In any event the pending counter-claim turns on Epsteins state of mind i.e whether he had a valid basis for bringing a lawsuit against Edwards Despite this narrowing of the case Epstein continues to attempt to force Edwards to answer a series of detailed questions about his legal representation of sexual abuse clients At his deposition Edwards through legal counsel properly raised objections to these questions including attorney-client privilege work product privilege and for other well-founded reasons Epstein has failed to provide any sound basis for ove1Tuling the objections Accordingly the Court should deny his motion to oven-ule the objections MEMORANDUM OF LAW The attorney-client privilege is provided for in section Florida Statutes which states that a client has a privilege to refuse to disclose and to prevent any other person from disclosing the contents of confidential communications when such other person learned of the communications because they were made in the rendition of legal services to the client Fla Stat The purpose of the attorney-client privilege is to encourage clients to make full disclosure to their attorneys Genovese Provident Life Accident Ins Co So 3d Fla as revised on denial ofrehg Nov quoting Fisher United States U.S It is also impo1iant to note that the attorney/client privilege belongs to the client not the attorney Neu Miami Herald Pub Co So 2d Fla The work product doctrine provides an additional level of protection for attorneys involved in litigation and is outlined in Florida Rule of Civil Procedure which states that a party may obtain discovery of documents and tangible things otherwise discoverable under subdivision of this rule and prepared in anticipation of litigation or for trial by or for another party or by or for that partys representative including that partys attorney consultant surety indemnitor insurer or agent only upon a showing that the paiiy seeking discovery has need of the materials in the preparation of the case and is unable without undue hardship to obtain the substantial equivalent of the materials by other means In ordering discovery of the materials when the required showing has been made the court shall protect against disclosure of the mental impressions conclusions opinions or legal theories of an attorney or other representative of a party concerning the litigation The rationale supp011ing the work product doctrine is that one party is not entitled to prepare his case through the investigative work product of his adversary where the same or similar information is available through ordinary investigative techniques and discovery procedures Millard Mall Servs Inc Bolda So 3d Fla th DCA quoting Southern Bell Tel Tel Co Deason So.2d Fla If the moving paity fails to show that the substantial equivalent of the material cannot be obtained by other means the discovery will be denied Millard Mall Servs Inc Bolda So 3d at EPSTEINS MOTION FILED AS LONG AS SEVEN-AND-A-HALF-YEARS AFTER THE DEPOSITION SHOULD BE DENIED AS UNTIMELY Epstein took Edwards first deposition on March than seven-and-a-half years ago Epstein took Edwards second deposition on May than four years ago Now with the trial rapidly approaching Epstein has filed a motion challenging certain objections that Edwards legal counsel interposed years ago Epstein provides no reason why he failed to raise this issue much sooner For example if Epstein had concerns about privileges and other related objections that developed during the March deposition he should have raised them with the Court before the May deposition And even after the May deposition Epstein has waited for years to raise any concern Delaying to raise the issue years later is unfair both to Edwards-and to the Court-since the issues could have been resolved long ago without the need for a possible third deposition which would need to be set on the eve of trial Nor does Epstein offer any clear reason why the Court should address these issues now as part of pre-trial discovery for a case set to go to trial shortly It is important to note that Edwards will testify at trial and Epstein will be of course free to ask any legitimate questions at that time Should something develop during the course of the trial that makes an answer from Edwards relevant and admissible the Comi would always be free to direct an answer at that time Epstein provides no explanation why the discovery at issue here is necessary now to help him prepare for trial Accordingly Epstein will suffer no prejudice if the Court denies his motion Entirely apart from any particular deadlines that may or may not have been set it is well settled trial courts have broad discretion in controlling discovery and in issuing protective orders Katzman Rediron Fabrication Inc So.3d Fla 4th DCA Epstein offers no reason why this discovery at this late date is need to help him prepare for trial Consider for example on the very first questions Epstein seeks to force attorney Edwards to answer Why did E.W come why did she hire you in the first place What was the purpose As the Court is aware E.W was one of Epsteins sexual assault victims After Edwards filed a lawsuit against Epstein for the sex abuse E.W testified in the underlying civil case that Epstein sexually abused her In the underlying civil case as well as in this case Epstein took the Fifth rather than answer the questions about his sexual abuse of E.W Against that backdrop Epstein does not explain why it is necessary for the Court to address the issue of whether attorney-client privilege properly was invoked to prevent question in this area although to be clear the privilege obviously does apply The Court should exercise that discretion