EFTA00294244.pdf

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, SECOND AMENDED COUNTERCLAIM Bradley J. Edwards (EDWARDS) sues Jeffrey Epstein (EPSTEIN) and alleges: COUNT I-ABUSE OF PROCESS 1. This is an action for damages in an amount in excess of the minimum jurisdictional limits of this Court. 2. Counter/plaintiff, EDWARDS, is sui juris, resides in Broward County, Florida, and is an attorney licensed to practice in the State of Florida at all times material hereto. 3. Counter/defendant, EPSTEIN, is sui juris and is a resident of Palm Beach County, Florida. 4. EPSTEIN is a convicted felon having entered into a plea agreement pursuant to which he effectively conceded his having engaged in illicit sexual activity with a large number of female children over an extended period of time in violation of both State and Federal criminal laws. EFTA00294244 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Second Amended Counterclaim Page 2 of 13 5. EPSTEIN was sued civilly by a large number of his victims. Many of the cases against him have been settled, and upon information and belief, federal law enforcement agencies continue to investigate additional allegations of EPSTEIN'S serial abuse and molestation of children; others remain pending. As a consequence, EPSTEIN continues to face the potential of further criminal prosecution and huge civil judgments for both compensatory and punitive damages in favor of many victims of his depraved criminal exploitation of children including victims represented by EDWARDS. 6. In the face of overwhelming evidence of his guilt, EPSTEIN repeatedly asserted his Fifth Amendment Right against self-incrimination and refused to answer any substantive questions regarding his sexual exploitation of his minor victims. Lacking any substantive defense to the claims against him, EPSTEIN sought to avoid his compensatory and punitive liability and to deter cooperation in the ongoing criminal investigation by employing the extraordinary financial resources at his disposal to intimidate his victims and their legal counsel into abandoning their legitimate claims or resolving those claims for substantially less than their just value. 7. In some circumstances, EPSTEIN's tactics have proven successful, while other victims have thus far withstood this continued assault upon them and persisted in the prosecution of their claims. EDWARDS' clients are among those who continued the prosecution of their claims and the assertion of federal statutory rights afforded to them pursuant to the Federal Crime Victims' Rights Act (CVRA). EFTA00294245 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Second Amended Counterclaim Page 3 of 13 8. While prosecuting the legitimate claims on behalf of his clients, EDWARDS has not engaged in any unethical, illegal, or improper conduct nor has EDWARDS taken any action inconsistent with the duty he has to vigorously represent the interests of his clients. EPSTEIN has no reasonable basis to believe otherwise and has never had any reasonable basis to believe otherwise. 9. Nevertheless, EPSTEIN filed civil claims against EDWARDS and EDWARDS' client, L.M. for the sole purpose of further attempting to intimidate EDWARDS, L.M., and others into abandoning or settling their legitimate claims for less than their just and reasonable value. His sole purpose in both filing and prosecuting claims against EDWARDS was never the stated purpose of collecting money damages from EDWARDS since EPSTEIN knew that he had never suffered any damage as a consequence of any wrongdoing by EDWARDS. Nevertheless, EPSTEIN filed knowingly baseless and unsupportable claims against EDWARDS and proceeded to prosecute those baseless and unsupportable claims in order to divert EDWARDS from the prosecution of EDWARDS' legitimate claims against EPSTEIN, to require EDWARDS to expend time, energy and resources on his own defense, to embarrass EDWARDS and impugn his integrity, and deter others with legitimate claims against EPSTEIN from pursuing those claims at the risk of having to fend off similar assaults. EPSTEIN's real purpose was to put pressure on EDWARD$, L.M., and other victims by publishing what amounts to nothing more than a highly defamatory press release issued under the cloak of protection of the litigation privilege. 10. EPSTEIN acted purely out of malice toward EDWARDS and others, and he had ulterior motives and purposes in filing his unsupported and unsupportable claims. EPSTEIN'S EFTA00294246 Edwards adv. Epstein Case No.: 502009CA040800XXXXIABAG Second Amended Counterclaim Page 4 of 13 primary purpose in both filing and continuing to prosecute each of the claims against EDWARDS was to inflict a maximum economic burden on EDWARDS in having to defend against the spurious claims, to distract EDWARDS from the prosecution of claims against EPSTEIN arising out of EPSTEIN'S serial abuse of minors, and ultimately to extort EDWARDS into abandoning the claims he was prosecuting against EDWARDS. The claims filed by EPSTEIN against EDWARDS included the following: a. violation of F.S. §§772.101, et. seq.— Florida Civil Remedies for Criminal Practices Act; b. Florida RICO—"Racketeer Influenced and Corrupt Organization Act" pursuant to F.S. §§895.01, et. seq.; c. abuse of process; d. fraud; e. conspiracy to commit fraud. 12. EPSTEIN, in his Complaint, directly alleged that EDWARDS was a knowing participant in a civil theft and criminal enterprise when EPSTEIN was well aware that there was and is absolutely no evidence whatsoever to support such false assertions. Indeed, his Complaint was replete with speculation, conjecture, and innuendo and was entirely devoid of factual support for his spurious allegations. Indicative of his total disregard for the lack of any predicate for his claims, EPSTEIN ignored the statutory requirement for written notice prior to the initiation of a civil theft claim. EFTA00294247 Edwards adv. Epstein Case No.: 502009CA040800XXXXMIIAG Second Amended Counterclaim Page 5 of 13 13. EPSTEIN knew at the time of the filing of the specified claims and throughout his failed prosecution of those claims that he could not prosecute the claims to a successful conclusion because: a. they were both false and unsupported by any reasonable belief or suspicion that they were true; b. he had suffered no legally cognizable injury proximately caused by the falsely alleged wrongdoing on the part of EDWARDS; c. he had no intention of waiving his Fifth Amendment privilege against self- incrimination in order to provide the relevant and material discovery that would be necessary in the course of prosecuting the claims, (even if they had any reasonable basis), and he knew that his prosecution would consequently be barred by the sword-shield doctrine; d. EDWARDS' conduct in the prosecution of claims against EPSTEIN could not support the prosecution of a separate civil lawsuit against EDWARDS because of the absolute protection of the litigation privilege. 