EFTA00294291.pdf

02/01/2012 16:11 FAX 5616845816 SEARCY DENNEY liboovois JEF v REY EPSTEIN, Plaintiff, SCOTT ROTHSTELN, individually, BRAD I LEY J. EDWARDS, individually, and individually, Defendant, 1 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA0408003OOOOvIBAG DEFENDANT/COUNTER-PLAINTIFF, BRADLEY J. EDWARDS, RESPONSE IN dPPOSITION TO JEFFERY EPSTEIN'S MOTION FOR A PROTECTIVE ORDER RBLATING TO HIS DEPOSITION AND IN SUPPORT OF EDWARDS' MOTINO TO COMPEL AND IMPOSE SANCTIONS j Defendant/Counterplaintiff, Bradley J. Edwards (hereinafter EDWARDS), by and throligh his undersigned attomeys, respectfully responds in opposition to Plan tiff/Counterdefendant, Jeffrey Epstein's (hereinafter EPSTELN) motion for a protective orde[ and to terminate his deposition. The motion is ffivolous and should be denied. EPSTEIN has filed a Complaint against EDWARDS that alleges that EDWARDS filed lawsltits making "unfounded . . . sexual allegations" and pleading "a causc of action for RICO wheii there was no good faith basis for doing so." EPSTEIN's Complaint further alleges that much of the discovery EDWARDS look in support of these lawsuits "had no legitimate purpose." In prior filings with this Court, EDWARDS has painstakingly detailed under oath the gooci faith basis for every claim he brought and every step be took in the prosecution of Chose clainps. In defense of the lawsuit against him, EDWARDS is now obviously entitled to ask EFTA00294291 02/01/2012 18:11 FAX 5818845818 SEARCY DENNEY 2002/015 Ed rds adv. Epstein Casa No.: 502009CA040800XXXXMBAG Resrlonse in Opposition to Epstein's Motion for Protective Order Rotating to his Deposition and in Sumfort of Edwards' Motion to Compel and Impose Sanctions Pagi 2 of 15 EPSTEIN whether the lawsuits were, far from being "unfounded," in fact entirely well-founded and whether there was, in fact, a "good faith basis" for a RICO claim. EDWARDS is now obviously allowed to explore the legitimate purposes underlying his discovery in those cases — specifically, whether his discovery efforts were reasonably calculated to lead to admissible i evi ence by showing that he, in fact, would have uncovered admissible evidence through those dis very lo efforts had his cases not been voluntarily settled by EPSTEIN. Accordingly, EP TEIN's baseless motion should be denied and EPSTEIN should be directed to begin to ans er relevant questions about both the lawsuit that he chose to file and prosecute against El) ARDS and the pending, closely related counterclaims. FACTUAL BACKGROUND Plaintiff/Counterdefendant, EPSTEIN has filed a Second Amended Complaint against ED ARDS. The complaint challenges EDWARDS' professionalism as an attorney rep enting girls who had been sexually abused. In particular, the Complaint charges EDWARDS with "making unfounded and highly ch ged sexual allegations" in the lawsuits he and his co-counsel filed on behalf of clients. Second Amended Complaint at 2 (emphasis added). The Complaint specifically advances an "abilise of process" claim against EDWARDS, namely that EDWARDS "made illegal, improper, and perverted use of the civil process" by doing such things as "filing a state court action on behilf of L.M. against [EPSTEIN] seeking damages" (¶ 30). EPSTEIN goes on to allege that "EDWARDS knew or should have known that highly-charged sexual allegations in [his] co laint that EPSTEIN forced L.M. to have `oral sex' with him were false" (1130(b)). EFTA00294292 02/01/2012 16:12 FAX 5616845816 ankle DENNElt .411003/015 Edwards adv. Epstein Cas No.: 502009CA040800XXXXMBAG Res nse in Opposition to Epstein's Motion for Protective Order Relating to his Deposition and in Sop rt of Edwards' Motion to Compel and Impose Sanctions Pag1 3 of IS the EPSTEIN also contends that EDWARDS "made illegal, improper and perverted use of civil process" by conducting "unreasonable and unnecessary `discovery,' [and] making unfounded allegations . . . ." (¶ 32)). Among the improper discovery EPSTEIN alleges that EDWA.RDS engaged in without "legitimate purpose" was asking three of EPSTEIN's jet pilots about sexual activities on EPSTEIN's aircraft (¶ 32(1)); sending letters asking for deposition dat4 for the deposition of TV personality Donald Trump, law professor Alan Dcrshowitz, magician David Copperfield, and other individuals who were without any knowledge of relevant eviarnce about EPSTEIN's sex offenses (¶ 32(2)); subpoenaing EPSTEIN's sex therapist (1[ 32(')); attempting to plead a civil RICO action against EPSTEIN for organizing a criminal enterprise bringing young girls to EPSTEIN to molest "when there was no good faith basis for doing so" (1 32(9)); and filing without sufficient evidence a motion alleging EPSTEIN was going to transfer assets outside the country to avoid paying damages to his sexual assault victims (131(10)). II In response to EPSTEIN's Complaint, EDWARDS has filed a Second Amended Cou terclaim against EPSTEIN. The counterclaim alleges (among many other things) that "Dal 'ng 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 inve his their tigation [of EPSTEIN's sex offenses] by employing the extraordinary financial resources at isposal to intimidate his [sexual assault] victims and their legal counsel into abandoning legitimate claims or resolving those claims for substantially less than their just value" (Cot nterclaim ¶ 6). The counterclaim specifically alleges an abuse of process claim, namely EFTA00294293 02/01/2012 18:12 FAX 8818845818 SEARCY DENNEY 111004/015 Edwards adv. Epstein Case No.: 502009CA040800XXXXMBAG Response in Opposition to Epstcin's Motion for Protective Order Relating to his Deposition and in Su rt of Edwards' Motion to Compel and Impose Sanctions Page 4 of 15 tha "every motion [made by EPSTEIN], every request for production, every subpoena issued, and every deposition taken . . . was intended with respect to EDWARDS solely and exclusively to advance EPSTEIN's efforts at extortion . . . ." (Counterclaim ¶ 16). The counterclaim also rai1 es a malicious prosecution claim, alleging that EPSTEIN's entire Complaint against E1 WARDS was "false and unsupported by any reasonable belief or suspicion that [its 1 all gations) were true" (Counterclaim ¶ 29). On January• 25, 2012, EDWARDS' attorney began taking EPSTEIN's deposition. (A copy of the transcript of the deposition is attached as Exhibit "A"). EPSTEIN answered a question about his name. EPSTEIN answered a question about bis addresses. Then EPSTEIN, in typical EPSTEIN fashion, proceeded to give essentially no information in answers to many other qu 'stions asked of him. Among the relevant questions that EPSTEIN refused to answer were: Do you now or have you ever had a sexual preference for minors? (p. 6) • Have you ever discussed your sex-related arrest or conviction with any reporter or news m dia representative? (p. 12) Have you ever discussed your sex-related activities with minors in the State of Florida with any reporter or news media representative? (p. 13) • Do you know who LM is? (p. 21). A ough he had answered very few questions — and even though he is the Plaintiff who chose to t : o er the legal system by filing his Complaint -- EPSTEIN then terminated his deposition, rtedly to get further "direction" from the Court. EDWARDS' counsel then stated: EFTA00294294 02/01/2012 16:13 ■ 5616845816 SEARCY DENNEY lj005/015 Edwards adv. Epstein Ca. No.: 502009CA040800XXXXMBAO Responst in Opposition to Epstein's Motion for Protective Order Relating to his Deposition and in St4 port of Edwards' Motion to Compel and impose Sanctions Page Sof IS So that the record is clear, it is my intention to ask very specific questions about every factual allegation included in every claim brought by Mr. Edwards on behalf of every victim in every case in which it is alleged that Mr. Edwards has abusively prosecuted that claim. I want to know about the connection between Mr. Epstein and each one of those alleged victims. I want to know about every individual who had information concerning the events