EFTA00808816Set 9
2009-12-0738p7,270w
discovery matters were addressed.
On December 22, 2017, Edwards and Epstein filed a Joint Pretrial Stipulation
(Res.App.5, pp.59-303).4 In the Joint Pretrial Stipulation, the parties identified the
issues ... same
circumstances.).
(Res.App.5, p.68). Thus, Edwards recognized in the Joint Pretrial Stipulation that
there was a possibility of prejudice to Edwards or confusion of the jury resulting
4 Epstein ... included the Joint Pretrial Stipulation in his Appendix to the Petition for
Writ of Certiorari; however, he did not include the exhibits to the stipulation.
Edwards has included the Joint
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808816.pdf
EFTA00807470Set 9
2018-03-1318p5,538w
JEFFREY EPSTEIN,
Plaintiff/Counter-Defendant,
v.
SCOTT ROTHSTEIN, individually, and
BRADLEY J. EDWARDS, individually,
Defendants/Counter-Plaintiff.
JOINT PRETRIAL STIPULATION
Pursuant to this Court's Order Specially Setting Jury Trial Plaintiff/Counter-Defendant
Jeffrey Epstein ("Epstein ... Defendant/Counter-Plaintiff Bradley Edwards ("Edwards") hereby
submit this Joint Pretrial Stipulation.
A. List of All Pending Motions: The trial of this matter is special set to commence on March ... Discovery Responses from Edwards;
EFTA00807470
Epstein v. Rothstein and Edwards
Case No. 502009CA040800XXXXMBAG
Joint Pretrial Stipulation
Page 2
c. 9/28/17, Edwards' Memorandum in Opposition to Epstein's Motion to Compel
https://www.justice.gov/epstein/files/DataSet%209/EFTA00807470.pdf
EFTA00801275Set 9
90p17,710w
legal significance, if I can approach, is
16 laid out in our pretrial stipulation.
17 And the case law is really clear. When
18 lawyers enter into a pretrial stipulation ... read it. I didn't go back and look at the
8 pretrial stipulation itself, among the --
9 just so everybody knows -- among the 1,239
10 docket entries here ... what was wrong in May,
24 that's the problem.
25 THE COURT: The pretrial stipulation,
PALM BEACH REPORTING SERVICE, INC.
EFTA00801322
49
1 just for record, the case
https://www.justice.gov/epstein/files/DataSet%209/EFTA00801275.pdf
EFTA00804571Set 9
125p25,245w
which is in -- is on page 3 under
23 paragraph G, is that the pretrial stipulation
24 allows the parties to supplement.
25 And here, what happened ... language that allows
17 the parties to supplement their exhibit list.
18 The pretrial stipulation that Mr. Scarola and I
19 negotiated --
20 May I approach again, Your Honor ... COURT: Okay.
4 MR. LINK: There's a material change to
5 the unilateral pretrial stipulation. The
6 parties agree --
7 THE COURT: Hold on just a moment
https://www.justice.gov/epstein/files/DataSet%209/EFTA00804571.pdf
EFTA00728666Set 9
2010-09-275p2,007w
stipulate, in writing, to as many facts and issues as possible;
3. prepare a Pretrial Stipulation in accordance with Paragraph E; and
4. list all objections to trial exhibits ... Pretrial Stipulation Must be Filed. It shall be the duty of Plaintiff's counsel to see that the
Pretrial Stipulation is drawn, executed by counsel, and filed with the Clerk ... Crainr.P1 for the
parties are charged with good faith cooperation in this regard. The Pretrial Stipulation shall contain the
following separately numbered paragraphs:
1. a list of all pending motions
https://www.justice.gov/epstein/files/DataSet%209/EFTA00728666.pdf
EFTA00728661Set 9
2010-12-035p2,005w
stipulate, in writing, to as many facts and issues as possible;
3. prepare a Pretrial Stipulation in accordance with Paragraph E; and
4. list all objections to trial exhibits ... Pretrial Stipulation Mast be Filed. It shall be the duty of Plaintiff's counsel to see that the
Pretrial Stipulation is drawn, executed by counsel, and filed with the Clerk ... Counsel for the
parties are charged with good faith cooperation in this regard. The Pretrial Stipulation shall contain the
following separately numbered paragraphs:
1. a list of all pending motions
https://www.justice.gov/epstein/files/DataSet%209/EFTA00728661.pdf
EFTA00793693Set 9
2018-03-0824p4,964w
available information about
3 All background information is derived from the complaints and Joint Pretrial
Stipulation, included in the Appendix.
3
EFTA00793695
the Rothstein firm and the Ponzi scheme ... Importantly, on December 22, 2017, the parties entered into a Joint Pretrial
Stipulation, listing the Stipulated Facts and Statement of Issues of Fact for
Determination at Trial. (App. 13). Pursuant ... This ruling
was in clear contradiction to the parties' agreement in the signed pretrial
stipulation that the cases would be tried together.
Epstein immediately filed an Emergency Petition for Writ
https://www.justice.gov/epstein/files/DataSet%209/EFTA00793693.pdf
EFTA00793881Set 9
34p23,564w
approach, is
26 the last seven to eight years. 26 laid out in our pretrial stipulation.