in favor of finding that Epsteins objections are simply raised too late EDWARDS HAS NOT WAIVED ANY PROTECTIONS Epstein also argues that the Edwards has somehow waived these protections by filing his counterclaim But it is important to understand the parameters of Edwards counterclaim against Epstein which alleges Epstein engaged in wrongful conduct against Edwards See Fomih Amended Counterclaim by Edwards against Epstein Jan That counterclaim thus turns on Epsteins state of mind as demonstrated by one of the important allegations in the counterclaim EPSTEIN knew at the time of the filing of the specified claims against Edwards and throughout his failed prosecution of those claims that he could not prosecute the claims to a successful conclusion because a they were both false and unsupported by any reasonable belief or suspicion that they were true he had suffered no legally cognizable injury proximately caused by the falsely alleged wrongdoing on the paii of EDWARDS he had no intention of waiving his Fifth Amendment privilege against self-incrimination in order to provide the relevant and material discovery that would be necessary in the course of prosecuting the claims even if they had any reasonable basis and he knew that his prosecution would consequently be baITed by the sword-shield doctrine EDWARDS conduct in the prosecution of claims against EPSTEIN could not support the prosecution of a separate civil lawsuit against EDWARDS because of the absolute protection of the litigation privilege Fomih Amended Counterclaim at emphasis added As the highlighted language above makes clear the issue to be tried in connection with Edwards counter-claim against Epstein turns on what Epstein knew when he filed his lawsuit against Edwards Questions of what happened in a private meeting when E.W for example came to Edwards law office for a private meeting cannot have any bearing on Epsteins knowledge Epstein points to one paragraph of the Edwards counterclaim as somehow constituting a broad waiver of attorney-client and work-product protections Paragraph of the counterclaim reads While prosecuting the legitimate claims on behalf of his clients EDWARDS has not engaged in any unethical illegal or improper conduct nor has EDWARDS taken any action inconsistent with the duty he has to vigorously represent the interests of his clients EPSTEIN has no reasonable basis to believe otherwise and has never had any reasonable basis to believe otherwise Fourth Amended Counterclaim at emphases added The key language in this paragraph is the highlight language which concerns Epsteins reasonable basis for believing that Edwards was somehow not pursuing legitimate claims for his clients Until Epstein is willing to testify that the sex abuse claims were illegitimate he has no reason for deposing Edwards on any of these subjects Of course as the Court is well aware Epstein has taken the Fifth rather than answer the simple foundational question of whether the sex abuse lawsuits against him were legitimate The only case that Epstein cites in support of his waiver theory is a federal decision from a federal magistrate judge involving application of the federal rules of civil procedure Mot at citing Dunkin Donuts Inc Marys Donuts Inc F.R.D Epstein does not quote from the case directly but instead crafts his own description of the holding But the case involved a situation where corporate plaintiff was refusing to provide a corporate representative to testify about the plaintiffs theory of the case See id at Plaintiffs object to provide a corporate representative to testify as to the facts supporting their theory that Defendants undeITeported sales and analyzing the issue under Fed Civ Here of course Mr Edwards has been deposed twice as long as seven years ago about his theories of the case This case is vastly different than that one Moreover even assuming for sake of argument that any sort of waiver has taken place the waiver would be expressly limited Perhaps in contrast to federal law under Florida law a party can make a limited waiver of its attorney-client or work product privileges in this state Paradise Divers Inc Upmal So 2d Fla th DCA citing Volpe Conroy Simberg Ganon P.A So.2d Fla 4th DCA Shafnaker Clayton So.2d Fla 1st DCA Air Lines Inc Gellert So.2d Fla 3d DCA waiver by disclosure limited to other unrevealed communications only to the extent that they are relevant to the communication already disclosed see also Procacci Seit/in So.2d Fla 3d DCA citing cases regarding limited waiver As is apparent for portion of the Counterclaim discussed above the only waiver that Edwards could even conceivably be making by filing his lawsuit would be with regard to situations where Epstein is claiming to have had a good faith and honest belief that Edwards was engaged in improper activities But as the Comi well knows Epstein has not testified to any such belief instead taking the Fifth when asked the most basic questions about his crimes and Edwards representation of clients attempting to hold Epstein accountable for them Because any alleged waiver would be limited to any area where Epstein had pled such a belief Epstein presents no basis for finding any waiver at all See Paradise Divers Inc Upmal So 2d Fla Dist Ct App The limited waiver made by Paradise on the subject of maintenance and cure does not constitute a waiver of the attorney client and work product objections made to protected investigative materials mental impressions or communications concerning other counts of the complaint Finally in addition to all these problems Edwards simply is unable to somehow waive the attorney-client privilege because that privilege belongs not to him but to his