14. EPSTEIN acted purely out of malice toward EDWARDS and others, and he had ulterior motives and purposes in filing his unsupported and unsupportable claims as previously detailed in Paragraph 9. 15. EPSTEIN'S filing and prosecution of claims against EDWARDS recklessly and purposely disregarded the lack of justification for each of the claims and EPSTEIN never had as EFTA00294248 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Second Amended Counterclaim Page 6 of 13 his primary purpose to establish what he did consider or reasonably could have considered to be meritorious claims. 16. Each and every pleading filed by and on behalf of EPSTEIN in his prosecution of every claim against EDWARDS, every motion, every request for production, every subpoena issued, and every deposition taken as detailed on the docket sheet attached as Exhibit A was intended with respect to EDWARDS solely and exclusively to advance EPSTEIN'S efforts at extortion as previously detailed, and constituted a perversion of process after its initial service. 17. As a result of EPSTEIN's wrongful conduct as alleged, EDWARDS has suffered and will continue to suffer damages including but not limited to injury to his reputation, interference in his professional relationships, the loss of the value of his time required to be diverted from his professional responsibilities, and the cost of defending against EPSTEIN's spurious and baseless claims. WHEREFORE, EDWARDS demands judgment against EPSTEIN for compensatory damages, costs, and such other and further relief as the Court may deem appropriate under the circumstances. Counter/plaintiff, EDWARDS, reserves the right to assert a claim for punitive damages upon satisfying the applicable statutory prerequisites. Counter/plaintiff, EDWARDS, further demands trial by jury. COUNT II—MALICIOUS PROSECUTION 18. This is an action for damages in an amount in excess of the minimum jurisdictional limits of this Court. EFTA00294249 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Second Amended Counterclaim Page 7 of 13 19. Counter/plaintiff, EDWARDS, is sui juris, resides in Broward County, Florida, and is an attorney licensed to practice in the State of Florida at all times material hereto. 20. Counter/defendant, EPSTEIN, is sui juris and is a resident of Palm Beach County, Florida. 21. EPSTEIN is a convicted felon having entered into a plea agreement pursuant to which he effectively conceded his having engaged in illicit sexual activity with a large number of female children over an extended period of time in violation of both Statc and Federal criminal laws. 22. EPSTEIN was sued civilly by a large number of his victims. Many of the cases against him have been settled, and upon information and belief, federal law enforcement agencies continue to investigate additional allegations of EPSTEIN'S serial abuse and molestation of children; others remain pending. As a consequence, EPSTEIN continues to face the potential of further criminal prosecution and huge civil judgments for both compensatory and punitive damages in favor of many victims of his depraved criminal exploitation of children including victims represented by EDWARDS. 23. In the face of overwhelming evidence of his guilt, EPSTEIN repeatedly asserted his Fifth Amendment Right against self-incrimination and refused to answer any substantive questions regarding his sexual exploitation of his minor victims. Lacking any substantive defense to the claims against him, EPSTEIN sought to avoid his compensatory and punitive liability and to deter cooperation in the ongoing criminal investigation by employing the extraordinary financial resources at his disposal to intimidate his victims and their legal counsel EFTA00294250 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Second Amended Counterclaim Page 8 of 13 into abandoning their legitimate claims or resolving those claims for substantially less than their just value. 24. While prosecuting the legitimate claims on behalf of his clients, EDWARDS has not engaged in any unethical, illegal, or improper conduct nor has EDWARDS taken any action inconsistent with the duty he has to vigorously represent the interests of his clients. EPSTEIN has no reasonable basis to believe otherwise and has never had any reasonable basis to believe otherwise. 25. Nevertheless, EPSTEIN filed civil claims against EDWARDS and EDWARDS' client, L.M. for the sole purpose of further attempting to intimidate EDWARDS, L.M., and others into abandoning or settling their legitimate claims for less than their just and reasonable value. His sole purpose in filing claims against EDWARDS was never the stated purpose of collecting money damages from EDWARDS since EPSTEIN knew that he had never suffered any damage as a consequence of any wrongdoing by EDWARDS. Nevertheless, EPSTEIN filed knowingly baseless and unsupportable claims against EDWARDS and proceeded to prosecute those baseless and unsupportable claims in order to divert EDWARDS from the prosecution of EDWARDS' legitimate claims against EPSTEIN, to require EDWARDS to expend time, energy and resources on his own defense, to embarrass EDWARDS and impugn his integrity, and deter others with legitimate claims against EPSTEIN from pursuing those claims at the risk of having to fend off similar assaults. EPSTEIN's real purpose was to put pressure on EDWARDS, L.M., and other victims by publishing what amounts to nothing more than a highly defamatory press release issued under the cloak of protection of the litigation privilege. EFTA00294251 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Second Amended Counterclaim Page 9 of 13 26. EPSTEIN acted purely out of malice toward EDWARDS and others, and he had ulterior motives and purposes in filing his unsupported and unsupportable claims. EPSTEIN'S primary purpose in filing each of the claims against EDWARDS was to inflict a maximum economic burden on EDWARDS in having to defend against the spurious claims, to distract EDWARDS from the prosecution of claims against EPSTEIN arising out of EPSTEIN'S serial abuse of minors, and ultimately to extort EDWARDS into abandoning the claims he was prosecuting against EDWARDS. 