EFTA00806757Set 9
2018-11-2656p13,446w
EPSTEIN,
Plaintiff,
v.
SCOTT ROTHSTEIN, individually,
BRADLEY J. EDWARDS, individually,
and L.M., individually,
Defendants,
DEFENDANT/COUNTER-PLAINTIFF'S SECOND AMENDED PROPOSED JURY
INSTRUCTIONS AND VERDICT FORM
Defendant/Counter-Plaintiff, BRADLEY J. EDWARDS ... Documentary, Photographic or Physical
Evidnece is Admitted
EFTA00806757
EDWARDS ADV. EPSTEIN
Case No.: 502009CA040800XXXXMBAG
Defendant/Counter-Plaintiff's Second Amended Proposed Jury Instructions and Verdict Form
Page ... Verdict Form Bradley Edwards' Verdict Form
EFTA00806758
EDWARDS ADV. EPSTEIN
Case No.: 502009CA040800XXXXMBAG
Defendant/Counter-Plaintiff's Second Amended Proposed Jury Instructions and Verdict Form
Page 3 of 56
I HEREBY CERTIFY
https://www.justice.gov/epstein/files/DataSet%209/EFTA00806757.pdf
EFTA01069263Set 9
15p2,751w
SETTLEMENT PURSUANT TO
RULE 1.442, FLORIDA RULES OF CIVIL PROCEDURE
AND 4768.79, FLORIDA STATUTES
Defendant/Counter-Plaintiff, Bradley J. Edwards, by and through his undersigned
counsel, states that at least ninety ... docket on which this case is set for trial, whichever is earlier.
THEREFORE, Defendant/Counter-Plaintiff hereby serves this proposal for settlement
pursuant to Florida Rule of Civil Procedure ... Proposal is void.
7. ACCEPTANCE AND REJECTION: This Proposal shall be deemed by the
Defendant/Counter-Plaintiff to be rejected unless accepted by delivery of a written notice of
acceptance within thirty
https://www.justice.gov/epstein/files/DataSet%209/EFTA01069263.pdf
EFTA00620018Set 9
2011-08-2520p3,955w
BRADLEY J. EDWARDS, individually,
Defendants.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S PROPOSAL
FOR SETTLEMENT TO DEFENDANT/COUNTER-PLAINTIFF
BRADLEY J. EI)WARDS, INDIVIDUALLY
Plaintiff/Counter-Defendant, JEFFREY EPSTEIN, by and through undersigned counsel,
hereby serves this ... Proposal for Settlement upon Defendant/Counter-Plaintiff, BRADLEY J.
EDWARDS, individually, pursuant to §768.79, Fla. Stat. and Fla. R. Civ. P. 1.442:
1. This Proposal is being made pursuant ... behalf of Plaintiff/Counter-Defendant, JEFFREY
EPS1'EIN.
3. This Proposal is being made to Defendant/Counter-Plaintiff, BRADLEY J.
EDWARDS, individually.
4, This Proposal is directed to, and is intended to resolve
https://www.justice.gov/epstein/files/DataSet%209/EFTA00620018.pdf
EFTA00804096Set 9
8p1,416w
BRADLEY J. EDWARDS, individually,
Defendants.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S PROPOSAL
FOR SETTLEMENT TO DEFENDANT/COUNTER-PLAINTIFF
BRADLEY J. EDWARDS, INDIVIDUALLY
Plaintiff/Counter-Defendant, JEFFREY EPSTEIN, by and through undersigned counsel,
hereby serves this Proposal ... Settlement upon Defendant/Counter-Plaintiff, BRADLEY J.
EDWARDS, individually, pursuant to §768.79, Fla. Stat. and Fla. R. Civ, P. 1.442:
1. This Proposal is being made pursuant to §768.79, Fla. Stat ... made on behalf of Plaintiff/Counter-Defendant, JEFFREY
EPSTEIN.
3. This Proposal is being made to Defendant/Counter-Plaintiff, BRADLEY J.
EDWARDS, individually.
4. This Proposal is directed to, and is intended to resolve
https://www.justice.gov/epstein/files/DataSet%209/EFTA00804096.pdf
EFTA00599847Set 9
8p1,416w
BRADLEY J. EDWARDS, individually,
Defendants.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S PROPOSAL
FOR SETTLEMENT TO DEFENDANT/COUNTER-PLAINTIFF
BRADLEY J. EDWARDS, INDIVIDUALLY
Plaintiff/Counter-Defendant, JEFFREY EPSTEIN, by and through undersigned counsel,
hereby serves this Proposal ... Settlement upon Defendant/Counter-Plaintiff, BRADLEY J.