clients See Neu Miami Herald Pub Co So 2d Fla It is also important to note that the attorney/client privilege belongs to the client not the attorney For all these reasons the Court reject Epsteins argument that Edwards has waived any protections over confidential communications EDWARDS OBJECTIONS ON GROUNDS OF ATTORNEY-CLIENT PRIVILEGE AND WORK PRODUCT PROTECTION SHOULD BE SUSTAINED As Epstein notes attorney-client and work product issues arose repeatedly during the course of attorney Edwards deposition This is hardly surprising because Epsteins defense counsel repeatedly asked Edwards to answer questions about the details of his legal strategies and investigations during Edwards deposition By Epsteins count Edwards raised attorney-privilege approximately times and work product doctrine approximately times Mot at Rather than go through each of the specific objections Epstein has cherry-picked a few examples that he believes exemplify why the objections should be overruled But even his selected examples presumably the best he could find to make his arguments demonstrate quite clearly that the objections should be sustained For the convenience of the Court Edwards will proceed to refute the examples cited by Epstein in the order they appear in his motion Initial Examples o.f Attorney-Client and Work Product Assertions As a starting point consider this exchange that Epstein highlights as one of his first examples Why did E.W come why did she hire you in the first place What was the purpose Transcript of Deposition dated March page lines A This is going to get into attorney-client privileged information as to why she hired me which would incorporate the things that she told me that related to my representation therefore I am invoking the privilege and not answering Id at page lines Mot at Epstein offers no reason whatsoever for believe that this objection is even arguably improper Indeed it is not until pages later in his motion that Epstein advances his general arguments about attorney-client privilege See Mot at There Epstein even writes that an attorney-client communication is one that relates to the subject matter of the attorneys employment Mot at citing Gold Coast Race 267way Ehrenfeld So.2d Fla th DCA citations omitted Obviously asking why E.W sought to hire Edwards goes directly to the subject matter for which Edwards was hired and falls squarely within attorney-client privilege even under the authorities Epstein has chosen to cite Of course the same protection would exist with regard to Epsteins questions about another of Edwards sexual abuse clients L.W Epstein asked about why she hired Edwards And what for what purpose did Ms L.M originally hire you Transcript of Deposition dated March page line MR SCAROLA I am going to object That calls for attorney-client privilege Id at page line Mot at Here again it is hard to imagine a subject more directly covered by the attorney-client privilege than this one Questions Related to Attorney Russell Adler Epstein next discusses questions touching on attorney Scott Rothstein and legal research and factual investigation that Edwards conducted while representing his sex abuse clients Mot at With regard to these objections they are obviously well-founded attorney-client and work product objections Consider for example a question Epstein asked Edwards regarding a meeting between attorney Russell Adler and attorney Bradley Edwards regarding a legal issue that arose during the case Was a question posed to you Transcript of Deposition dated March at page line A The question was on the table at least from my perspective coming into the room and was then directed at me whats the answer to this particular legal issue Id at page line And what was the legal issue Id at page line MR SCAROLA If this was an issue that was identified during the course of the legal proceedings to opposing counsel then I am going to allow you to identify the issue without getting into any of the substance of the discussion regarding that issue If it was an issue that was identified in the cour se of the proceedings to opposing counsel I am going to object and instruct you not to answer on the basis of the work-product privilege Id at page line A Work product privilege Id at page line Mot at Obviously these questions go directly at a legal issue that had arisen between lawyers during the course of the proceedings where Edwards was representing his sex abuse clients in their lawsuits against Epstein It is hard to image a clearer example of a communication protected by the work-product doctrine Indeed exploring this subject would necessarily involve discussions of attorney Edwards mental impressions conclusions opinions and theories which generally remain protected from disclosure Southern Bell Tel Tel Co Deason So 2d Fla Edwards Refitsal to Allow His Clients to Go on Television Epstein also points to the fact that Edwards refitsed to allow his sex abuse clients to be interviewed by television stations Mot at Epstein does not explain how consistent with his theory of the case Edwards efforts to reduce publicity could somehow be relevant to his case But in any event Edwards testified that investigating this subject would involve exploration of protected attorney-client communications see Transcript of Deposition dated March Id at page line and Epstein offers no reason to doubt that assertion Subpoena to Maxwell An equally obvious situation involving attorney work product is Epsteins question to Edwards about why he decided to serve a subpoena on Ghislaine Maxwell the girlfriend of Epstein See Mot at Maxwell is not one of the individuals that Epstein cites in his complaint as one of the persons Edwards allegedly