27. The claims filed by EPSTEIN against EDWARDS were the following: a. violation of F.S. §§772.10I, et. seq.— Florida Civil Remedies for Criminal Practices Act; b. Florida RICO—"Racketeer Influenced and Corrupt Organization Act" pursuant to F.S. §§895.01, et. seq.; c. abuse of process; d. fraud; e. conspiracy to commit fraud. 28. EPSTEIN, in his Complaint, directly alleged that EDWARDS was a knowing participant in a civil theft and criminal enterprise and that he had conspired to and did engage in a fraud against EPSTEIN when EPSTEIN was well aware that there was and is absolutely no evidence whatsoever to support such false assertions. Indeed, his Complaint was replete with speculation, conjecture, and innuendo and was entirely devoid of factual support for his spurious allegations. Indicative of his total disregard for the lack of any predicate for his claims, EFTA00294252 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Second Amended Counterclaim Page 10 of 13 EPSTEIN ignored the statutory requirement for written notice prior to the initiation of a civil theft claim. 29. EPSTEIN knew at the time of the filing of the specified claims and throughout his failed prosecution of those claims that he could not prosecute the claims to a successful conclusion because: a. they were both false and unsupported by any reasonable belief or suspicion that they were true; b. he had suffered no legally cognizable injury proximately caused by the falsely alleged wrongdoing on the part of EDWARDS; c. he had no intention of waiving his Fifth Amendment privilege against self- incrimination in order to provide the relevant and material discovery that would be necessary in the course of prosecuting the claims, (even if they had any reasonable basis), and he knew that his prosecution would consequently be barred by the sword-shield doctrine; d. EDWARDS' conduct in the prosecution of claims against EPSTEIN could not support the prosecution of a separate civil lawsuit against EDWARDS because of the absolute protection of the litigation privilege. 30. EPSTEIN acted purely out of malice toward EDWARDS and others, and he had ulterior motives and purposes in filing his unsupported and unsupportable claims as previously detailed in Paragraph 25. EFTA00294253 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Second Amended Counterclaim Page I I of 13 31. EPSTEIN'S filing and prosecution of claims against EDWARDS recklessly and purposely disregarded the lack of justification for each of the claims and EPSTEIN never had as his primary purpose to establish what he did consider or reasonably could have considered to be meritorious claims. 32. After unsuccessful efforts to defend and amend his maliciously filed and prosecuted claims over a period of almost two years, EPSTEIN abandoned each of the claims described in Paragraph 27 except for an ongoing effort to salvage his abuse of process claim. That abandonment brings to successful conclusion EDWARDS' defense against each of the other abandoned claims and constitutes a specific bona fide termination in EDWARDS' favor of the prior prosecution of each abandoned claim. 33. As a result of EPSTEIN's wrongful conduct as alleged, EDWARDS has suffered and will continue to suffer damages including but not limited to injury to his reputation, interference in his professional relationships, the loss of the value of his time required to be diverted from his professional responsibilities, and the cost of defending against EPSTEIN's spurious and baseless claims. WHEREFORE, EDWARDS demands judgment against EPSTEIN for compensatory damages, costs, and such other and further relief as the Court may deem appropriate under the circumstances. Counter/plaintiff, EDWARDS, reserves the right to assert a claim for punitive damages upon satisfying the applicable statutory prerequisites. Counter/plaintiff, EDWARDS, further demands trial by jury. EFTA00294254 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Second Amended Counterclaim Page 12 of 13 I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Fax and U.S. Mail to all counsel on the attached l t, this 4.7 day of November, 2011. Jack arila Florida ar No.: 169440 S rc Denney Scarola Barnhart & Shipley, P.A. Palm Beach Lakes Boulevard .st Palm Beach, Florida 33409 hone: (561) 686-6300 Fax: (561) 383-9451 Attorneys for Bradley J. Edwards EFTA00294255 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Second Amended Counterclaim Page 13 of 13 COUNSEL LIST Jack A. Goldberger, Esquire Atterbury, Goldberger & Weiss, P.A. 250 Australian Avenue South, Suite 1400 West Palm Beach, FL 33401 Phone: (561) 659-8300 Fax: (561) 835-8691 Fanner, Jaffe, Weissing, Edwards, Fistos & Lehrman, PL 425 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Phone: (954) 524-2820 Fax: (954) 524-2822 Marc S. Nurik, Esquire Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phone: (954) 745-5849 Fax: (954) 745-3556 Joseph L. Ackerman, Jr., Esquire Fowler White Burnett, P.A. 901 Phillips Point West 777 S Flagler Drive West Palm Beach, FL 33401-6170 Phone: (561) 802-9044 Fax: (561) 802-9976 EFTA00294256 - Not an Official Document Page 1 of 67 Report Selection Criteria Case ID: Docket Start Date: Docket Ending Date: Case Description Case ID: Case Caption: Division: Filing Date: Court: Location: Jury: Type: Status: 502009CA040800XXXXMB 502009CA040800XXXXMB JEFFREY EPSTEIN V SCOTT ROTHSTEIN AG -CROW Monday , December 07th, 2009 CA - CIRCUIT CIVIL MB - MAIN BRANCH Y-Jury OC - OTHER CIRCUIT PE - PENDING Related Cases No related cases were found. Case Event Schedule No case events were found. Case Parties Seq Assoc Expn Date 11- JUN- 2010 PLAINTIFF @2075728 EPSTEIN, JEFFREY ATTORNEY 0224162 CRITTON JR , ESQ, ROBERT DEWEESE DEFENDANT @2075729 ROTHSTEIN, SCOTT DEFENDANT (2075730 EDWARDS, BRADLEY J Aliases: Aliases: none Aliases: Aliases: EXHIBIT A liltp://councon.co.palm-bea( ket_report... 11/29/2011 EFTA00294257 - Not an Official Document Page 2 of 67 5 10- AUG- 2010 DEFENDANT JUDGE ATTORNEY ATTORNEY 9 1 ATTORNEY 10 ATTORNEY 11 Docket Entries ATTORNEY O)2075731 LM Aliases: none none AG CROW, JUDGE DAVID Aliases: 0169440 SCAROLA , ESQ, JACK Aliases: none none 0914444 FARMER, ESQ, GARY Aliases: 0195677 SANCHEZ, LILLY ANN Aliases: none 0235954 ACKERMAN , ESQ, JOSEPH L Aliases: none 0599298 [ADLER , ESQ, RUSSELL S Aliases: none Docket Docket Type Book and Page No. Attached To: 100000 - ADDITIONAL COMMENTS [Filing Date: 07-DEC-2009 Filing Party: Disposition Amount: Docket Text: none. 800FF - CAFF Filing Date: 07-DEC-2009 http://courtcon.co.palm-beach.fLus/p1s/jiwp/ck_public_qry_doct.cp_dktrpt_docket_report... 