that are alleged in those complaints, every individual who was in a position to have possibly had information about the events alleged in those complaints. I want to ask this witness about every person whose deposition was taken and scheduled to be taken, the relationship of those persons to Mr. Epstein, knowledge that those persons may have with respect to Mr. Epstein's activities with minors, other crimes committed by Mr. Epstein as part of an ongoing and continuous course of conduct supportive of claims for punitive damages against Mr. Epstein and supportive of RICO claims against him. And had this deposition been permitted to continue, we would have covered each of those areas and substantially more. DISCUSSION I. EDWARDS Is Entitled to Take Broad Discovery In Deposing EPSTEIN. Before turning to the specific questions that EDWARDS is entitled to ask of EPSTEIN, it is portant to review the current procedural posture of this case. EPSTEIN has chosen to invoke the legal system by filing a Complaint against attorney EDWARDS. Accordingly, just like any other civil plaintiff, EPSTEIN must answer questions about his case or suffer the consequences of the application of the well-established "sword-shield doctrine"—the dismissal of his claims. Under the Florida rules, EDWARDS is entitled to ask any and all questions reasonably calculated to lead to the discovery of admissible evidence. Considering the substance of the cla s EPSTEIN is making against EDWARDS in his totally bogus lawsuit that all relate to disaovery that was conducted by EDWARDS in the sexual molestation claims against EPSTEIN, EFTA00294295 02/01/2012 16.13 FAX 5616845816 SEARCY DENNEY 2008/015 Edwards adv. Epstein Cast No.: 502009CA040800XXXXN4BAG Rewonse in Opposition to Epstein's Motion for Protective Order Relating to his Deposition and in Su port of Edwards' Motion to Compel and Impose Sanctions j e Pa 6of IS th questions asked by EDWARDS' counsel in the deposition of EPSTEIN would likely result in dir act admissible evidence — far exceeding the liberal threshold of reasonably calculated to lead to rte discovery of admissible evidence. II. EDWARDS Is Entitled to Ask EPSTEIN Questions About Whether the Clients' Claims Against EPSTEIN Were "Well-Founded." Remarkably, EPSTEIN takes the position that he can file a lawsuit against EDWARDS alleging that F,DWARDS improperly £led "unfounded" sexual abuse claims (Second Amended Complaint at 2) but then he need not answer any questions about whether the abuse claims were, ind&ed, well-founded! His position is absolutely absurd. Once EPSTEIN filed an "abuse of proicess" claim against EDWARDS — for example, that EDWARDS "made illegal, improper, and pe L. erred use of the civil process" by doing such things as "filing a state court action on behalf of . against [EPSTEIN) seeking damages" (1 30) — EDWARDS was entitled to depose EPSTEIN about those issues. It was entirely proper, for instance, for EDWARDS to ask about wh EPSTEIN considers L.M.'s sexual abuse law suits to be somehow "improper." Of course, if EP TEN sexually abused L.M., there would be nothing "improper" about an attorney filing a sexlial abuse claim against EPSTEIN. Indeed, an attorney with an obligation to zealously replies ' ent his clients would be neglecting his duties if he did anything other than file such a claim . EPSTEIN's motion for a protective order claims that these questions had no other purpose than to be somehow "sexually harassing." Motion for a Protective Order at 4. But the mot on itself demonstrates the absurdity of EPSTEIN's position. EPSTEIN's Motion for a EFTA00294296 02/01/2012 16:13 FAX 5616845818 SEARCY DENNEY 2007/015 Edw rds adv. Epstein Case o.: 502009CA040800)0C0CMEtAG Res nsc in Opposition to Epstein's Motion for Protective Order Relating to his Deposition and in Sup a of Edwards' Motion to Compel and Impose Sanctions Page 7 of 15 Prothetive Order describes Epstein's lawsuit as involving a claim that "EDWARDS filed the federal case of L.M. v. EPSTEIN . . . with 145 counts and knew . . . that the highly-charged sexual allegations were false . . . ." Id. at 2 (emphasis added). This claim against EDWARDS obv usly means that EDWARDS is able to ask EPSTEIN whether each and every one of these 145 counts were or were not "false" — i.e., whether EPSTEIN sexually abused L.M. on 145 spe ifically identified dates. That is precisely what EDWARDS was in the process of beginning to d in EPSTEIN's deposition ... at least before EPSTEIN walked out. In his pleading, EPSTEIN appears to exhibit some squeamishness about sexual matters, in clai ing that "questions related to sexual conduct and criminal misconduct are not (and were not) designed to, and would not, provide any information relevant to the" case. Motion for Pro case bell ED • ctive Order at 5. But EPSTEIN's complaint directly and repeatedly belies the idea that this should be litigated without sexual activities being discussed. Apparently EPSTEIN ves he should be allowed to file a complaint making all kinds of false allegations about VARDS and the discovery EDWARDS conducted in the various sexual abuse cases brought on behalf of several of EPSTEIN's child victims, yet have the court hand-cuff EDWARDS so as to not permit EDWARDS to disprove those false allegations made by EPSTEIN nor allow ED ARDS to prove the valid allegations outlined in his counter-claim. While that may be what wo d work best for EPSTEIN, that is simply not at all how our system works. Nor does it make any difference, as EPSTEIN seems to suggest, that he might choose to Inv e the Fifth Amendment rather than provide direct answers to some of these questions. It is not arassment to ask relevant questions, which a plaintiff in a civil case then refuses to answer. EFTA00294297 02/01/2012 16:14 FAX 5616845816 SEARCY ISBNNBV la008/015 Ed ards adv. Epstein Cas No.: 502009CA040800XXXXMBAG Res nse in Opposition to Epstein's Motion for Protective Order Relating to his Deposition and in Su on of Edwards' Motion to Compel and Impose Sanctions Dag 8 of 15 To he contrary, the plaintiff's answers can be used against him through adverse inferences. See, e.g , In re J.E.B., 971 So.2d 187, 188 (Fla.App. 2 Dist. 2007) (citing Baxter v. Palmigiano, 425 U.S. 308 (1976) ("[T]he Fifth Amendment does not forbid adverse inferences against parties to civ I actions when they refuse to testify in response to probative evidence offered against them[.]")). For all these reasons, EPSTEIN's motion for a protective order to prevent EDWARDS from asking questions about whether the sexual assault cases against him were well- folided should be denied. rn. EDWARDS Is Entitled to Ask Questions About Whether There Was a Basis for His Client's RICO Claims Against EPSTEIN. As a separate and independent reason for completely rejecting EPSTEIN's motion for a protective order, EDWARDS was entitled to ask EPSTEIN questions about his clients' RICO claims against EDWARDS. EPSTEIN's complaint against EDWARDS alleges that "Et WARDS filed motions in the EPSTEIN Actions attempting to plead a cause of action for RICO [Racketeering Influenced and Corrupt Organizations) when there was no good faith basis for:king so." Second Amended Complaint at 32(9). EDWARDS is accordingly entitled to ask questions about whether there was a "basis" for the RICO claims against EPSTEIN. A bit of background about the complaints and the RICO claims may be useful. For each of ii s three clients, EDWARDS tiled complaints alleging basic sexual assault claims, such as sexual battery in violation of Florida Statutes §800.04 and procuring a minor for prostitution in EFTA00294298 ' OE/0112612 FAE 58188451318 sEARcY DENNEY Edwalds adv. Epstein Case No.; 502009CA040800XXXXMRAG Response in Opposition to Epstein's Motion for Protective Order Relating to his Deposition and in Support of Edwards' Motion to Compel and Impose Sanctions Page of 15 vio Lion of Florida Statutes § 796.03. Such claims involve single acts of sexual abuse directed agai st