis added Accordingly Edwards should be compelled to tum overall of the items requested by Epstein Finally a court has the inherent power to implement and enforce effective judicial proceedings pursuant to pretrial rules As such when a party fails to comply with a pretrial order a court has broad discretion in determining sanctions First Republic Corp o/America Hayes So 2d Fla 3d DCA Rule of the Florida Rules of Civil Procedure provides that for purposes of this subdivh;ion an evasive or incomplete answer shall be treated as a failure to answer FLA R.C1v This Rule likewise governs failure to comply with a prior court order and mandates that such failure inay be considered a contempt of the court FLA R.C1v Plaintiff certifies that he in good faith has conferred or attempted to confer with the person or party failing to make the discovery in an effort to secure the information or material without court action FLA R.CIV CONCLUSION Accordingly for all of the reasons delineated above and in reliance upon the applicable Tonja Had.dad P.A SE th Street Fort Lauderdale FL I I _j law cfted herein Jeffrey Epstein respectfully requests that this Court yet again Order Defendant Bradley Edwards to respond in full to Plaintiffs Request to Produce and such other and further relief as this Court deems proper WE HEREBY CERTIFY that a true and correct copy of the foregoing was served via electronic service to all parties onihe attached service list this September Isl Tonja Haddad Coleman Tonja Haddad Coleman Esq Florida Bar No Tonja Haddad PA SE th Street 267SuiteJ0l FortLauderdale Florida301 facsimile Tonja TonjaHaddad.com Efiling 011jahaddad;com Attorneys for Epstein Tonja Haddad P.A SE th Street Fort Lauderdale FL _J SERVTCR LTST CASE NO Jack Scarola Esq jsx searcylaw.com mep searcylaw.com Searcy Denney Scarola et al Palm Beach Lakes Blvd West Palm Beach FL Jack Goldberger Esq jgoldberger agwpa.com smahoney agwpa;com Atterbury Goldberger Weiss PA Australian Ave South Suite West Palm Beach FL Marc Nurik Esq East Broward Blvd Suite Fort Lauderdale FL I Bradley Edwards Esq brad pathtojustice.com Farmer Jaffe Weissing Edwards FistosLehrman Andrews A venue Suite Fort Lauderdale,.Florida Fred Haddad Esq Dee FredHaddadLaw.com SE 7th Street Suite Fort Lauderdale FL Tonja Haddad Coleman Esq Tonja tonjahaddad:com efiling tonjahaddad.com Law Offices of Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Chester Brewer Jr Wcblaw aol.com wcbasst aol.com Chester Brewer Jr P.A Australian Avenue Suite West Palm Beach FL Tonja Haddad,P.A SE th Street Fort Lauderdale FL I IN TIIE CIRCUIT COURT OF THE th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CIVIL DIVISION AG CASE NO Judge David Crow JEFFREY EPSTEIN Plaintiff/Counter-Defendant SCOTT ROTI-ISTEIN indiyidunlly and BRADLEY EDWARDS individually Defendants/Counter-Plaintiffs PLAINTIFF JEFFREY EPSTEINS MOTION TO COMPEL ANJ AMEND PROTEClIVF.ORDER Plaintiff Jeffrey Epstein CEpslein by and thrntigh his undersigncd 267cow1scl moves.this Court to compel the production of documents from Defendant BRADLEY EDWARDS Edwurds and to amend and lift a protective order relating to a subpoena to the Bankruptcy Trustee The grounds for this Motion arc as follows On April Epstein sent a Request to Prodtice to Edwards requesting the following documents All emails data correspondence men10s or similar docu nents betpeen Bradley Echvards Scoh Rothstein William B.erger and Rus.seU Adl.er and/or any attorney or representative of,RRA and any investor or ird part person or entity regarding Jeffrey Epstein or which mentions Jeffrey Epstein including Mike Fistcn Kenneth Jenne Patiiek Roberts or Rick Rich Fandrey On.May Edwards served his rcspo 267nsetoth.is request by stating Objection as to communications to or from investigators as that is protected by the work-product and/or attorney-client privilege Exhibit A I i I Epstein Rothstein and Edwards Case No AG Epsteins Motiont9 Compel and Amend Protective Order Although Edwards did not object to producing all documcnll requested he did not produce.any documents responsive to this requesL Nor did Edward who asserted privilege prepare a privilege log related to this request It is important to note that this request went to documents within Edward possession and control as opposed to documents that were produced from th Bankruptcy Trustee 1e documents requested in were also requested by means of a subpoena to the Bankmptcy Trustee dated April I After scvcrnl motions and orders to compel Edw.mls finally prepared a