11/29/2011 EFTA00294258 - Not an Official Document Page 3 of 67 Filing Party: IIEPSTEIN, JEFFREY Disposition Amount: Docket Text: none. PE - PENDING Filing Date: 07-DEC-2009 Filing Party: Disposition Amount: Docket Text: none. RCPT - RECEIPT FOR PAYMENT Filing Date: 07-DEC-2009 Filing Party: EPSTEIN, JEFFREY Ii Disposition Amount: Docket Text: A Payment of -$30.00 was made on receipt CAMB363437. 1 CMP - COMPLAINT Filing Date: 07-DEC-2009 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: none. 2 CCS - CIVIL COVER SHEET Filing Date: 07-DEC-2009 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: none. 3 1SMIS - SUMMONS ISSUED Filing Date: 07-DEC-2009 Filing Party: L M, Disposition Amount: Docket Text: SM-09-232330 4 SMIS - SUMMONS ISSUED Filing Date: 07-DEC-2009 Filing Party: ROTHSTEIN, SCOTT Disposition Amount: Docket Text: SM-09-232331 http://councon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dktrpt_docket_report... 11/29/2011 EFTA00294259 - Not an Official Document Page 4 of 67 5 II SMIS - SUMMONS ISSUED Filing Date: 07-DEC-2009 Filing Party: IEDWARDS, BRADLEY J Disposition Amount: Docket Text: SM-09-232332 6 SMIS - SUMMONS ISSUED Filing Date: 07-DEC-2009 Filing Party: )ROTHSTEIN, SCOTT Disposition Amount: Docket Text: NOT USED SM-09-232389 7 SMIS - SUMMONS ISSUED Filing Date: 07-DEC-2009 Filing Party: IROTHSTEIN, SCOTT Disposition Amount: I Docket Text: SCOTT ROTHSTEIN SM-09-232390 RCPT - RECEIPT FOR PAYMENT (Filing Date: 08-DEC-2009 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: A Payment of -$401.00 was made on receipt CAMB363514. RCPT - RECEIPT FOR PAYMENT Filing Date: 08-DEC-2009 Filing Party: Disposition Amount: Docket Text: A Payment of -$10.00 was made on receipt CAMB363732. SRTN - (ATTACHED) SERVICE RETURN Filing Date: 11-DEC-2009 Filing Party: EDWARDS, BRADLEY J Disposition Amount: Docket Text: none. SRTN - (ATTACHED) SERVICE RETURN Filing Date: 11-DEC-2009 1 Intp://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dlctrpt_docket_report... 11/29/2011 EFTA00294260 - Not an Official Document Page 5 of 67 Filing Party: III- M, Disposition Amount: Docket Text: none. SRTN - (ATTACHED) SERVICE RETURN Filing Date: 14-DEC-2009 Filing Party: ROTHSTEIN, SCOTT Disposition Amount: Docket Text: SERVED RCPT - RECEIPT FOR PAYMENT Filing Date: 21-DEC-2009 Filing Party: Disposition Amount: Docket Text: A Payment of -$395.00 was made on receipt CAMB367609. 8 ANS - ANSWER Filing Date: 21-DEC-2009 Filing Party: EDWARDS, BRADLEY J J Disposition Amount: Docket Text: AND COUNTERCLAIM 9 TANS -ANSWER Filing Date: 21-DEC-2009 Filing Party: EDWARDS, BRADLEY J Disposition Amount: Docket Text: & COUNTERCLAIM . . . 10 I MSTR - MOTION TO STRIKE Filing Date: 28-DEC-2009 Filing Party: L M, Disposition Amount: Docket Text: Inone. 11 I ANAD - DEFENSES ANSWER & AFFIRMATIVE Filing Date: 28-DEC-2009 Filing Party: L M, Disposition Amount: http://courtcon.co.palm-heach.fl.usipls/jiwp/ck_public_qry_doct.cp_dktrpt_docket report... 11/29/2011 EFTA00294261 - Not an Official Document Page 6 of 67 Docket Text: Inone. 15 MDFT - MOTION FOR DEFAULT Filing Date: 31-DEC-2009 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: AGAINST DFT SCOTT ROTHSTEIN 12 MOT - MOTION Filing Date: 12-JAN-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: OFOR A MORE DEFINITE. 13 RADF - DEFENSES REPLY TO AFFIRMATIVE Filing Date: 12-JAN-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: none. 16 I NOH - NOTICE OF HEARING Filing Date: 14-JAN-2010 Filing Party: Disposition Amount: Docket Text: none. 17 I RNOH - RE-NOTICE OF HEARING Filing Date: 19-JAN-2010 Filing Party: Disposition Amount: Docket Text: none. 14 DFT-DEFAULT Filing Date: 21-JAN-2010 Filing Party: ROTHSTEIN, SCOTT Disposition Amount: Docket Text: none. 18 NCAN - NOTICE OF CANCELLATION Filing Date: [25-JAN-2010 http://courtcon.co.palm-beach.fl.us/p1s/jiwpick_public_qty_doct.cp_dktrpt docket_repon... II/29/2011 EFTA00294262 - Not an Official Documcnt Page 7 of 67 Filing Party: ICRITTON JR , ESQ, ROBERT DEWEESE Disposition Amount: Docket Text: OF HEARING 19 LORD - ORDER Filing Date: 26-JAN-2010 Filing Party: Disposition Amount: Docket Text: ON MOT OF COUNTER-DFT FOR AND MOT TO DISMISS, DENIED. MORE DEFINITE STATEMENT D CROW. 20 NOTD - DEPOSITION NOTICE OF TAKING Filing Date: 04-FEB-2010 Filing Party: 1 CRITTON JR , ESQ, ROBERT DEWEESE Disposition Amount: Docket Text: none. 21 NOTD - DEPOSITION NOTICE OF TAKING Filing Date: 08-FEB-2010 Filing Party: Disposition Amount: Docket Text: none. 22 IMOT- MOTION Filing Date: 17-FEB-2010 Filing Party: ROTHSTEIN, SCOTT Disposition Amount: Docket Text: TO SET ASIDE DEFAULT 23 MDIS - MOTION TO DISMISS Filing Date: 26-FEB-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: EDWARDS' COUNTERCLAIM 24 NOH - NOTICE OF HEARING Filing Date: 26-FEB-2010 Filin Party: EPSTEIN, JEFFREY Disposition Amount: http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_ciry_doct.cp_dIctrpt_docket_report... 11/29/2011 EFTA00294263 - Not an Official Document Page 8 of 67 Docket Text: 3-9-10 AT 8:45 AM 25 NOH - NOTICE OF HEARING Filing Date: 01-MAR-2010 Filing Party: SCAROLA , ESQ, JACK Disposition Amount: Docket Text: 3-2-10 AT 8:45 AM 32 MDFT - MOTION FOR DEFAULT Filing Date: 01-MAR-2010 Filing Party: EDWARDS, BRADLEY J Disposition Amount: Docket Text: AGAINST JEFFREY EPSTEIN 26 MSTR - MOTION TO STRIKE Filing Date: 02-MAR-2010 Filing Party: EDWARDS, BRADLEY J Disposition Amount: Docket Text: MOTION TO DISMISS AND IMPOSE SANCTIONS 27 RNOH - RE-NOTICE OF HEARING Filing Date: 02-MAR-2010 Filing Party: SCAROLA , ESQ, JACK Disposition Amount: Docket Text: none. 128 I NOH - NOTICE OF HEARING Filing Date: 02-MAR-2010 Filing Party: SCAROLA , ESQ, JACK Disposition Amount: Docket Text: _ none. 29 NOTD - NOTICE OF TAKING DEPOSITION Filing Date: 03-MAR-2010 'Filing Party: L M, Disposition Amount: Docket Text: CROSS 30 ORD - ORDER Filing Date: 04-MAR-2010 http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dlctrpt docket_report... 