EFTA00799145Set 9
2018-05-2219p5,171w
Intervenors'
motions; begin working on response to same; work
on Response to B. Edwards' Motion for Appellate
Attorneys' Fees
EFTA00799148
Client Ref: 0002 - 0001 May 7, 2018
Invoice # 559 Page ... issues relating to in camera review;
follow up on insurance policy
04/03/18 RJG Review/analyze Edwards' Motion to Strike improper 2.50 987.50
references to alleged contents of privileged
documents from Epstein ... proposed
Sealing Order, work on preparations for April 4, 2018,
UMC hearing on B. Edwards' Motion to Change Case
Style and Case Management; review B. Edwards'
Motion for Sanctions; work
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799145.pdf
EFTA00799106Set 9
2018-05-0339p8,898w
waiver of
same, assertion of privilege in discovery, in
preparation for drafting Response to Edwards' Motion
to Compel Response to Request for Admissions
03/01/18 RJG Continue drafting/revising Response in Opposition ... Edwards' Motion to Compel Response to Request
for Admissions
03/01/18 RJG Begin updating research on malicious 1.90 750.50
prosecution/elements and recent case law in
preparation for trial
03/01/18 RJG Review/analyze ... Edwards' Motion for Separate 0.80 316.00
Trials or, in the Alternative to Adjust the Order of
Proof, in preparation for drafting response
03/01/18 RJG Begin researching bifurcation of trial/eleventh-hour
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799106.pdf
EFTA01100909Set 9
16p3,889w
allegation was meant to have referenced Epstein rather than Edwards.
EFTA01100909
Edwards adv. Epstein
Edwards' Motion to Dismiss Second Amended Complaint
Case No.: 502009CA040800XXXXMBAG
3. the Amended Complaint fails ... Florida 33409
F
ax:
Attorneys for BRADLEY J. EDWARDS
2
EFTA01100910
Edwards adv. Epstein
Edwards' Motion to Dismiss Second Amended Complaint
Case No.: 502009CA040800XXXXMBAG
COUNSEL LIST
Martin Weinberg, Esquire
Martin ... SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually, and
L.M., individually,
Defendant,
SUPPLEMENT TO EDWARDS' MOTION TO DISMISS AND MOTION FOR LEAVE
TO AMEND TO ASSERT CLAIM FOR PUNITIVE DAMAGES
Defendant/Counter-plaintiff
https://www.justice.gov/epstein/files/DataSet%209/EFTA01100909.pdf
EFTA00596449Set 9
2008-08-0836p11,867w
York Daily News, respectfully submits this
memorandum of law in opposition to Bradley J. Edwards' motion to compel the Daily News to
produce a tape recording that news reporter George ... record unpublished interview
for use in his private litigation in Florida. As such, Edwards' motion strikes at the very heart of
the reporter's privilege codified in lig Civil Rights ... newsgathering efforts of journalists for their
private purposes, were routinely permitted.") (internal citations omitted).
Edwards' motion to compel must be denied for several reasons. First, the Court need not
even
https://www.justice.gov/epstein/files/DataSet%209/EFTA00596449.pdf
EFTA00807470Set 9
2018-03-1318p5,538w
Epstein's Omnibus Response in Opposition to Edwards' Four
Motions to Compel.
3. 10/26/17, Edwards' Motion for Protective Order.
4. 11/6/17, Epstein's Supplemental Motion to Compel Discovery ... Production from Non-Parties.
7. 11/22/17, Epstein's Request for Judicial Notice.
8. 12/1/17, Edwards' Motion for Leave to Propound Limited Requests for
Admission.
9. 12/4/17, Edwards' Notice of Filing ... County,
Case No. 502009CA40800XXXMB (M. 385).)
75. On October 4, 2011, the Court denied Edwards' Motion to Dismiss Second
Amended Complaint finding that the allegations were sufficient to plead
https://www.justice.gov/epstein/files/DataSet%209/EFTA00807470.pdf
EFTA00582880Set 9
2009-12-2111p3,299w
EDWARDS,
individually
Defendants.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN
OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'
MOTION FOR LEAVE TO AMEND TO ASSERT CLAIM FOR PUNITIVE DAMAGES
Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein ... undersigned counsel, hereby offers the following response in opposition to Defendant/Counter-
Plaintiff EDWARDS' ("Edwards") Motion for Leave to Assert a Claim for Punitive Damages
("motion")" and states:
SUMMARY OF ARGUMENT ... Tiger Point Golf v. Hippie, 977 So. 2d 608. 610 (Fla. 1" DCA 2007). Edwards'
motion should not be permitted to obscure the fact that he cannot seek punitive damages
https://www.justice.gov/epstein/files/DataSet%209/EFTA00582880.pdf
EFTA00612483Set 9
2015-10-2035p8,537w
filing Epstein's response to the motion to cancel oral argument, indicating that
Edwards' motion would be opposed based in part upon the tipsy coachman doctrine.
An agreement could ... Epstein, November 5, 2009, 08-cv-80119 (R. 815), stating:
Plaintiff's [Edwards'] motion is entirely devoid of evidence of
Defendant's [Epstein's] alleged fraudulent transfers. The Court declines
https://www.justice.gov/epstein/files/DataSet%209/EFTA00612483.pdf
EFTA00623045Set 9
2009-10-139p2,567w
EDWARDS,
individually, Defendants.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN
OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'
MOTION TO DISMISS THE CORRECTED SECOND AMENDED COMPLAINT
Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("EPSTEIN"), by and through ... undersigned counsel, hereby offers the following Response in Opposition to Defendant/Counter-
Plaintiff EDWARDS' ("EDWARDS") Motion to Dismiss the Corrected Second Amended
Complaint and states:
1. EDWARDS' two-page, five-paragraph ... Rothstein, Edwards
Case No.. 502009CA040800XXXXMB/Div. AG
Epstein's Response in Opposition to Edwards'
Motion to Dismiss Second Amended Complaint
settlements to unsuspecting investors. Through the law firm of Rothstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00623045.pdf
EFTA00811311Set 9
2018-03-0810p2,963w
Privileged Documents
7. On March 8,2018, the Court held a hearing on Edwards' Motion to Strike, at which
time the Court granted the motion and ordered all pleadings referencing ... party included explicit language memorializing this
broad ruling in their competing proposed orders on Edwards' Motion to Strike Untimely Exhibits,
et al, which were submitted to the Court late last ... referring to the documents at issue.
12. First, in his Response in Opposition to Edwards' Motion for Partial Relief from
Stay filed on March 14, 2018, Epstein not only gratuitously
https://www.justice.gov/epstein/files/DataSet%209/EFTA00811311.pdf