privilege log relating to communications to and from the investigators among others However Edwards did not pfodi1cc any e-mails or documents between the lawyers at RRA and a tho U.S Attorn Office thc State Attorneys Office the Federal Bureau of Jnvcstigalion to which he had not objected and for which he did not claim a privilege on his privilege log Edwards did not produce uny documents by and between RRA lawyers or representatives and third parties such ns Conchita Sarnoff a reporter and any other news employees or reporters Edwards has not identified any communication wHh reporters on hi privilege log On January i Epstein sent a second subpoena requesting the following documents from the Bankiuptcy Tmstce I Any and all email communications by/between any attorney and/or employee of the fotmer Rothstein law firm including but not limited to Sc tt Rothstein Russe11 Adler WiUiam Berger Michael F_isten Ken Jenne David Boden Deborah ViUegas Andrew Barnett Patrick Roberts Richard fll!ldry ChristinaKitlcmirin Gary Farmer and Bradley Edwards on the one hand and any of the following regarding Jeffrey Epstein a U.S Attorneys office Epstein Rothstein and Edwards Case No AG Epsteins Motion to Compei and Ant encl Protective Order State ofFloridaAttorneys Office Federal Bureau of Investigations City of PalmBeach Police Department Any investigator working for the State of Florida Any attorney lawfom aud any agent of any attorney or Jaw frnn who represented any individual with a claim against Jeffrey Epstein On April Epstein sent a Request to Produce to Edwards seeking documents that support Edwards contention that Epstein as vaivcd his Fifth Amendment right by speaking to reporters On May Ed vards responded with objections nrtd claims of privilege Edwards did not prepare a privilege log even though the Court ordered him to do.so On July this Cowt entered an Order granting a MC tfon for Protective Order without prejudice relating to the records on the subpoena to the Bmikruptcy ruslec based on scope and rcleva11cy A copy of the Order is attached to this Motion as Exhibit On November Edwards filed his Renewed Motion for Summary Judgment and a lengthy Statement of Undisputed Facts in which he purported to identify i 225sunimary judgment evidence on which he rcHcd 1ch undisputed facfa reference and/or quote the Pnlm Bench Police IncidentReport see correspondence from the U.S Attomeys Office to Epstein see correspondence between the U.S Attorn Office nnd Epsteins counsel see to supp rt Edwards ar.gumcnt that he acted in good faiU1 and that Epstein violated his agrccn1ent vith the lJ.S Attorneys Office il28 Ed;,vards also quotes con-espondcnce from the U.S Attorneys Office to Epsteins counsel see specifically in support of h!s contention that 1here was a joint attempt to minimize Epsteins civil exposure I Epstein Rothstein and Edwards Case No AG Epstein Motion to Compel and Amend Protective Order Id Edwards ulso cites.from a proposed plea agrcement see in support ofhis cont;ntion that Epstein engaged inwilness tampering Edwards hns nlso referred to statements allegedly made by Epstein to a reporter in of his Undisputed Statement of Facts Edwards contends Epsteins aHeged statements to reporters waives his Fifth Amendment rights As a result of Edwards relying on communications with the government and reporters ns port of his Rerie ved Motion for Summary Judgment and to support his.contention thnt Epstein has Vaivcd his Fifth Amendment rights by speaking with reporters discovery is highly appropriate on lhesc issues and should be pennittcd Epstein wishes to amend md narrow his request to the Trustee to obtain the following records Aile-mails data co1Tespondcnce and similar documents dated April through August by and_ between Bradley Edwards Scott Rothstein Marc Nurik Cara Holmes Mike Fistcn and miy one of the following rcg.u;ding or incntioning Jeffrey Epstein in ruiy way the U.S Attorneys Office the Slate Attorneys Office the Federal Bureau of Investigation Conchita Sarnoff and any other news employees or reporters The described documents arenot privileged so no in ca 265icra review is necessary Epsteins request has been narrowed so that compliance nnd production are not overly broad or burdensome The 267rcq1iest is relevant and necessary in order for Epstein to defend Edwnrds Renewed Motion for Summary Judgment including Edwards contention that Epstein his waived his Fifth Amendment rights by discussions and communications with media news employees or reporters Epstein Rothstein