11/29/2011 EFTA00294264 - Not an Official Document Page 9 of 67 'Filing Party: II Disposition Amount: Docket Text: ON MOTION TO STRIKE, DISMISS SANCTIONS... SEE ORDER DCROW AND IMPOSE 31 ORD - ORDER Filing Date: 09-MAR-2010 Filing Party: Disposition Amount: Docket Text: ON MOTIO TO SET ASIDE DEFAULT:D CROW 33 MDFT - MOTION FOR DEFAULT Filing Date: 11-MAR-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: PLEADING WAS FILED (NO ENVELOPE PROVIDED)** 34 NOH - NOTICE OF HEARING Filing Date: 11-MAR-2010 Filing Party: JCRITTON JR , ESQ, ROBERT DEWEESE Disposition Amount: Docket Text: 4-30-10 AT 3:30 PM 35 ANS - ANSWER Filing Date: 16-MAR-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: TO COUNTERCLAIM 36 RADF - DEFENSES REPLY TO AFFIRMATIVE Filing Date: 16-MAR-2010 Filing Party: EDWARDS, BRADLEY J Disposition Amount: Docket Text: none. 37 REQP - REQUEST TO PRODUCE Filing Date: 18-MAR-2010 Filing Party: (EDWARDS, BRADLEY J Disposition Amount: http://courtcon.co.palm-beach.flus/p1s/jiwp/ckpublic_qry_doct.cp_dktrpt_docket_report... 11/29/2011 EFTA00294265 - Not an Official Document Page 10 of 67 Docket Text: Ilnone. 38 MOT - MOTION Filing Date: 29-MAR-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: FOR JUDGMENT OR ALTERNATIVE MOTION FOR SUMMARY JUDGMENT [39 NOJT - NOTICE OF JURY TRIAL Filing Date: 05-APR-2010 Filing Party: Disposition Amount: EDWARDS, BRADLEY J Docket Text: r UP 4/7/10** 40 NOTD - NOTICE OF TAKING DEPOSITION Filing Date: 05-APR-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: 'VIDEO OF SCOTT ROTHSTEIN ON 4-15-10 AT 10 AM 41 r NOS - NOTICE OF SERVICE Filing Date: Filing Party: Disposition Amount: Docket Text: JFIRST SET OF INTERROGATORIES 42 INOH - NOTICE OF HEARING Filing Date: 07-APR-2010 EPSTEIN, JEFFREY 07-APR-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: 5-11-10 AT 8:15 AM 43 NOTD - NOTICE OF TAKING DEPOSITION Filing Date: 07-APR-2010 Filing Party: CRITTON JR , ESQ, ROBERT DEWEESE Disposition Amount: Docket Text: VIDEO OF MICHAEL FISTEN & RICHARD FANDRY htip://courtcon.co.palm-beach.fl.us/pls/jiwp/ck_publicigy_doct.cp_dktrpt_docket report... 11/29/2011 EFTA00294266 - Not an Official Document Page 11 of 67 4 REQP - REQUEST TO PRODUCE Filing Date: Filing Party: Disposition Amount: Docket Text: 4 13-APR-2010 EPSTEIN, JEFFREY TO EDWARDS MOT - MOTION Filing Date: 13-APR-2010 Filing Party: Disposition Amount: EDWARDS, BRADLEY J Docket Text: 46 Filing Date: PURSUANT TO F.S. 57.105 NOH - NOTICE OF HEARING Filing Party: 115-APR-2010 FARMER, ESQ, GARY Disposition Amount: Docket Text: 14-19-10 AT 8:45 AM 47 I MFPO - MOTION FOR PROTECTIVE ORDER Filing Date: 15-APR-2010 Filing Party: L M, Disposition Amount: Docket Text: none. 48 I OSJT - ORDER SETTING JURY TRIAL Filing Date: 15-APR-2010 Filing Party: Disposition Amount: Docket Text: 49 Filing Date: 10-15-10 AT 9 AM. D CROW NOH - NOTICE OF HEARING Filing Party: 16-APR-2010 EPSTEIN, JEFFREY i Disposition Amount: Docket Text: 50 Filing Date: Filing Party: 4-22-10 AT 8:45 AM MSTR - MOTION TO STRIKE 16-APR-2010 EPSTEIN, JEFFREY imp://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dktrpt_docket_report... 11/29/2011 EFTA00294267 - Not an Official Document Page 12 of 67 Disposition Amount: i Docket Text: AFFIDAVIT OF SCOTT ROTHSTEIN 51 ORD - ORDER Filing Date: 19-APR-2010 Filing Party: Disposition Amount: Docket Text: ON MOTION FOR PROTECTIVE ORDER: GRANTED. D CROW 52 NOTD - DEPOSITION NOTICE OF TAKING Filing Date: 19-APR-2010 Filing Party: CRITTON JR , ESQ, ROBERT DEWEESE Disposition Amount: Docket Text: OF HERBERT STETTIN 5-19-10 AT 4 PM 53 MOT - MOTION Filing Date: 21-APR-2010 Filing Party: IEPSTEIN, JEFFREY Disposition Amount: Docket Text: FOR ENLARGEMENT OF TIME TO RESPOND TO REQUEST TO PRODUCE 54 MOT - MOTION Filing Date: 21-APR-2010 Filing Party: L M, Disposition Amount: Docket Text: PURSUANT TO F.S. 57.105 55 ORD - ORDER Filing Date: 22-APR-2010 Filing Party: Disposition Docket Text: Amount: ON MOTION TO STRIKE AFFIDAVIT OF SCOTT ROTHSTEIN: DENIED. D CROW 56 I NOH - NOTICE OF HEARING Filing Date: 23-APR-2010 Filing Party: CRITTON JR , ESQ, ROBERT DEWEESE Disposition Amount: Docket Text: 5-5-10 AT 8:45 AM http://courtcon.co.palm-beachfLus/p1s/jiwp/ck_public_qry_doctcp_dktrpt_docket_report... 11/29/2011 EFTA00294268 - Not an Official Document Page 13 of 67 57 NOH - NOTICE OF HEARING Filing Date: 26-APR-2010 Filing Party: CRITTON JR , ESQ, ROBERT DEWEESE Disposition Amount: Docket Text: 4-30-10 AT 3:30 PM 58 I NOAP - NOTICE OF APPEARANCE Filing Date: 27-APR-2010 Filing Party: Disposition Amount: Docket Text: CO COUNSEL OBO PLTF JEFFREY EPSTEIN FILED BY JACK A GOLDBERGER ESQ r59 I RQCP - REQUEST FOR COPIES Filing Date: 27-APR-2010 Filing Party: EDWARDS, BRADLEY J Disposition Amount: Docket Text: none. 60 RPRS - REPLY/RESPONSE Filing Date: 03-MAY-2010 Filing Party: EDWARDS, BRADLEY J Disposition Amount: Docket Text: & SUPPORTING LEGAL AUTHORITIES IN OPPOSITION. . . 61 MCMP - MOTION TO COMPEL Filing Date: 10-MAY-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: BRADLEYY EDWARDS TO APPEAR FOR FOLLOW UP DEPO 62 ORD - ORDER Filing Date: 11-MAY-2010 Filing Party: Disposition Amount: Docket Text: ON EPSTEIN MOTION FOR JUDGMENT ON THE PLEADINGS .. . DCROW 63 NOF - NOTICE OF FILING Filing Date: lit -MAY-2010 i http://courtcon.co.palm-beach.fl.us/pis/jiwp/ckpublic_qry_doct.cp_dkUpt docket_report... 11/29/2011 EFTA00294269 - Not an Official Document Page 14 of 67 Filing Party: 'EPSTEIN, JEFFREY Disposition Amount: Docket Text: CORRECTED EXHIBIT D AS CITED IN PLTF MOTION TO COMPEL. . 64 I NOH - NOTICE OF HEARING Filing Date: 11-MAY-2010 Filing Party: CRITTON JR , ESQ, ROBERT DEWEESE Disposition Amount: Docket Text: 5/20/10 8:45 AM EPSTEIN MOTION TO COMPEL BRADLEY EDWARDS TO APPEAR FOR FOLLOWUP DEPO 65 RESP - RESPONSE TO: Filing Date: 12-MAY-2010 Filing Party: EDWARDS, BRADLEY J Disposition Amount: Docket Text: REQ FOR PRODUCTION DTD 4/12/10 66 NOS - NOTICE OF SERVICE Filing Date: 12-MAY-2010 Filing Party: EDWARDS, BRADLEY J Disposition Amount: Docket Text: IOF DFT EDWARDS ANSWERS TO PLTF 1ST INTERRS 67 NOF - NOTICE OF FILING Filing Date: 14-MAY-2010 Filing Party: EDWARDS, BRADLEY J Disposition Amount: Docket Text: ORIG JURAT TO ANSWERS . . . . 68 NCAN - NOTICE OF CANCELLATION Filing Date: 20-MAY-2010 Filing Party: CRITTON JR , ESQ, ROBERT DEWEESE Disposition Amount: Docket Text: OF HEARING 69 MFPO - ORDER MOTION FOR PROTECTIVE Filing Date: 20-MAY-2010 Filing Party: Disposition Amount: http://courtcon.co.palm-beachnus/p1s/jiwpick_public_qry_doct.cp_dIctrpt docket report... 