IN THE CIRCUIT COURT OF THE
FIFTEENTH JUDICIAL CIRCUIT, IN AND
FOR PALM BEACH COUNTY, FLORIDA
JEFFREY EPSTEIN, CASE NO.: 502009CA0408003OOOCMBAO
Plaintiff,
vs.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually, and
.1., individually,
Defendants.
/
COUNTER-PLAINTIFF EDWARDS' MOTION TO OVERRULE
COUNTER-DEFENDANT EPSTEIN'S OBJECTIONS
AND TO COMPEL ANSWERS TO INTERROGATORIES
Counter-Plaintiff, Bradley Edwards ("Edwards"), pursuant to Florida Rule of Civil
Procedure 1.380, moves for an order overruling the blanket attorney-client privilege objections
raised by Counter-Defendant, Jeffrey Epstein ("Epstein"), in answers to interrogatories, and
compelling Epstein to answer the interrogatories, and states:
Background
1. Epstein is a convicted felon for having engaged in illicit sexual activity with
numerous underaged girls over a period of years.
2. Edwards represented three of Epstein's victims in connection with criminal
investigations and civil lawsuits.
3. In an effort to avoid compensatory and punitive damage liability, to deter
cooperation in the ongoing criminal investigations, and to intimidate his victims and their
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