and Ed vards Case No Epsteins Motion to Compei ci Amend Protective Order Based on the above Epstein requests thefolfowing relief a An Order directing Edwards to produce the above-described r:ecords that arc in lzls possession und control An Order directing the llankruptcy Trustee to produce the records described aboveand amending the prior protective order so as to allow the Bankruptcy Trustee to produce the records described above and That the Order contain a specific deadline for compliance Epstein requests comp Jinn cc within twenty days of the date of the Order so as to allow time for any additional discovery in a lvm1cc of Rothsteins deposition and in advance of the hearing on Ed,vrirds Renewed Motion for Summary dgment The undersigned counsel certifies that he has and wil_l continue to attempt to resolve this matter with counsel for Edwards without the need of a hearing WHEREFORE 267Plaintiff JEFFREY EPSTEIN requests the Court gmnf ils 225Motion to Compel and Amend Protectiye Order for the reasons set forth above Rcs t,fl Ifr 1qt ittc4 Sfu,8 Jjh Ackcrn1im1 Florida Bar No FOWLER WHITE Epstein Rothstein and Edwards Case No AG Epsteins Motion to Compel and Amend Protective Order FO"WLER WHITE IN TIIE CIRCUIT COURT OF TIIE th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUN1Y FLORIDA CIVIL DTVISIONAG CASE Judge David Crow IBFFREY EPSTEIN Plain ti ff/Countcr-Defondant SCOTI ROTHSTEIN individually and BRADLEY WAR.DS indivi lually Defcndants/CounterN Plaintiffs ORUERON PLAINTIFli JEFFREY EPSTEINS MOTION TO 1PEL AND AMEND PRO"fECTIVE ORDER THIS MATTER came before the_ Court on Plaintiff JeffrcyEpsteins_ Mod on to Compel and Amend Protcc ivc Order i!l the above-styled case This Court lutving reviewed th Motion having heard argument of counsel mid being otherwise fully advised in thcpremises it is hereby OllDERl AND ADJUDGED as follows The Motion seeks to Compel a Req1:1_est to Produce and to rilodify this Courts prior Protective Order in regard to specific requests of the Defendant EDWARDS In addition the Motion seeks authority to direct a subpoena to the Bank ptcy Trustee of the fonncr ln,v firm of the Defendants EDWARDS arid ROTHSTEIN The Court finds that the Amended Rc Juest for Production and request for subpoena docs request documents which the Court find _are jther relevant and/or reaso1ibly cnlculatcd lend to admissible evidence Therefore within tweitfy days ofthc date of this Order the Defendant EDWARDS shall produce any non-privileged documents as klcntified,in..P.aragraP,h.13 of.EDWARDS Motion to Compel and Amend Protective Order In addition the Plaintiff EPSTEIN is given authority to issue a subpoena to the Bankruptcy Trustee requesting the i entical documents that are non-privileged Notlihig in this Order shall constitute any waiver orrnling upon any privilege that may apply to said documents and the Defendant ED ARDS an or others mny file an objection any such documentation on any privilege grounds and shall file a privi ege log specifically identifying such documents EXIBITB Epstein Rotl1stein and Edwards Case No 502009CA040800JCXMB/Division AG Order on Epstcin Motion to Compel and AmendJrotective Order Page of DONV AND ORDERED in Chambers at West Palm BearefcfAJf each County Florida this __ day of April AA D4 JUD Ir IO r1:o DA 1v/D __ HONORABLE DAVID CROW TCf?ow CIRCUIT WOGE Copies furnished to Joseph Ackennan Jr Esq Fo,vlcr White Durnell P.A Phillips Point West South Flagler Ddve West aim Beach FL Lilly Ann Sanchez Esq The Law Finn Four Seasons Tower th Floor Brickell Avenue founi FL Jack Scarola Esq Searcy Denney Scarola Barnhart Shipley P.A Palm Beach Lakes.Blvd West Pahn Beach FL Jack A Goldberger Esq Atterbury Goldberger Weiss P.A Australian Avenue South Suite West PalmBcach FL Marc Nurikt Esq Law Offices of Marc Nurik One Broward Blvd Suite Fort Lauderdale FL Bradley Edwards Esq Fanner Jaffe Wdssing Edwards Fistos Lehrman P.L North Andrews Avenue Suite FortLaud dale,FL301 JEFFREY EPSTEIN Plaintiff SCOTr ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants IN THE CIRCUIT COURT OF.THE FIFTEENTH JUDICIA.L CIRCUIT IN AND FOR PALM BEACH COUNTY FLORIDA CASE NO PLAINTIFFS MOTION TO COMPEL DISCOVERY.RESPONSES AND FOR SANCTIONS Plaintiff Jeffrey Epstein by and through his undersigned counsel and pursuant to Ruic of theF/i,ricla Rules Civil Procedille hereby moves this.Court lo enter an order compelling the Defendant Bradley Edwards yet gain to provide responses to Plnintiffs Request for Production Plaintiff likewise requests that