11/29/2011 EFTA00294270 - Not an Official Document Page 15 of 67 Docket Text: II(BANKRUPTCY TRUSTEE) 70 JAGOR - AGREED ORDER Filing Date: 21-MAY-2010 Filing Party: Disposition Amount: Docket Text: ON EPSTEINS MOTION FOR ENLARGEMENT RESPOND TO EDWARDS REQUEST OF TIME TO TO PRODUCE 71 MOT - MOTION Filing Date: I[25-MAY-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: ITO POSTPONE HEARING 72 NOH - NOTICE OF HEARING Filing Date: 25-MAY-2010 Filing Party: Disposition Amount: Docket Text: 01-JUN-10 73 RESP - RESPONSE TO: Filing Date: 27-MAY-2010 Filing Party: I EPSTEIN, JEFFREY Disposition Amount: Docket Text: IN OPPOSITION TO MOTION TO W/ATTACHMENTS SET ASIDE DEFAULT 74 RRTP - RESPONSE TO REQ TO PRODUCE Filing Date: 27-MAY-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: none. 75 ORD - ORDER Filing Date: 01-JUN-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: ON EPSTEINS MOTION TO POSTPONE GRANTED. D CROW THE 6/4/10 HEARING IS http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dlcUpt docket_report... 11/29/2011 EFTA00294271 - Not an Official Document Page 16 of 67 76 i REQP - REQUEST TO PRODUCE Filing Date: 03-JUN-2010 Filing Party: Disposition Amount: Docket Text: (SUPPLEMENTAL) OF DEFT EPSTEIN 77 CNS - CONSENT Filing Date: 11-JUN-2010 Filing Party: Disposition Amount: Docket Text: [none. 78 ORD - ORDER Filing Date: 11-JUN-2010 Filing Party: Disposition Amount: Docket Text: ON SUBSTITUTION OF COUNSEL DCROW 79 STIP - STIPULATION Filing Date: 11-JUN-2010 Filing Party: Disposition Amount: Docket Text: & SUBSTITUTION OF COUNSEL 80 MCMP - MOTION TO COMPEL Filing Date: 17-JUN-2010 Filing Party: EDWARDS, BRADLEY J Disposition Amount: Docket Text: COMPLETE RESONSE TO REQ TO PRODUCE IJ 81 NOH - NOTICE OF HEARING Filing Date: 17-JUN-2010 Filing Party: SCAROLA , ESQ, JACK Disposition Amount: Docket Text: 6/29/10 8:45 AM DFT EDWARDS MOTION TO COMPEL PLTF EPSTEIN TO RESPOND TO REQ ... 82 NOH - NOTICE OF HEARING Filing Date: 21-JUN-2010 Filing Party: h0p://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_publicAry_doct.cp_dIctrpt_docket_report... 11/29/2011 EFTA00294272 - Not an Official Document Page 17 of 67 'Disposition Amount: Docket Text: 6/28/10 8:45 AM MOTION TO COPEL PRODUCTION OF DOCS. . . 83 MCMP - MOTION TO COMPEL Filing Date: 21-JUN-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: PRODUCTION OF DOCS FROM BANKRUPTCY. . . 84 MFPO - ORDER MOTION FOR PROTECTIVE Filing Date: 22-JUN-2010 Filing Party: L M, Disposition Amount: Docket Text: none. 85 MFPO - ORDER MOTION FOR PROTECTIVE Filing Date: 25-JUN-2010 _ Filing Party: Disposition Amount: Docket Text: (BANKRUPTCY TRUSTEE SUPPLEMENTAL) 86 MOT - MOTION Filing Date: I25-JUN-2010 Filing Party: I Disposition Amount: Docket Text: !OF HERBERT STETTIN-FOR PROTECTIVE ORDER 87 NOH - NOTICE OF HEARING Filing Date: 125-JUN-2010 Filing Party: Disposition Amount: Docket Text: JUNE 28 2010 88 NOT - NOTICE Filing Date: 25-JUN-2010 Filing Party: Disposition Amount: Docket Text: JOINDER • http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp dictipt docket_report... 11/29/2011 EFTA00294273 - Not an Official Document Page 18 of 67 89 [XLT - EXHIBIT LIST Filing Date: 30-JUN-2010 Filing Party: JEPSTEIN, JEFFREY Disposition Amount: Docket Text: none. 90 I WLIS - WITNESS LIST Filing Date: 30-JUN-2010 Filing Party: EDWARDS, BRADLEY J Disposition Amount: Docket Text: none. 91 I NOH - NOTICE OF HEARING Filing Date: 01-JUL-2010 Filing Party: Disposition Amount: Docket Text: none. 92 NOH - NOTICE OF HEARING Filing Date: M.-JUL-2010 Filing Party: Disposition Amount: Docket Text: 8/10/10 8:45 AM PLTF MOTION TO COMPEL BRADLEY EDWARDS TO APPEAR. . . 93 I_RERQ - RESPONSE TO REQ FORT ADMISSION Filing Date: j 07-JUL-2010 Filing Party: — I EDWARDS, BRADLEY J Disposition Amount: Docket Text: (1ST) 94 NOH - NOTICE OF HEARING Filing Date: _....r 12-JUL-2010 Filing Party: Disposition Amount: Docket Text: 8/3/10 8:45 AM PLTF MOTION TO ENLARGE TIME TO SERVE WITNESS & EXHIBIT LIST . . . 95 NOS - NOTICE OF SERVICE I http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_ciry_doct.cp_dlctrpt_docket_report... 11/29/2011 EFTA00294274 - Not an Official Document Page 19 of 67 [Filing Date: II12-JUL-2010 Filing Party: [EPSTEIN, JEFFREY 1 Disposition Amount: Docket Text: ADMISSINOS TO BRADLEY EDWARDS 96 NOH - NOTICE OF HEARING Filing Date: 12-JUL-2010 Filing Party: Disposition Amount: Docket Text: none. 97 MOT - MOTION Filing Date: 12-JUL-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: TO ENLARGE TIME TO SERVE WITNESS & EXHIBIT LIST AND REQ FOR STATUS CONFERENCE 98 I MOT - MOTION [Filing Date: 19-JUL-2010 Filing Party: EDWARDS, BRADLEY J Disposition Amount: Docket Text: TO APPOINT COMMISSIONER 99 NOH - NOTICE OF HEARING Filing Date: 19-JUL-2010 Filing Party: Disposition Amount: Docket Text: 8/3/10 100 ORD - ORDER Filing Date: _ 03-AUG-2010 Filing Party: Disposition Amount: Docket Text: DEFENDANT'S MOTION TO APPOINT COMMISSIONER. (CC MLD TO ATTY) 101 ORD - ORDER Filing Date: 03-AUG-2010 Filing Party: http://courtcon.co.palm-beachil.us/p1s/jiwp/ck_publicAry_doctcp_dlctrpt docket_report... 11/29/2011 EFTA00294275 - Not an Official Document Page 20 of 67 [Disposition Amount: Docket Text: ON MOTION TO ENLARGE TIME: GRANTED. D CROW 103 STIP - STIPULATION Filing Date: 09-AUG-2010 Filing Party: FARMER , ESQ, GARY Disposition Amount: Docket Text: FOR ORDER OF DISMISSAL WITH PREJUDICE AS TO L.M.INDIVIDUALLY. ONLY 102 ODIS - ORDER OF DISMISSAL Book 024028 - Page 00263 Filing Date: 10-AUG-2010 Filing Party: Disposition Amount: Docket Text: FINAL D CROW 104 INCAN - NOTICE OF CANCELLATION Filing Date: 12-AUG-2010 Filing Party: Disposition Amount: Docket Text: OF HEARING 105 MCON - MOTION FOR CONTINUANCE Filing Date: 23-AUG-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: [Docket Text: OF JURY TRIAL 106 7E 7- 1 - EXHIBIT LIST Filing Date: 25-AUG-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: AND EXHIBIT LIST 107 ORDG - ORDER GRANTING Filing Date: J02-SEP-2010 Filing Party: Disposition Amount: Docket Text: ION PLAINTIFF'S MOTION FOR CONTINUANCE OF JURY TRIAL j I http://courtcon.co.palm-beach.fl.us/p1s/jiwpick_public_qry_doct.cp_dktrpt docket_report... 11/29/2011 EFTA00294276 - Not an Official Document Page 21 of 67 108 1 ORDG - ORDER GRANTING Filing Date: 02-SEP-2010 Filing Party: Disposition Amount: 'Docket Text: ION PLAINTIFF'S MOTION FOR STATUS CONFERENCE 109 I NOCO - NOTICE OF CONFLICT 'Filing Date: 07-SEP-2010 'Filing Party: SANCHEZ, LILLY ANN Disposition Amount: Docket Text: none. 110 WT. - MOTION Filing Date: I17-SEP-2010 'Filing Party: FEDWARDS, BRADLEY J Disposition Amount: Docket Text: TO EXPAND INTERR 111 NOFI - NOTICE INTERROGS OF FILING Filing Date: 17-SEP-2010 Filing Party: EDWARDS, BRADLEY J Disposition Amount: Docket Text: none. --, 112 NOT - NOTICE Filing Date: I17-SEP-2010 Filing Party: rEDWARDS, BRADLEY J Disposition Amount: Docket Text: PROPOUNDING EXPERT INTERR 113 j REQP - REQUEST TO PRODUCE Filing Date: 17 SEP-2010 Filing Party EDWARDS, BRADLEY J Disposition Amount Docket Text: none. 114 L NOH - NOTICE OF HEARING Filing Date: 17-SEP-2010 Filing Party: http://courtcon.co.palm-beach.fl.us/pls/jiwp/ckpublic_qry_doct.cp_dkUpt docket_report... 