EDWARDS, individually, pursuant to §768.79, Fla. Stat. and Fla. R. Civ, P. 1.442:
1. This Proposal is being made pursuant to §768.79, Fla. Stat ... made on behalf of Plaintiff/Counter-Defendant, JEFFREY
EPSTEIN.
3. This Proposal is being made to Defendant/Counter-Plaintiff, BRADLEY J.
EDWARDS, individually.
4. This Proposal is directed to, and is intended to resolve
https://www.justice.gov/epstein/files/DataSet%209/EFTA00599847.pdf
EFTA00805510Set 9
2011-08-2520p3,930w
JEFFREY EPSTEIN, by and through undersigned counsel,
hereby serves this Proposal for Settlement upon Defendant/Counter-Plaintiff, BRADLEY J.
EDWARDS, individually, pursuant to §768.79, Fla. Stat ... made on behalf of Plaintiff/Counter-Defendant, JEFFREY
EPSTEIN.
3. This Proposal is being made to Defendant/Counter-Plaintiff, BRADLEY J.
EDWARDS, individually.
4, This Proposal is directed to, and is intended to resolve ... instant action (Case No. 502009CA040800)OOOCMB-AO) by
Plaintiff/Counter-Defendant, JEFFREY EPSTEIN, against Defendant/Counter-Plaintiff,
BRADLEY J. EDWARDS, individually, and all claims pled or which could have been pled by
Defendant/Counter-Plaintiff, BRADLEY
https://www.justice.gov/epstein/files/DataSet%209/EFTA00805510.pdf
EFTA00613867Set 9
8p1,397w
BRADLEY J. EDWARDS, individually,
Defendants.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S PROPOSAL
FOR SETTLEMENT TO DEFENDANT/COUNTER-PLAINTIFF
BRADLEY J. EDWARDS, INDIVIDUALLY
Plaintiff/Counter-Defendant, JEFFREY EPSTEIN, by and through undersigned counsel,
hereby serves this Proposal ... Settlement upon Defendant/Counter-Plaintiff, BRADLEY J.
EDWARDS, individually, pursuant to §768.79, Fla. Stat. and Fla. R. Civ. P. 1.442:
1. This Proposal is being made pursuant to §768.79, Fla. Stat ... made on behalf of Plaintiff/Counter-Defendant, JEFFREY
EPSTEIN.
3. This Proposal is being made to Defendant/Counter-Plaintiff, BRADLEY J.
EDWARDS, individually.
4. This Proposal is directed to, and is intended to resolve
https://www.justice.gov/epstein/files/DataSet%209/EFTA00613867.pdf
EFTA00617978Set 9
2015-02-0326p5,268w
BRADLEY J. EDWARDS, individually,
Defendants.
pLAINTIEF/COUNTER-DErENDANT iggritny EPSTEIN'S PROPOSAL
FOR SETTLEMENT TO DEFENDANT/COUNTER-PLAINTIFF
BRADLEY J. EDWARDS. INDIVIDUALLY
Plaintiff/Counter-Defendant, JEFFREY EPSTEIN, by and through undersigned counsel,
hereby serves this Proposal ... Settlement upon Defendant/Counter-Plaintiff, BRADLEY J.
EDWARDS, individually, pursuant to §768.79, Fla. Suit. and Fla. R. Civ. P. 1.442:
1. This Proposal is being made pursuant to §768.79, Fla. Stat ... made on behalf of Plaintiff/Counter-Defendant, JEFFREY
EPSTEIN.
3. This Proposal is being made to Defendant/Counter-Plaintiff, BRADLEY J.
EDWARDS, individually.
4. This Proposal is directed to, and is intended to resolve
https://www.justice.gov/epstein/files/DataSet%209/EFTA00617978.pdf
EFTA01196659Set 9
2015-02-0326p5,229w
BRADLEY J. EDWARDS, individually,
Defendants.
pLAINTIEF/COUNTER-DErENDANT iggritny EPSTEIN'S PROPOSAL
FOR SETTLEMENT TO DEFENDANT/COUNTER-PLAINTIFF
BRADLEY J. EDWARDS. INDIVIDUALLY
Plaintiff/Counter-Defendant, JEFFREY EPSTEIN, by and through undersigned counsel,
hereby serves this Proposal ... Settlement upon Defendant/Counter-Plaintiff, BRADLEY J.
EDWARDS, individually, pursuant to §768.79, Fla. Suit. and Fla. R. Civ. P. 1.442:
1. This Proposal is being made pursuant to §768.79, Fla. Stat ... made on behalf of Plaintiff/Counter-Defendant, JEFFREY
EPSTEIN.