this Court order sanctions against Defendant Edwards for his direct and flagrant disregard of this Courts previous Order dated April In support thereof Plaintiffstatcs INTRODUCTION On March Plaintiff Epstein served upon Defendant Edwards a Motion tq Compel and to Amend and Lift a Protective Order A true and correct copy of Plaintiffs Motion is attached hereto as Exhibit A On April this Court entered an Order on Plaintiffs Motion to Compel stating that within twenty days of the date of this Order the Defendant EDWARDS shall produce any non-privileged documents as identified in Paragraph of EDWARDS sicMotion to Gompel and Amend Protective Order See Order entered April JO tn1e and correct copy which is attached hereto as Exhibit The Orderfurthcr avowed that nothing in this Order shall constitute any waiver or ruling upon any privilege that may apply to said documents and the Dcfo11dm1t EDWARDS and/or others may file an objection to any such documentation on any privilege grounds and shall file aprb,i/ege log lpecijical i identijJ,i,,g such tf icuments See Exhibit emphasis added Accordingly all responses were due on or.before April On May Plaintiff received Defendant Edwards untimely response to the afore-referenced Request to Produce A perfunctory review orthe items provided by Edwards cstabli hes that his response.is incomplete and deficient Ed vards response contains nothing more than partial electronic communications between himself and three or four of the countless reporters with whom he had communications during 267thc relevant time period Fi1rther Defendants response irrefutably corroporatcs that he wholly disregarded this Courts Order Accordingly Defendant Edwards has failed to comply with this Courts Order to_producc the Hems responsive to Plaintiffs Request lo Produce as well as any opportunity afforded to him thereinto provide _any privilcgelog with respect to the afore-referenced request As such and as dem?nstrated more fully below Plaintiffs requested order is warihted MEMORANDlJM OF LAW This Court has the authority to rule oh this Motion without Oral Argument See First City Developments of Florida Inc Jal/mark Holly1ood Condominium Ass So 2d Fla 4th DCA Defendant Edwards was Ordered by this Court to provide aII e-mails data correspondence and similar documents dated April through August IO by and between Bradley Edwards Scott Rothstein Marc Nurik Cara Holmes Mike Fistcn and any on of he following regarding or mentioning ieffrey Epstein in any way a the U.S Attorneys Office the State Attorneys Office the Federal Bureau of Investigation Conchita Sarnoff and any othe news employees or reporters See Exhibit A This Court also permiHed Defendant Ed vards to assert any privilege grounds and file a privilege log specifically identifying such docuinents See Exhibit Edwards not only failed to provide the items requested but also failed to provide a privilege log as mandated It is well-settled law that if a party alleges that information requested from it is protected by privilege Jhcn a privilege log must be prepared a11d attached to the response or the privilege is waive See TIG Insurance C01p of America Jolm.rnn So.:2d Fla 4th DCA I stating that failure to provide a reason for privilege and prepare a privilege log constitutes waiver of the privilege emphasis added Here Edwards fails to either respond to the Request to Produce or assert any privilege as Court ordered A court has the inherent power to implement and enforce effective judicial proceedings pursuant to pretrial rules As such when a party fails to coinply with a pretrial order a court has broad discretion in determining sanctions First Republic Co,p ofAnwricll Hayes So 2d Fla 3d DCA Rule of the Florida Rules if Civil Procedure provides that tor purposes of this subdivision an evasive or incomplete answer shall be treated as a failure to answer FLA R.C1v This Ruic likewise governs failure to coinply w.ith a prior court order and mandates that.such failure maybe considered a.contempt of the court FLA R.CJV Accordingly Defendant Edwards inapposite and patent disregard for this Courts Order mandates sanctions Finally Plaintiff certifies that he good faith has conferred or attempted to confer with the person or party foiling to make the discovery in an effort to secure the infonnation or material without court action FLA R.Ctv A true and correct copy of the correspondence sent to Defendant Edwards regarding this Motion is attached hereto as Exhibit Pursuant to Rule of the Florida Rules of Civil