27 HR. LINK: Judge, we disagree with 37 And the case law is really ... think it's that simple, I 24 lawyers enter into a pretrial stipulation,
29 really don't. I think we're confusing two 29 Your Honor should follow ... look at the
6 because this case is all about whether we a pretrial stipulation itself, among the --
9 can demoaaaaato that Chore is a connection 9 just so everybody
https://www.justice.gov/epstein/files/DataSet%209/EFTA00793881.pdf
EFTA00583839Set 9
8p1,395w
Plaintiff,
v.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually,
and L.M., individually,
Defendants,
JOINT PRETRIAL STIPULATION
Pursuant to this Court's Order Setting Jury Trial and Directing Pretrial and Mediation ... Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein") and Defendant/Counter-
Plaintiff Bradley Edwards ("Edwards') hereby submit this Joint Pretrial Stipulation.
1. List of All Pending Motions:
a. Edwards' Motion to Determine Entitlement to Adverse ... Edwards for the
claims brought by him;
EFTA00583839
Edwards adv. Epstein
Case No. 502009CA040800XXXXMBAG
Pretrial Stipulation
Page 2
2. Whether Epstein maliciously set in motion a chain of events that
https://www.justice.gov/epstein/files/DataSet%209/EFTA00583839.pdf
Plaintiff,
v.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually,
and L.M., individually,
Defendants,
JOINT PRETRIAL STIPULATION
Pursuant to this Court's Order Setting Jury Trial and Directing Pretrial and Mediation ... Defendant Jeffrey Epstein ("Epstein") and Defendant/Counter-
Plaintiff Bradley Edwards ("Edwards') hereby submit this Joint Pretrial Stipulation.
1. List of All Pending Motions:
a. Edwards' Motion to Determine Entitlement to Adverse ... Edwards' Motion to Compel Answers to Interrogatories
EFTA01115102
Edwards adv. Epstein
Case No. 502009CA040800XXXXMBAG
Pretrial Stipulation
Page 2
2. Stipulated Facts: None.
3. Statement of Issues of Fact for Determination
https://www.justice.gov/epstein/files/DataSet%209/EFTA01115102.pdf
EFTA00808590Set 9
2017-12-0519p5,443w
Court entered its Order
on Motion to Reconfirm Existing Pretrial Deadlines and Re Pretrial Stipulation'', in which this
Court rejected Epstein's request to push the pretrial deadlines given ... catch-all" exhibit
category.
On December 22, 2017, Epstein and Edwards filed their Joint Pretrial Stipulation, in which
the parties reserved their "right to amend their Exhibit Lists." Obviously ... amendment
should have been permitted where the pretrial stipulation at issue agreed that the parties could
7
EFTA00808596
Edwards adv. Epstein
Case No. 502009CA040800XXXXMBAG
Response in Opposition to Epstein
https://www.justice.gov/epstein/files/DataSet%209/EFTA00808590.pdf
EFTA00793730Set 9
2018-03-0819p4,457w
December 22, 2017, the parties entered into a Joint Pretrial Stipulation,
listing the Stipulated Facts and Statement of Issues of Fact for Determination at
Trial. (App. 13). Pursuant ... Edwards stipulated to one trial of the claim and counterclaim in the
parties' Joint Pretrial Stipulation. Pursuant to the Stipulation—which was ordered
by the court and signed by counsel ... Case Against Rothstein". Second, is Edwards' Malicious Prosecution
Counterclaim. (App. 13 at C. 1.).
"Pretrial stipulations prescribing the issues on which a case is to be tried are
binding upon
https://www.justice.gov/epstein/files/DataSet%209/EFTA00793730.pdf
EFTA00793767Set 9
2018-03-0820p4,904w
December 22, 2017, the parties entered into a Joint Pretrial Stipulation,
listing the Stipulated Facts and Statement of Issues of Fact for Determination at
Trial. (App. 13). Pursuant ... trial of the claim and counterclaim in the
15
EFTA00793781
parties' Joint Pretrial Stipulation. Pursuant to the Stipulation—which was ordered
by the court and signed by counsel for both ... Case Against Rothstein". Second, is Edwards' Malicious Prosecution
Counterclaim. (App. 13 at C. 1.).
"Pretrial stipulations prescribing the issues on which a case is to be tried are
binding upon
https://www.justice.gov/epstein/files/DataSet%209/EFTA00793767.pdf
EFTA00807353Set 9
2018-03-1318p4,286w
Complaint
2 L.M. was dismissed from this case on August 9, 2010. (See Joint Pretrial Stipulation
(App. 12) at p. 8, 11143 & 44).
3
EFTA00807355
(Florida Civil Remedies for Criminal ... December 22, 2017, the parties entered into a Joint Pretrial Stipulation,
listing the Stipulated Facts and Statement of Issues of Fact for Determination at
Trial. (App. 12). Pursuant
https://www.justice.gov/epstein/files/DataSet%209/EFTA00807353.pdf