EDWARDS' clients. EDWARDS, however, went further than allege just simple, isolated acts of sexual abuse by PSTEIN. Instead, EDWARDS filed detailed RICO claims under, as appropriate, state and federal law. These RICO claims alleged that it was no accident that young girls like his clients L. , E.W. and Jane Doe ended up in EPSTE1N's mansion where he sexually abused them. Inst d, the RICO claims contended that EPSTEIN ran an entire criminal organization that was desiLn ed to satisfy his sexual appetite for attractive young (white) girls under the age of eighteen. The I I L. . v. Jeffrey Epstein, Case No. 502008-CA-028051 JOO(Xlv.03 AD (15th Cir. Fla.). The Rico Complaint specifically alleged that EPSTEIN procured dozens of girls to be sexually organization operated as follows: The enterprise was not a mere informal conspiracy, but had a definite hierarchical structure. Defendant, Jeffrey Epstein, served informally but effectively as the leader, C.E.O. or "boss" of this organization, directing his underlings how to recruit and procure young girls for his sexual activities and when to bring the girls to his mansion. y Epstein's key "lieutenant" in the organization was defendant who served as both his scheduler and a recruiter/procurer o e gir s. is was an important function, as the recruiting was necessary to satisfy Defendant Jeffrey Epstein's desire to abuse a large number of different minor girls with different (albeit similar) physical attributes and the scheduling was necessary to insure that the minor girls would be brought to Defendant Jeffrey Epstein's mansion to be sexually abused and prostituted at a time when Defendant Jeffrey Epstein was there (but not at the same time, when they might learn of other girls' identities and possibly become emboldened to report his activities to law enforcement). ab ed in this way. (For the convenience of the Court, a copy of the complaint by L.M. raising a R14 O claim is attached to this response as Exhibit "B".) EFTA00294299 02/01/2012 16:15 FAX 5616845816 SEARCY DENNEY 2010/015 was Edw ds adv. Epstein Case No.: 502009CA040800XXXXMBAG Response in Opposition to Epstein's Motion for Protective Order Relating to his Deposition and in Support of Edwards' Motion to Compel and Impose Sanctions Pagl lOof 15 It is these RICO allegations that EPSTEIN is now alleging EDWARDS filed "when there no good faith basis for doing so." Second Amended Complaint at ¶ 32(9). To defend himslelf against this allegation, EDWARDS must now obviously establish that there was a "good faitl basis" for the RICO claims. EDWARDS intends to establish that good faith basis by (am ng other things) showing that each and every allegation in the RICO Complaint was true. For example, with regard to the allegations quoted above, EDWARDS is now entitled to ask wh er EPSTEIN was (in the words of the RICO allegation) "directing his underlings how to rec it and procure young girls for his sexual activities and when to bring the girls to his marision." As another example, EDWARDS is now entitled to ask whether EPSTEIN was (in the words of the RICO allegation) arranging for "girls . . . [to] be brought to [his] mansion to be sexually abused and prostituted at a time when [he] was there (but not at the same time, when they, might learn of other girls' identities and possibly become emboldened to report his activities to law enforcement)." Finally, since the RICO allegations contain general allegations about EP IN running a criminal organization, all deposition questions about EPSTEIN's criminal orgdttization procuring young girls for him are obviously proper and should be allowed. As this Court knows, all of EPSTEIN's preposterous claims pretending to demonstrate some "abuse of process" are based on the allegation that EDWARDS' discovery tactics, including the filing of RICO counts, were allegedly done to further Scott Rothstein's Ponzi scheme. To highlight the level of bad-faith to which EPSTEIN stoops to make this allegation that EDWARDS' filing of the RICO count was