Procedure Epstein is entitled to reasonable attorneys fees necessitated by Defendants flagrant disregard of both this Courts Order and the afore-reference Rules of Civil Procedure CONCLUSION Accordingly for all of the reasons delineated above and in reliance upon the applicable Jaw cited herein Plaintiff Jeffrey Epstein respectfully requests that this Court yet again Order Defendant Bradley Edwards to respond in full to Plaintiffs Request to Produce award attorneys fees as sanctions and such other and further relief as this Court deems proper Ton.fa Ha ad Coleman Esq Fin Bar No LA OFFICHS OF TONJA J-IADDAI PA South Andrews A venue Suite200N fort Lauderdale Florida33.30 I facsimile Tonja tonjahaddadpa:com WE 1-IEREB CERTIFY that a true and correct copy of the foregoing was scr upon aH parties listed on the attached service list via facsimile and US Mail this i fay ru_J Tonjri Haddad Coleman Esq Fla Bar No SERVICE LIST CASE NO Jack Scarola Esq Searcy Denney Scarola ct al Palm Beach Lakes Blvd West Palm Beach FL Jack Goldberger Esq Atterbury,.Goldbergcr Weiss PA AustralianAvc South Suite West Palm Beach FL Marc Nurik Esq I East Brmvnrd Blvd Suite700 267Fort Lauderdale Bradley Edwards Esq Farmer Jaffe Wcissing Edwards Fistos Lehnnan Andrews Avenue Suite Fort l.audcrdalc Florida lilly Ann Sanchez Esq LS.Law.Firm Four Seasons Tower 15th Floor Brickell A venue Miami Fiorida I I I I IN THECIRCUITCOURT OF THE th JUDICIAL CIRCUIT INAND FOR PALM BEACH COUNTY FLORIDA CIVIL DIVISION AG CASE N0 Judge David Crow JEFFREY EPSTEIN Pla!ritiff/Counter-Defendant SCOTT ROTHSTEIN individually and BRADLEY EDWARDS individually Defendants/Counter Plaintiffs __ ORDER ON PLAINTIFF JEFFREY EPSTEINS MOTION TO COMPEL PRODUCTION OF DOCUMENTS.FROM DEFENDANT BRADLEY EDWARDS AND FOR SANCTIONS THIS MATTER came before the Court on Plainti Jeffrey Epsteins Motion to Compel Production of Documents from Defendant Bradley Edwards and for Sanctions in the above-styled case This Court having reviewed the Motion having heard argument of counsel and being otherwise fully advised in the premises it is hereby ORDERED AND ADJUDGED as follows fu do Bm a,d.-s Ac If A c/S Tu I I JP Wif i-s t1 sd-6c.rd dY a thl-d t,AJ fk lt F!fJ Cs d;1cL TlG qi _a Su 2d CJ fi Cf lJ c-A _l I Epstein Rothstein and Edwards Case No 502009CA040800XMB/Division AG Order on Epsteins Motion to Compel and for Sanctions Page2 of2 7h 6l XS tu M.,c iJd cl cc.f IS DONE AND ORDERED in Chambers at West Palrri Beach Palm Beach County Florida this day of fa"1 I YlcY Copies furnished to Lilly Ann Sanchez Esq The Law Firm Four Seasons Tower th Floor Brickell A venue Miami Jack Scarola Esq Searcy Denney Scarola Barnhart Shipley P.A Palm Beach.Lakes Blvd West Palm Beach FL Jack A Goldberger Esq Atterbury Goldberger Weiss P.A 250Australian Avenue South Suite West Palm Beach Marc Nurik Esq Law Offices of Marc Nurik One Broward Blvd Suite Fort Lauderdale FL Bradley J.,Edwards Esq Farmer Jaffe Weissing Edwards,Fistos Lehrman,P.L North Andrews Avenue Suite Foit Lauderdale FL i I JEFFREY EPSTEIN Plaintiff vs SCOIT ROTHSTEIN individually BRADLEY EDWARDS individually and L.M individually Defendant IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FO RPALM BEACH COUNTY FLORIDA CASE NO ORDER ON OUSTANDING DIS THIS CAUSE having come to be con i,deted August on outstanding discovery motions and the Court having revf Yed tlie file and being fully advised in the tr premises it is hereby ORDERED and ADJUDJ ht DWARDS.Motion for Clarification is GRANTED and this Courts Order of is vacated 267without prejudice EDWARDS shall file a written response specifically addressing the production sought in Paragraph of EPSTEINs fl qr Motion fo Come:!"and nd Protective Order ofMarch as Ordered in this Courts r-b April I order The response hall identify no rivileged res onsive documents prev1g,u Jy,produced shall be accompanied by all non-pnv1leged responsive do.cuments not previo prnduced if any and shall identify in a proper.privilege-log as referenced in this Courts May Order responsive documents withheld from production on the basis of any assertion of privilege This respon,se shall be filed within IO days from the date of this Order i I i I Edwards adv Epstein Case No Order on Outstanding Discovery Motions DONE.AND ORDERED atWest Palm Beach Palm Beach County Florida this I Edwards adv Epstein Case No Order on Outstanding Discovery Motions COUNSEL LIST Jack A Goldberger Esquire jgo1dberger agwpa.com smahoney agwpa.com Atterbury Goldberger Weiss P.A Australian Avenue South