asked to depose for improper purposes Therefore delving into the reasons for the subpoena would necessarily involve exploration of attorney Edwards mental impressions conclusions opinions and theories which have the highest level of word production protection See Southern Bell Tel Tel Co So 2d at Epstein offers no sound reason for stripping Edwards of work product protection particularly in light of the fact that he refused to answer any questions about which of his close associates were involved in his sexual abuse Edwards Directions to His Investigator Yet another obvious example of work product protection comes from Epsteins request that Edwards explain why Edwards investigators in the case were investigating ce1iain subjects Mot at Here again Epstein offers no sound reason for requiring Edwards to answers these questions Epstein appears to forget that he voluntarily dismissed his claim against Edwards and what remains to be tried is Edwards counter-claim against Epstein The counterclaim turns on Epsteins malice toward Edwards that is what Epstein himself knew when he filed his now dismissed action against Edwards not the confidential details of Edwards investigation of the sex abuse cases which of course Epstein could not have known and does not allege that he knew Illustrative of this point is this paragraph in the counterclaim alleging malice by Epstein EPSTEIN acted purely out of malice toward EDWARDS and others and he had ulterior motives and purposes in filing his unsupported and unsupportable claims EPSTEINS primary purpose in both filing and continuing to prosecute each of the claims against EDWARDS was to inflict a maximum economic burden on EDWARDS in having to defend against the spurious claims to distract EDWARDS from the prosecution of claims against EPSTEIN arising out of EPSTEINS serial abuse of minors and ultimately to extort EDWARDS into abandoning the claims he was prosecuting against EDWARDS Fourth Amended Counterclaim at emphases added Of course in this case Epstein never testified that he was aware of Edwards undertaking certain investigations and most important Epstein never testified that those investigations were unrelated to his sex abuse of minor girls Epstein cannot even begin to show the kind of factual predicate that would be necessary to make these issues relevant to his case He does allude vaguely to the issue of whether Edwards engaged in improper conduct Mot at But here again Epstein does not specify what improper conduct he genuinely and honestly believed Edwards was engaged in and he refused to answer questions about these subjects at his deposition He cannot carry his burden of showing why the Court should compel Edwards to answer questions about work-product protected infonnation Edwards Investigation Concerning Alfi,edo Rodriguez Epstein next contends that he wants to dete1mine the scope of Mr Edwardss knowledge of Mr Alfredo Rodriguez Mot at citing to deposition questions on this subject It appears to be undisputed that Rodriguez was a household employee of Epsteins during the relevant time frame when Epstein was sexually abusing girls in his home so it is hard to understand how Edwards could even conceivably have been engaged in some sort of improper action in trying to determine what Rodriguez knew about the abuse Moreover the Court will recall that it is a matter of public record that Rodriguez was federally prosecuted for and pied guilty to transactions involving the Holy Grail of Epsteins contact list with minor girls and his associates See United States Alfredo Rodriguez Case No 10-80015-CR-Marra/Hopkins DE statement of facts for plea agreement U.S Dist Ct S.D Fla June noting Rodriguezs possession of documents from Epstein including names of material witnesses and additional victims and that after being arrested Rodriguez advised the FBI he had witnessed naked girls whom he believed were minors at the pool area of Epsteins home knew that his former employer i.e Epstein was engaging in sexual contact with underage girls and had viewed pornographic images of underage girls on computers in Epsteins home And once again Epstein refused to answer any questions about Rodriguez during his deposition although he now seeks to force Edwards to answer questions on this subject The salient fact remains that Edwards efforts to obtain information from Rodriguez fall squarely within work-product protection For Edwards to answer questions would once again require direct exploration of Edwards mental impressions about the case he was investigating Epstein offers no sound reason for stripping Edwards of work product protection Edwards Efforts to Obtain Information About Epstein fi the Government Epstein next seeks to force Edwards to answer questions about his effo1is to obtain information from the federal government about Epsteins crimes Here again as the Court well knows it is a matter of public record that the federal government undertook an extensive investigation of Epsteins criminal sex abuse of minor girls Ultimately this investigation produced a non-prosecution agreement in which Epstein agreed to pled guilty to two Florida sex crimes in exchange for the federal government agreeing not to prosecute Epstein for federal crimes such as knowingly and willfully conspiring with others known and unknown to commit an offense against the United States that is to use a facility or means of interstate or foreign commerce to knowingly persuade induce or entice minor females to engage in prostitution in violation of Title United States Code Section all in violation of Title United States Code Section See Epstein Non-Prosecution Agreement at I see also id at recounting four other federal