3. This Proposal is being made to Defendant/Counter-Plaintiff, BRADLEY J.
EDWARDS, individually.
4. This Proposal is directed to, and is intended to resolve
https://www.justice.gov/epstein/files/DataSet%209/EFTA01196659.pdf
EFTA00799436Set 9
10p1,767w
BRADLEY J. EDWARDS, individually,
Defendants/Counter-Plaintiff.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S PROPOSAL
FOR SETTLEMENT TO DEFENDANT/COUNTER-PLAINTIFF
BRADLEY J. EDWARDS, INDIVIDUALLY
Plaintiff/Counter-Defendant, Jeffrey Epstein, hereby proposes to settle the above-styled
case ... Litigation") with Defendant/Counter-Plaintiff, Bradley J. Edwards, individually.
I. This Proposal is made pursuant to section 768.79, Florida Statutes and Florida Rule
of Civil Procedure 1.442.
2. Proposal for Settlement ... Beach. FL 33409 444 West Railroad Avenue
West Palm Beach FL 33401
Co-Counselfor Defendant/Counter-Plaintiff Co-Counselfor Defendant/Counter-Plaintiff
Bradley J. Edwards Bradley J. Edwards
Bradley J. Edwards Jack A. Goldberger
https://www.justice.gov/epstein/files/DataSet%209/EFTA00799436.pdf
EFTA00807707Set 9
10p1,744w
BRADLEY J. EDWARDS, individually,
Defendants/Counter-Plaintiff.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S PROPOSAL
FOR SETTLEMENT TO DEFENDANT/COUNTER-PLAINTIFF
BRADLEY J. EDWARDS, INDIVIDUALLY
Plaintiff/Counter-Defendant, Jeffrey Epstein, hereby proposes to settle the above-styled
case ... Litigation") with Defendant/Counter-Plaintiff, Bradley J. Edwards, individually.
I. This Proposal is made pursuant to section 768.79, Florida Statutes and Florida Rule
of Civil Procedure 1.442.
2. Proposal for Settlement ... Beach. FL 33409 444 West Railroad Avenue
West Palm Beach FL 33401
Co-Counselfor Defendant/Counter-Plaintiff Co-Counselfor Defendant!Counter-Plaintif
Bradley J. Edwards Bradley J. Edwards
Bradley J. Edwards Jack
https://www.justice.gov/epstein/files/DataSet%209/EFTA00807707.pdf
EFTA00807717Set 9
10p1,662w
BRADLEY J. EDWARDS, individually,
Defendants/Counter-Plaintiff.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S PROPOSAL
FOR SETTLEMENT TO DEFENDANT/COUNTER-PLAINTIFF
BRADLEY J. EDWARDS, INDIVIDUALLY
Plaintiff/Counter-Defendant, Jeffrey Epstein, hereby proposes to settle the above-styled
case ... Litigation") with Defendant/Counter-Plaintiff, Bradley J. Edwards, individually.
I. This Proposal is made pursuant to section 768.79, Florida Statutes and Florida Rule
of Civil Procedure 1.442.
2. Proposal for Settlement ... Beach. FL 33409 444 West Railroad Avenue
West Palm Beach FL 33401
Co-Counselfor Defendant/Counter-Plaintiff Co-Counselfor DefendantlCounter-Plaintiff
Bradley J. Edwards Bradley J. Edwards
Bradley J. Edwards Jack
https://www.justice.gov/epstein/files/DataSet%209/EFTA00807717.pdf
EFTA01075090Set 9
2011-09-0812p4,946w
future strategy and impact on case
07/29/1 1 Receipt and review of Order on Defendant/Counter-Plaintiff, Bradley J. Edwards' CEK 0.25
Motion to Dismiss Plaintiff, Jeffrey Epstein's Amended Complaint
07/29/1 ... Receipt and review of Order on Defendant/Counter-Plaintiff, Bradley J. Edwards' CEK 0.25
Motion for Leave to Assert Claim for Punitive Damages
07/29/1 I Receipt and review of Order on Plaintiff/Counter-Defendant ... procedural requirements for proposals MJS 0.50
for settlement
08/22/11 Draft Proposal for Settlement to Defendant/Counter-Plaintiff MJS 0.75
08/22/11 Draft proposed General Release to attach to Proposal for Settlement
https://www.justice.gov/epstein/files/DataSet%209/EFTA01075090.pdf
EFTA01118553Set 9
2011-09-0812p5,066w
future strategy and impact on case
07/29/11 Receipt and review of Order on Defendant/Counter-Plaintiff, Bradley J. Edwards' CEK 0.25
Motion to Dismiss Plaintiff, Jeffrey Epstein's Amended Complaint