Suite West Palm Beach FL Phone Fa;,c Bradley Edwards Esquire brad pathtojustice:com Tonja Haddad Coleman Esquire tonja tonjahaddadpa.com Andrews A venue Suite Fort Lauderdale,FL Phone Fax Lilly Ann Sanche5q lsanchez theJ firat The L-S La Ff FaITIIer Jaffe Weissing Edwards Fistos Lehnnan,FL Bn lWnue 15th Floor Miani1 Ee Jf tf 425.North Andrews Avenue Suite Fort Lauderdale FL Phone Fax Marc Nurik Esquire marc nuriklaw.com One Broward Blvd Suite Fort Lauderdale Phone Fa Scarola Esquire earcy Denney Scarola Barnhart Shipley Beach LakesBoulevard West Palm Beach Phone Fax Attorneys for Edwards BATES DATE Privilege Log Dated Farmer Jaffe Welssin Edwards Fistos Lehrman TO FROM Mike Fisten Mike Fisten Russell Adler Bradley Edwards Attorneys at RRA Bradley Edwards Attorneys at RRA Priscila Nascimento Bradley Edwards Jacquie Johnson Bradley Edwards WIiam Berger Attorneys at RRA Bradley Edwards Attorneys at RRA Bradley Edwards DESCRIPTION Investigation into Epsteins 267planes Potential New witnesses Investigation into Epsteins planes Conference room reserved Investigator information Motion to unseal criminal records Investigation Into Epsteins planes Investigation Into Epsteins planes OBJECTION not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to 1ead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by priliacv rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the BATES DATE Undated Privilege Log Dated Farmer Jaffe Welssimt Edwards Fistos Lehrman TO FROM KenJenne Mike Fisten Mike Flsten Bradley Edwards Bradley Edwards Mike Flsten Bradley Edwards Shawn Gilbert Bradley Edwards Shawn Gilbert Unknown Staff Bradley Edwards Attorneys at RRA Mike Flstos Bradley Edwards Mike Fisten DESCRIPTION OBJECTION privacy rights Epstein Probation W/P Attorner Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Epstein Probation W/P Attorney Client Privllege Irrelevant and not reasonably calculated to lead to the discovery of admissible eyidence protected by privacv rights Epstein Probation W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Epstein Case Info W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of a_dmlssible evidence protected by privacy rights Discussion with secretary W/P Attorney Client Privilege Irrelevant and garding client Information not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Miscellaneous case info Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights Legal Research RE Causes of W/P Attorlley Client Privilege Irrelevant and action against Epstein not reasonably calculated to lead the discovery of admissible evidence protected by ririvacv rl2hts Copperfield Depa W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evldencei protected by privacy rights I I A BATES DATE i i i j11I I Cl_ Privilege Log Dated Farmer Jaffe WeissinJ Edwards Fistos Lehrman IQ FROM William Berger Bradley Edwards Bradley Edwa_rds Ken Jenne Bradley Edwards Mike Flsten Attorneys at RRA Mike Fistos Scott Rothstein Russell Adler Attorneys at RRA _Bradley Edwards Bradley Edwards Susan Stirling KenJenne Bradley Edwards DESCRIPTION Depo information Investigation into Epsteins planes Potential new witnesses Legal Research RE Causes of action against Epstein Legal Research RE causes of action against Epstein Legal Research RE causes of action against Epstein Filed Motions Epstein Probation OBJECTION discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by pravacv rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant an not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of.admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Priyilege Irrelevant and not reasonably calculated to lead to the discovery of admlsslbie evidence protected by BATES Privilege Log Dated Farmer Jaffe Weissim Edwards Fistos Lehrman DATE TO FROM DESCRIPTION Bradlev Edwards Mike Flsten Copperfield Depa Marc Nurlk Bradley Edwards Legal Research RE causes of action against Epstein Jacquie Johnson Bradley Edwards Dershowitz Depo Jacquie Johnson Bradley Edwards 0epo technlcalitles Pat Roberts Ronald Wise Mike Flsten Pat Roberts Ronald Wise Mike Fisten Vehicle Registratlons-Vlsoski Vlsoski Research Questions Bradley Edwards Jacquie Johnson Wayne Black Retainer Cara Holmes Jacquie Johnson RE Subpoenas for Epsteins attorneys Bradley Edwards Jacquie Johnson Witness List OBJECTION W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery cf admissible evidence protected by prh1acy rights W/P Attorney Olent Privilege Irrelevant and not reasonably calcuiated to lead io