sex crimes involving minors covered by the federal non-prosecution agreement Against that uncontested factual backdrop Epstein eff01is to depose Edwards as to why he was attempting to secure information from the Government about Epsteins federal sex crimes can have serve no other purpose than harassment and Epstein never explains why he needs answers to the questions at issue as part of his defense But once again the salient point remains that Edwards mental impressions and other reasons for pursuing investigation in this area is protected from disclosure by the work-product doctrine Epstein has not shown any good reason for the Court to deny protection here particularly given the fact that he could have obtained any relevant info1mation in other ways See e.g Universal City Dev Partners Ltd Pupillo So 3d Fla th DCA extending work product protection where litigant was free to obtain information through discovery or public records requests to the law enforcement agencies Information Sharing Between Plaintiffs Attorneys Epstein next seeks to force Edwards to discuss any information-sharing arrangement that might have existed between the multiple plaintiffs attorneys representing Epsteins victims and Edwards in the course of representing his victims Mot at Here again it is hard to understand how answers to such questions could have even the remotest relevance to the case at hand Assuming for sake of discussion that such a1Tangements were put in place they would simply be a standard device for sharing information between clients with a common goal holding Epstein accountable for the sex offenses he committed against minor girls Epstein offers no explanation as to why the existence and/or details such a1Tangements could be important to any jury evaluating this case Of course he never testified about having any concern about these arrangements when he was deposed But once again the salient point remains that Edwards mental impressions and other reasons for creating any such a1Tangements is protected from disclosure by the work-product doctrine Edwards Prosecution of Epstein Cases in Next Epstein seeks to force Edwards to discuss the confidential legal strategy underlying decisions made regarding investigation of some of Epsteins high-profile friends who might have had knowledge of Epsteins sex abuse Mot at Here again Epstein has never testified that he had a good faith basis for believing that any efforts made by Edwards were somehow improper Of course instead of providing any such testimony Epstein invoked his Fifth Amendment rights rather than answers questions about his friends during his deposition allowing the Court and the jury to infer from that fact alone that these individuals would have had relevant information for Edwards to investigate Epstein never clearly explains why he needs a third deposition of Edwards to explore these subjects to prepare for trial He himself has the best infonnation about the connections between himself and his friends and what sexual activities and/or minor girls his friends may have observed while interacting with him In seeking to penetrate work product protection Epstein must show that he is unable to obtain infonnation from other sources See e.g Universal City Dev Partners Ltd Pupillo So 3d Fla th DCA under work product doctrine if the moving party fails to show that the substantial equivalent of the material cannot be obtained by other means the discovery will be denied Epstein obviously has other means to explore his friends connections to his sex abuse his own personal knowledge Moreover the questions Epstein seeks to force Edwards to answer involve discussions between attorneys about why they made pa1iicular decisions in the course of litigating the sex abuse cases against Epstein Such discussions are at the zenith of work product protection since they go directly to attorneys mental impressions The Court should not force a third deposition regarding such issues Assorted Objections Epsteins brief concludes with vanous assorted objections which he believes were improper Mot at The reasons that Edwards has provided above apply equally to these objections here The Court should not force a third deposition on these subjects It is more transparent now than ever that Epstein really just wants to know what Edwards knows about Epsteins criminal activities when he learned it how he learned it as well as what information about Epsteins criminal activities that Edwards through is diligent investigation has yet to learn CONCLUSION Wherefore Counter-Plaintiff respectfully requests that this Court deny Jeffrey Epsteins Motion to Compel Discovery Responses from Bradley Edwards as the motion in untimely made and is without merit I HEREBY CERTIFY that a true and c01Tect copy of the foregoing was sent via E-Serve da ar No ey E-Mail jsx searcylaw.com and cann searcylaw.com ary 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 COUNSEL LIST William Chester Brewer Esquire wcblaw aol.com wcblawasst gmail.com Australian A venue 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 Avenue Suite West Palm Beach FL Phone Fax Attorneys for Jeffrey Epstein Nichole Segal Esquire nj 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 Farmer Jaffe Weissing Edwards Fistos Lehrman P.L Andrews A venue Suite Fort Lauderdale FL Phone Fax Fred Haddad Esquire Dee FredHaddadLaw.com Fred FredHaddadLaw.com Fred Haddad P.A One Financial Plaza Suite Fort Lauderdale FL Phone Fax Attorneys for Jeffrey Epstein Tonja Haddad Coleman Esquire tonja tonjahaddad.com efiling tonjahaddad.com Tonja Haddad P.A SE 7th Street Suite Fort Lauderdale FL Phone Fax Attorneys for 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