11/29/2011 EFTA00294277 - Not an Official Document Page 22 of 67 Disposition Amount: Docket Text: SEPTEMBER 23,2010 115 RQAD - REQUEST FOR ADMISSIONS Filing Date: 17-SEP-2010 Filing Party: EDWARDS, BRADLEY J Disposition Amount: Docket Text: AND INTERROGATORY 119 NOUN - NOTICE OF UNAVAILABILITY Filing Date: 21-SEP-2010 Filing Party: SCAROLA , ESQ, JACK Disposition Amount: Docket Text: none. 117 STMT - STATEMENT Filing Date: 22-SEP-2010 Filing Party: EDWARDS, BRADLEY J Disposition Amount: Docket Text: OF UNDISPUTED FACTS 118 MOT - MOTION Filing Date: 22-SEP-2010 Filing Party: EDWARDS, BRADLEY J Disposition Amount: Docket Text: [FOR FINAL SUMMARY JUDGMENT 120 MOT MOTION Filing Date: 04-OCT-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: FOR ENLARGEMENT OF TIME TO FILE JOINT STATEMENT 121 AGOR - AGREED ORDER Filing Date: 06-OCT-2010 Filing Party: Amount: —Disposition Docket Text: ON EDWARDS MOTION TO EXPAND CROW INTERR IS GRANTED. D 122 AGOR - AGREED ORDER http://courtcon.co.palm-beach.flus/p1s/jiwp/ck_public_qry_doct.cp_dIctrpt_docket report.. 11/29/2011 EFTA00294278 - Not an Official Documcnt Page 23 of 67 Filing Date: 12-OCT-2010 Filing Party: Disposition Amount: Docket Text: PLTFS MOTION FOR ENLARGEMENT OF TIME TO FILE JOINT STATEMENT IS GRANTED. D CROW 123 MCMP - MOTION TO COMPEL Filing Date: 14-OCT-2010 Filing Party: Disposition Amount: Docket Text: 'none. 124 NOH - NOTICE OF HEARING iFiling Date: 14-OCT-2010 'Filing Party: Disposition Amount: r Docket Text: 21-OCT=-=10 125 STMT - STATEMENT Filing Date: 15-OCT-2010 Filing Party: Disposition Amount: Docket Text: JOINT AND CASE MANAGEMENT REPORT 126 NOTD - DEPOSITION NOTICE OF TAKING Filing Date: 18-OCT-2010 Filing Party: Disposition Amount: Docket Text: none. 127 I MOT - MOTION Filing Date: 19-OCT-2010 Filing Party: EDWARDS, BRADLEY J Disposition Amount: Docket Text: FOR LEAVE TO ASSERT CLAIM FOR PUNITIVE DAMAGES 128 1RNOH - RE-NOTICE OF HEARING Filing Date: 20-OCT-2010 Filing Party: http://courtcon.co.palm-beach.fl.us/pls/jiwp/ck_public_qry_doct.cp_ciktrpt_docket report... 11/29/2011 EFTA00294279 - Not an Official Document Page 24 of 67 Disposition Amount: Docket Text: OCTOBER 27,2010 129 I MOT - MOTION Filing Date: 21-OCT-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: TO ENLARGE TIME TO RESPOND TO CERTAIN DISCOVERY REQUESTS 130 RESP - RESPONSE TO: Filing Date: 21-OCT-2010 Filing Party: Disposition Amount: Docket Text: REQUEST TO PRODUCE 131 OBJ - OBJECTION Filing Date: 21-OCT-2010 Filing Party: Disposition Amount: Docket Text: TO INTERROGATAORIES 132 RESP - RESPONSE TO: Filing Date: 21-OCT-2010 Filing Party: Disposition Amount: Docket Text: REQUEST FOR ADMISSION & INTERROGARTORY 133 ANTI - ANSWER INTERROGATORIES TO Filing Date: 21-OCT-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: none. 134 I NOH - NOTICE OF HEARING Filing Date: 27-OCT-2010 Filing Party: Disposition Amount: Docket Text: NOVEMBER 19,2010 1 http://courtcon.co.palm-beach.fl.us/pls/jiwp/ckpublic_qry_doctcp_dktrpt_docket_report... 11/29/2011 EFTA00294280 - Not an Official Document Page 25 of 67 135 MOT - MOTION Filing Date: 27-OCT-2010 Filing Party: Disposition Amount: Docket Text: TO PROPOUND IN EXCESS OF THIRTY REOUESTS FOR ADMISSIONS 136 RNOH - RE-NOTICE OF HEARING Filing Date: 27-OCT-2010 Filing Party: Disposition Amount: Docket Text: NOVEMBER 4, 2010 8:45 A.M. 137 jORD - ORDER Filing Date: 29-OCT-2010 Filing Party: Disposition Amount: Docket Text: ON STATUS CONFERENCE HELD ON 10/15/10. D CROW 138 ORD - ORDER Filing Date: 04-NOV-2010 Filing Party: Disposition Amount: Docket Text: ON DFT BRADLEY J EDWARDS MOTION TO COMPEL OR ALTERNATIVELY TO STRIKE PLTF CLAIM FOR DAMAGES DCROW 139 I ORD - ORDER Filing Date: 04-NOV-2010 Filing Party: Disposition Amount: Docket Text: ON DEFENDANT BRADLEY J. EDWARDS' MOTION TO COMPEL COMPLETE RESPONSE TO REOUEST TO PRODUCE DCROW 140 I NOT - NOTICE Filing Date: 08-NOV-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: OF PROPOUNDING FIRST SET OF EXPERT WITNESS INTERROGS AND REQUEST TO PRODUCE EXPERT REPORTS http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qty_doct.cp_dkupt docket_report... 11/29/2011 EFTA00294281 - Not an Official Document Page 26 of 67 IITO DEFT/COUNTERPLTF BRADLEY J. EDWARDS 141 ORSH - ORDER SETTING HEARING Filing Date: 10-NOV-2010 Filing Party: Disposition Amount: Docket Text: 05-JAN-11 ( D. CROW) 142 NOH - NOTICE OF HEARING Filing Date: 12-NOV-2010 Filing Party: Disposition Amount: Docket Text: 16-NOV-10 143 ORD - ORDER Filing Date: 16-NOV-2010 Filing Party: Disposition Amount: Docket Text: ON EDWARDS MOTION TO PROPOUND EXCESS OF 30 REQUESTS. D CROW 144 NCAN - NOTICE OF CANCELLATION Filing Date: 16-NOV-2010 Filing Party: Disposition Amount: Docket Text: OF DEPO OF SCOTT ROTHSTEIN 145 I NOT - NOTICE Filing Date: 22-NOV-2010 Filing Party: EDWARDS, BRADLEY J Disposition Amount: Docket Text: OF PROPOUNDING EXPERT INTERROGATORIES 146 I NOH - NOTICE OF HEARING Filing Date: 23-NOV-2010 Filing Party: Disposition Amount: Docket Text: 05-JAN-11 147 NOF - NOTICE OF FILING Filing Date: 23-NOV-2010 hup://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dIctrpt_docket_report... 11/29/2011 EFTA00294282 - Not an Official Document Page 27 of 67 'Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: AMENDED PRIVILEGE LOG 148 NOTD - DEPOSITION NOTICE OF TAKING Filing Date: 130-NOV-2010 Filing Party: ISCAROLA , ESQ, JACK Disposition Amount: Docket Text: none. 149 ORD - ORDER Filing Date: 01-DEC-2010 Filing Party: Disposition Amount: Docket Text: ON PLTFS OBJECTION TO REQUEST FOR ADMISSIONS DTD 12/1/10 DCROW 150 ORD - ORDER Filing Date: 01-DEC-2010 Filing Party: Disposition Amount: Docket Text: ON PLTS OBJECTION TO REQUEST TO PRODUCE, DTD 12/1/10 DCROW 151 I ORD - ORDER Filing Date: 01-DEC-2010 Filing Party: Disposition Amount: Docket Text: ON PLTFS OBJECTIONS TO INTERROGS, DTD 12/1/10 DCROW 152 MOT - MOTION Filing Date: 01-DEC-2010 Filing Party: EDWARDS, BRADLEY J Disposition Amount: Docket Text: FOR STAY OF SUBPOENA 153 RESP - RESPONSE TO: Filing Date: 01-DEC-2010 Filing Party: EPSTEIN, JEFFREY 'Disposition Amount: http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dlctrpt_docket_report... 