the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege lrre evant and not reasonably calculated to lead to the discovery of admissible evider,ce protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by prlvacv rights W/P Attorney Client Privltege Irrelevant and not reasonably calculated to lead to the discovery cf admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and Privilege Log Dated Farmer Jaffe WelssinJ Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION lead to the discovery of admissible evidence;protected by privacy rights Denis Kleinfeld Beth Williamson Litigation Strategy Work Product;attorney client prlvllege;irrelevant reasonably calculated to lead to the discovery of admissible evidence;protected by pri laCV rights Robert Busche Bradley Edwards Jane Doe brother Attorney/Client privilege and/or work product Robert Busche Bradley Edwards Doe family member Attorney/Client privilege and/or work product Bradley Susan Stirling Jones Atlantic asphalt Attorney/Client privilege and/or work product Edwards Bradley D.F New addition to the case Attorney/Client privilege and/o.r work product Edwards Susan Stirling Bradley Edwards Jane Doe Dukenlk Attorney/Client privilege and/or work product Bradley Jacquie Johnson Subpoena for Adriana Muclnska Attorney/Client privilege and/or work product Edwards MikeFisten Bradley Edwards Samantha Lee Rivera info Attorney/Client privilege and/or work product Robin BradleyJ Edwards case number assignments Attorney/Client privllege and/or work product Kempner Bradley Susan Stirling case list Attorney/Client privilege and/or work product Edwards Jacquie Johnson Bradley Edwards Subpoena for Adriana Mucinska Attorney/Client sirlvilege and/or work product Jacquie Johnson Bradley Edwards Client information Attomey/Cllent privilege and/or work product D.F Bradley Edwards Client communication Attorney/Olent privilege and/or work product N.R Bradley Edwards Client communication Attorney/Oient privilege and/or work product Jacquie Johnson Bradley Edwards Discussion re client/victim Attorney/Client privilege and/or work product personal information N.R Bradley Edwards Client communication Attorney/Client privilege and/or work product RRA Personnel RRA personnel Client names/types of action Attorney/Client privilege and/or work product client Information privacy right prMlege not relevant Russell Adler Bradley Edwards Conflict Check for Brad Edwards Attorney/Client privilege and/orwork product files Pat Roberts Bradley Edwards Client info Attorney/Client privilege and/or work product BATES DATE Privilege log Dated Farmer Jaffe Weisslnf Edwards Fistos Lehrman TO Attorneys at RRA Mike Fisten Amy Swan Bradley Edwards Jacquie Johnson Bradley Edwards Paul Cassell Paul Cassell FROM Priscilla Nascimento DESCRIPTION RE Epstein Conference Room Reserved Bradley Edwards Discussion of Epstein strategy Bradley Edwards VictimPsychologic I Assessme Ken Jenne Investigation into Epsteins planes BTGdley Edwards RE Epstein-Maxwell Subpoena Paul Cassell RICO Statement Bradley Edwards Punitive Damages Bradley Edwards Victim Complaints Forensic accountants Epsteins Fraudulent Transfers OBJECTION privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead ta the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to lead to the discover of admissible evidence protected by privacy rights W/P Attomey Client Privilege trre evant and not reasonably calculated ta lead to the discovery of admissible evidence protected by privacy rights W/P Attorney Client Privilege Irrelevant and not reasonably calculated to le.ad to the discovery of admissible evidence protected by privacy rights BATES DATE Privilege log Dated Farmer Jaffe Weissin Edwards Fistos Lehrman TO FROM DESCRIPTION Jacquie Johnson Bradley dwards Epstein Discovery Jacquie Johnson Bradley Edwards Epstein Discovery Bradley Edwards Jacquie Johnson Epstein Discovery Ken Jenne Bradley Edwards Bradley Edwards Jacquie Johnson Bradley Edwards Paul Cassell Bradley Edwards Marc Nurik Discussions about the Epstein case Epsteindepo in New Yoo Hearing regarding the Epstein computers Epstein AUSA-Attorneys Fees OBJECTION Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by Drivacy rights Work product attorney/client privilege lrrelevanfand not reasonably calculated to lead fo the discovery of the admissible evidence protected by prlvacv rights Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Work product attorney/client privilege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected bv crivacy rights Work product