07/29/11 Receipt ... review of Order on Defendant/Counter-Plaintiff, Bradley J. Edwards' CEK 0.25 ±
Motion for Leave to Assert Claim for Punitive Damages
07/29/11 Receipt and review of Order on Plaintiff/Counter-Defendant, Jeffrey Epstein ... procedural requirements for proposals MJS 0.50 —
for settlement
08/22/11 Draft Proposal for Settlement to Defendant/Counter-Plaintiff MJS 0.75
08/22/11 Draft proposed General Release to attach to Proposal for Settlement
https://www.justice.gov/epstein/files/DataSet%209/EFTA01118553.pdf
EFTA00805158Set 9
2018-01-0531p6,526w
amounts and for a finding that such are inadmissible evidence, and states:
INTRODUCTION
Defendant/Counter-Plaintiff Bradley J. Edwards ("Edwards") represented three plaintiffs
who brought tort claims seeking money damages against Epstein ... Epstein respectfully requests that this Court enter an Order in Limine precluding
11
EFTA00805168
Defendant/Counter-Plaintiff Bradley J. Edwards, his counsel, and his witnesses from making any
argument, statement, evidence ... Railroad Avenue
mep@searcylaw.com West Palm Beach, FL 33401
jsx@searcylaw.com njs@FLAppellateLaw.com
scarolateam@searcylaw.com kbt@FLAppellateLaw.com
Co-Counselfor Defendant/Counter-Plaintiff Co-Counselfor Defendant/Counter-Plaintiff
Bradley J. Edwards Bradley J. Edwards
Bradley J. Edwards Marc S. Nurik
https://www.justice.gov/epstein/files/DataSet%209/EFTA00805158.pdf
EFTA01200889Set 9
2014-12-0617p4,718w
Defendant/Counter-
Plaintiffs.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEMORANDUM
OF LAW REGARDING ETHICAL ISSUES RAISED BY
DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS REGARDING
ACCEPTANCE OF EPSTEIN'S PROPOSAL FOR SETTLEMENT
Plaintiff/Counter-Defendant Jeffrey Epstein (hereinafter "Epstein ... Court's request on December 6,
2014, hereby files this Memorandum of Law regarding Defendant/Counter-Plaintiff
Bradley Edwards's (hereinafter "Edwards") Opposition to Epstein's Motion for
Attorneys' Fees and Costs ... Civil Procedure, and governing case law. See
PlaintiffiCounter-Defendant Jeffrey Epstein's Reply to Defendant/Counter-Plaintiff
Bradley Edwards. 's Response in Opposition to Plaintiff/Counter-Defendant's Motionfor
Attorney's Fees and Costs
https://www.justice.gov/epstein/files/DataSet%209/EFTA01200889.pdf
EFTA01087947Set 9
2014-07-0215p2,225w
BRADLEY J. EDWARDS,
individually,
Defendants/Counter-Plaintiffs.
NOTICE OF APPEAL,
NOTICE IS HEREBY GIVEN that the Defendant/Counter-Plaintiff.
BRADLEY J. EDWARDS, appeals to the Fourth District Court of Appeal of
Florida, the final ... firm of BURLINGTON &
ROCKENBACH, P.A., files this Notice of Appearance on behalf of the
Defendant/Counter-Plaintiff, BRADLEY J. EDWARDS, solely as appellate
counsel in this cause, and directs all parties ... Motion to Dismiss dated April 20, 2011;
19. DE-308 Reply in Opposition to Defendant/Counter-Plaintiff's Motion to
Dismiss Amended Complaint dated May 13, 2011;
20. DE-346 Order Granting
https://www.justice.gov/epstein/files/DataSet%209/EFTA01087947.pdf
BRADLEY J. EDWARDS, individually,
Defendants.
PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S PROPOSAL
FOR SETTLEMENT TO DEFENDANT/COUNTER-PLAINTIFF
BRADLEY J. EDWARDS. INDIVIDUALLY
Plaintiff/Counter-Defendant, JEFFREY EPSTEIN, by and through undersigned counsel,
hereby serves this Proposal ... Settlement upon Defendant/Counter-Plaintiff, BRADLEY J.
EDWARDS, individually, pursuant to §768.79, Fla. Stat. and Fla. R. Civ. P. 1.442:
I. This Proposal is being made pursuant to §768.79, Fla. Stat ... made on behalf of Plaintiff/Counter-Defendant, JEFFREY
EPSTEIN.
3. This Proposal is being made to Defendant/Counter-Plaintiff, BRADLEY J.
EDWARDS, individually.
4. This Proposal is directed to, and is intended to resolve
https://www.justice.gov/epstein/files/DataSet%209/EFTA01114612.pdf