11/29/2011 EFTA00294283 - Not an Official Document Page 28 of 67 Docket Text: DFT COUNT PLTF BRADLEY J ADMISSIONS DTD 9/16/10 EDWARDS REQ FOR 154 NOS - NOTICE OF SERVICE Filing Date: 06-DEC-2010 Filing Party: Disposition Amount: Docket Text: ANSWERS TO FIRST SET 155 NOH - NOTICE OF HEARING Filing Date: I09-DEC-2010 Filing Party: Disposition Amount: Docket Text: 27-..IAN-1 . 156 SRSV - SERVED SUBPOENA RETURNED / Filing Date: 14-DEC-2010 Filing Party: Disposition Amount: Docket Text: SERVED 12/10/10 TO ROBERT D CRITTON 157 NPNP - NON PARTY NOTICE OF PRODUCTION Filing Date: 15-DEC-2010 Filing Party: SCAROLA , ESQ, JACK JS Disposition Amount: Docket Text: ISEE LIST 158 NOTD - DEPOSITION NOTICE OF TAKING Filing Date: 16-DEC-2010 Filing Party: Disposition Amount: Docket Text: SCOTT ROTHSTEIN 159 NOTD - DEPOSITION NOTICE OF TAKING Filing Date: 16-DEC-2010 Filing Party: Disposition Amount: http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dktrpt_docket_report... 11/29/2011 EFTA00294284 - Not an Official Document Page 29 of 67 Docket Text: IKEN JENNE 160 NOTD - DEPOSITION NOTICE OF TAKING IFiling Date: 16-DEC-2010 Filing Party: Disposition Amount: Docket Text: GARY FARMER 161 NOTD - DEPOSITION NOTICE OF TAKING IFiling Date: 16-DEC-2010 IFiling Party: Disposition Amount: Docket Text: DEBRA VILLEGAS 162 NOTD - DEPOSITION NOTICE OF TAKING Filing Date: 16-DEC-2010 Filing Party: Disposition Amount: Docket Text: none. 163 NOTD - DEPOSITION NOTICE OF TAKING Filing Date: 16-DEC-2010 Disposition Amount: Docket Text: none. 164 NOTD - DEPOSITION NOTICE OF TAKING Filing Date: 16-DEC-2010 Filing Party: Disposition Amount: Docket Text: none. 165 NOTD - DEPOSITION NOTICE OF TAKING Filing Date: 16-DEC-2010 Filing Party: http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dkIrpt_docket_report... 11/29/2011 EFTA00294285 - Not an Official Document Page 30 of 67 (Disposition Amount: Docket Text: 'none. 166 NOTD - DEPOSITION NOTICE OF TAKING Filing Date: 16-DEC-2010 Filing Party: Disposition Amount: Docket Text: none. 167 I NOTD - DEPOSITION NOTICE OF TAKING Filing Date: 116-DEC-2010 Filing Party: Disposition Amount: Docket Text: none. 168 MOT - MOTION Filing Date: 22-DEC-2010 Filing Party: EDWARDS, BRADLEY J Disposition Amount: Docket Text: FOR RECONSIDERATION 169 l DEPO - DEPOSITION Filing Date: 28-DEC-2010 Filing Party: Disposition Amount: Docket Text: SUBPOENA FOR 170 DEPO - DEPOSITION 28-DEC-2010 Filing Date: Filing Party: Disposition Amount: Docket Text: 'SUBPOENA FOR 171 DEPO - DEPOSITION Filing Date: 28-DEC-2010 Filing Party: Disposition Amount: Docket Text: SUBPOENA FOR I http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_clktrpt docket_report... 11/29/2011 EFTA00294286 - Not an Official Document Page 31 of 67 1172 11 DEPO - DEPOSITION Filing Date: 28-DEC-2010 Filing Party: Disposition Amount: Docket Text: SUBPOENA FOR 173 DEPO - DEPOSITION Filing Date: I28-DEC-2010 Filing Party: Disposition Amount: Docket Text: SUBPOENA FOR 174 DEPO - DEPOSITION Filing Date: L28-DEC-2010 Filing Party: Disposition Amount: Docket Text: SUBPOENA FOR 175 OBJ - OBJECTION Filing Date: 28-DEC-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: r Docket Text: TO BRADLEY EDWARDS EXPERT INTERRO... 176 NOS - NOTICE OF SERVICE Filing Date: 28-DEC-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: ANSWERS TO BRADLEY EDWARDS EXPERT INTERRO 179 MOT - MOTION Filing Date: La-DEC-2010 Filing Party: Disposition Amount: Docket Text: TO APPOINT COMMISSONER 180 I NOH - NOTICE OF HEARING Filing Date: 28-DEC-2010 Filing Party: http://courtcon.co.palm-beach.fl.us/p1s/jiwp/ck_public_qry_doct.cp_dIctrpt_docket_report... 11/29/2011 EFTA00294287 - Not an Official Document Page 32 of 67 Disposition Amount: Docket Text: 181 'MONDAY, JANUARY 3, 2011 MOT - MOTION Filing Date: 30-DEC-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: 182 Filing Date: TO TAKE JUDICAL NOTICE NOH - NOTICE OF HEARING DO-DEC-2010 Filing Party: Disposition Amount: Docket Text: 183 JANUARY 4,2011 MOT - MOTION Filing Date: 30-DEC-2010 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: FOR PROTECTIVE ORDER RELATING TO DEPOSITION OF ROBERT CRITTON 177 AGOR - AGREED ORDER Filing Date: 03-JAN-2011 Filing Party: Disposition Amount: Docket Text: MOITION APPT COMMISSIONER GRANTED. D CROW **2 CC MLD TO ATTY AKERMAN** 178 AGOR - AGREED ORDER Filing Date: 03-JAN-2011 Filing Party: Disposition Amount: Docket Text: APPT COMMISSIONER. D CROW 184 - I AGOR - AGREED ORDER Filing Date: 04-JAN-2011 Filing Party: Disposition Amount: Docket Text: JEFFREY EPSTEIN'S MOTION TO TAKE JUDICIAL NOTICE DCROW hup://courtcon.co.palm-beach.fl.usipls/jiwp/ck_public_qry_doct.cp_clictrpt_docket_report... 11/29/2011 EFTA00294288 - Not an Official Document Page 33 of 67 185 NOF - NOTICE OF FILING Filing Date: 04-JAN-2011 Filing Party: Disposition Amount: Docket Text: SUPPLEMENTAL EXHIBIT 186 1 MOT - MOTION ....- Filing Date: 06-JAN-2011 Filing Party: EPSTEIN, JEFFREY Disposition Amount: Docket Text: LTO AMEND COMPLATNT 187 RQCP - REQUEST FOR COPIES Filing Date: 06-JAN-2011 'Filing Party: IEPSTEIN, JEFFREY Disposition Amount: Docket Text: ITO EDWARDS' NOTICE OF PRODUCTION FROM NON-PARTY 188 NOTD - DEPOSITION NOTICE OF TAKING Filing Date: 06-JAN-2011 Filing Party: ACKERMAN , ESQ, JOSEPH L Disposition Amount: Docket Text: (none. 189 NCAN - NOTICE OF CANCELLATION Filing Date: 07-JAN-2011 Filing Party: Disposition Amount: Docket Text: OF DEPOSITION 190 NOTD - DEPOSITION NOTICE OF TAKING i Filing Date: 11-JAN-2011 Filing Party: ACKERMAN , ESQ, JOSEPH L -1 Disposition Amount: Docket Text: I CORRECTED 1 191 I NOTD - DEPOSITION NOTICE OF TAKING http://courtcon.co.palm-beach.fl.us/pls/jiwpick_public_qry_doct.cp_ciktrpt_docket_report... 11/29/2011 EFTA00294289 - Not an Official Document Page 34 of 67 Filing Date: 11-JAN-2011 Filing Party: ACKERMAN , ESQ, JOSEPH L Disposition Amount: Docket Text: CORRECTED 192 NOTD - NOTICE OF TAKING DEPOSITION Filing Date: 11-JAN-2011 Filing Party: ACKERMAN , ESQ, JOSEPH L Disposition Amount: Docket Text: CORRECTED 193 NOTD - NOTICE OF TAKING DEPOSITION Filing Date: 11-JAN-2011 Filing Party: ACKERMAN , ESQ, JOSEPH L Disposition Amount: Docket Text: CORRECTED 194 NOTD - NOTICE OF TAKING DEPOSITION Filing Date: 11-JAN-2011 Filing Party: ACKERMAN , ESQ, JOSEPH L Disposition Amount: Docket Text: CORRECTED 195 1 I NOTD - NOTICE OF TAKING DEPOSITION Filing Date: 11-JAN-2011 Filing Party: ACKERMAN , ESQ, JOSEPH L Disposition Amount: Docket Text: CORRECTED 196 NOTD - NOTICE OF TAKING DEPOSITION Filing Date: 11-JAN-2011 Filing Party: ACKERMAN , ESQ, JOSEPH L Disposition Amount: i • CORRECTED 197 ORD - ORDER I http://courtcon.co.palm-beach.fl.us/p1s/jiwpick_public_qry_doct.cp_dIctrpt docket_report . 11/29/2011 EFTA00294290