EFTA00611765.pdf

Electronically Filed 10/08/2013 08:28:06 PM ET IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, JUDGE: DAVID CROW VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, EPSTEIN'S OBJECTIONS TO EDWARDS'S DEPOSITION DESIGNATIONS Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Paragraph M of this Court's Order Setting Jury Trial and Directing Pretrial and Mediation Procedures, hereby objects to certain portions of the following of Defendant/Counter-Plaintiff Bradley Edwards's deposition designations, and to save space is listing only the portions to which he does not object, as nearly all of the questioning directed to Mr. Epstein was unrelated to this case. The grounds for the objections are discussed fully below. 1. March 17, 2010 deposition of Jeffrey Epstein Counsel does not object to the following, relevant portions of Epstein's first deposition: Page 13; Lines 11-21 Page 23; Lines 4-19 EFTA00611765 Page 23; Lines 4-19 Page 25; Lines 9-25 Page 26; Lines 6-15 Page 28; Lines 14-25 Page 30; Lines 6-18 Page 33; Lines 1-3 Page 34; Lines 7-22 Page 36; Lines10-25 Page 38; Lines 1-22 Page 48; Lines 13-25 Page 49; Lines 24-25 Page 50; Lines1-4 Page 50; Lines 8-25 Page 52; Lines10- Page 59; Lines 11 Page 63; Lines 4-25 Page 90; Lines 10-15 Page 116; Lines 8-15 Page 120; Lines 16-24 Page 126; Lines 1-5 2. January 25, 2012 deposition of Jeffrey Epstein Counsel does not object to the following, relevant portions of Epstein's second deposition: Page 17; Lines 12-15 Page 19-20; Lines 16-25 and Lines 1-22 Page 21; Lines 1-6 Epstein objects to the use of any testimony contained in each of the afore- referenced depositions that is not listed above, as it is neither relevant to, nor directly related to, Edwards's causes of action for Abuse of Process and Malicious Prosecution. The non-listed testimony and questioning from these depositions is salacious and replete with inflammatory and unnecessary lines of questioning related to criminal investigations or charges related to Epstein. Allowing the jury to hear this irrelevant portion of the depositions is improper, as it is being offered as "relevant solely to prove bad character" EFTA00611766 and would unduly inflame and prejudice the minds of the jury against Epstein. § 90.404(2) (a) FLA. STAT. (2013). Epstein further makes his objections to all of the non- listed Epstein deposition testimony on the following grounds: Relevance; Prejudice; Confusion; Misleading; Impermissible/Inadmissible Character Evidence; Impermissible/Inadmissible Evidence of other Crimes, Wrongs, or Acts; and Attorney- Client Privilege. See § 90.403 FLA. STAT. (2013); § 90.502 FLA. STAT. (2013); § 90.404(2) (a) FLA. STAT. (2013). By listing these grounds for objection, Epstein is not waiving his right to assert additional objections, or objections at trial. WE HEREBY CERTIFY that a true and correct copy of the foregoing was served, via electronic service, to all parties on the attached service list, this October 14, 2013. /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7ih Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 954.337.3716 (facsimile) Attorneys for Epstein EFTA00611767 SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Esq. Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldberger, Esq. Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. I East Broward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. Fanner Jaffe Weissing Edwards Fistos Lehrman 425 N Andrews Avenue Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, Esq. 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33301 Tonja Haddad Coleman, Esquire Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein EFTA00611768