attorney/client privilege irrelevant and not reasonably calculated to lead to 267the discovery of the admissible evidence protected by orivaev rights Work product attorney/client privUege Irrelevant and not reasonably calculated to lead to the discovery of the admissible evidence protected by privacy rights Bradley Edwards Be.th Wilamson Dtscusslons about recovery Brads Work product attorney/client privilege irrelevant and not reasonably calculated to lead Privilege.Log Dated Farmer Jaffe Weissini Edwards Fistos Lehrman I I I I BATES DATE TO FROM DESCRIPTION OBJECTION discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evjdence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Prlv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admlsslble evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv 11ot reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Additional Information RE W/P Priv not reasonably calculate.cl to lead _to Epstein Molestations discovery of admissible evidence Bradley E.dwards Confidential Source Additional Information RE W/P Priv not reasonably calculated to lead to Epstein Molestations discovery of admissible evidence i Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discovery of admissible 267evidence Bradley Edwards Confidential Source Additional Information RE W/P Priv not reasonably calculated to lead to Cl Epstein Molestations disc:overyof admissible evidence Bradley Edwards Confidential Source Litigation Strat.egy W/P Priv not rea onably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to dlscovery of admissible evidence Bradley Edwards Confidential Source Providing NeVJ Witnesses W/P Priv not reasonably calculated.to lead to discovery of admissible evidence Privilege Log Dated I I I I Farmer Jaffe WeissinJ Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv,j not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Secret Plea Deal For Epstein W/P Priv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Secret Plea Deal For Epstein W/P Priv not reasonably calculated to lead to Source discovery ofadmissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P PriI not reasonably calculated to lead to I discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Prlv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Additional Information RE W/P PriI not reasonably calculated to lead to Source Epstein Molestations discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Prlv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P PriI not reaso_nably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Secret Plea Deal For Epstein W/P Prlv notreasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Secret Plea Deal for Epstein W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv notreasonably calculated to lead to Privilege Log Dated Fanner Jaffe Weissinf Edwards Fistos Lehrman BATES DATE TO FROM DESCRIPTION OBJECTION discovery of admissible evidence Confidential Bradley Edwards Providing New Witnesses W/P Prlv not reasonably calculated to lead to Source discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to source discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Prlv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discovery of admissible evidence Confidential Bradley Edwards Providing New Witnesses Priv not reasonably calculated to lead to Source discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Provi ing New Witne_sses W/P Priv not reasonably calculated to lead to dlscovery of admissible evidence Bradley Edwards Confidential Source Litigation Strategy W/P Priv not reasonably calculated to lead to discovery of admissible evidence Bradley Edwards Confidential Source Providing New Witnesses W/P Priv not reasonably calculated to lead to discovery of-admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated _to lead to Source discovery of admissible evidence Confidential Bradley Edwards Litigation Strategy W/P Priv not reasonably calculated to lead to Source discover of admissible evidence Confidential Bradley Edwards Proyiding New Witnesses W/P Priv not reasonably calculated to lead to Source discovery of admissible evidence 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 H?o I Idc rM?M rM 10Cy f헊?f?Tz e?e:Aa I v"x i X5 EO5 5a r?q CX 9r Cy rq rqC M3 ş?:c p/p0 5H V)V 6T Y2 G5 qrM?r?qr?r9 q?10Cy rCX qr l1 X?l 3K fm?Q Z2f CX CX gT L??T 2E Cy 3P EM3 J4T L?h??M q?ᡚ?Y r??O?rJt CTX i P!e i I CTX rC YY I 1e 2j CTX X0T1i k3v Jh/e0h1 H(K 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