somehow in furtherance of Rothstein's schemes and not done for proper purposes, each of the original three complaints that included a RICO EFTA00294300 02/01/2012 10:15 FAX 5616845810 SEARCY DENNEY 2011/015 Edwt rds adv. Epstein Case o.: 502009CA040200X=CMBAG Resp nse in Opposition to Epstein's Motion for Protective Order Relating to his Deposition and in Stipp rt of Edwards' Motion to Compel and Impose Sanctions Page 11 of 15 court are attached. The Court will quickly notice something that EPSTEIN and bis army of if ant! eys have known all along to be true — each of these complaints was filed in 2008, while ED ARDS was a sole practitioner, months before knowing Rothstein or joining the Rothstein firm (the complaint filed on behalf of L.M. was already referenced above as Exhibit "B"; E.W. v. Jeffrey Epstein and M 50 2008 CA 028051XXXXMB AD (15th Cir. Fla.) Exhibit "C" Jane Doe v. Jeffrey Epstein, 08-80893-CIV-Marragoluison, (United States District Court Souftiem District of Florida) Exhibit "D"). IV. I EDWARDS Is Entitled to Ask Questions About Whether He Was Pursuing Productive Lines of Discovery. EPSTEIN also contends that EDWARDS "made illegal, improper and perverted use of the civil process" by conducting "unreasonable and unnecessary 'discovery,' [and] making unfciunded allegations . . . •" (¶ 32)). By making such allegations, EPSTEIN is obviously ope ing himself up for questions about what the discovery 1) would have revealed and whether the disc very involved "unfounded" allegations. As a specific example, EPSTEIN alleges that EDWARDS engaged in discovery without "leg timate purpose" by asking three of EPSTEIN's jet pilots about sexual activities on EPS1TEIN's aircraft. Second Amended Complaint at I 32(1). To defend against this allegation, ED .WARDS is now entitled to ask EPSTEIN whether he was sexually abusing young girls on EPSTEIN's airplane. Obviously, if EPSTEIN was engaged in such abuse — which he was, that would have been highly relevant to the RICO claim that EDWARDS was pursuing for his EFTA00294301 02/01/2012 18:15 FAX 5616845816 SEARCY DENNEY D012/015 Ed s adv. Epstein Cosi No.: 502009CA040800XXXXMBAG RcsAonsc in Opposition to Epstein's Motion for Protective Order Relating to his Deposition and in Supfort of Edwards' Motion to Compel and Impose Sanctions Pag I2 of 15 cli ts, and even more importantly, it would have been relevant to the punitive damages claims that were brought by each of EPSTEIN's sexual abuse victims. As another specific example, EPSTEIN alleges that EDWARDS had no "legitimate purpose" in requesting to depose TV personality Donald Trump, law professor Alan Dershowitz, malician David Copperfield, and other individuals. Second Amended Complaint at ¶ 32(2). Cle ly EDWARDS is now entitled to ask EPSTEIN whether these individuals possessed kn ledge about EPSTEIN sexually abusing young girls and whether these individuals had kn ledge of how EPSTEIN was procuring these young girls to abuse. In fact, in this case, the star ent of M=Iwas taken wherein she describes being constantly abused while serving as EPSTEIN's travel-along underage sex slave for years. She clearly indicates in her star ment that EPSTEIN abused underage children everywhere, including his airplanes, and that EP' TEIN's pilots and certain other individuals, including Dershowitz, had information relevant to EPSTEIN's repeated abuse of underage girls. mo As yet another example, EPSTEINalleges that EDWARDS had no basis for filing a on alleging EPSTEIN was going to transfer assets outside the country to avoid paying darriages to his sexual assault victims. Second Amended Complaint at ¶ 32(10). To defend against this allegation, EDWARDS is now entitled to ask whether EPSTEIN was afraid of being held liable on the numerous claims being filed li gainst him and whether, as a result, he began liqUodating assets and moving funds to off-shore bank accounts, placing assets in the names of oth rs, or transferring property, money or assets to other hidden places. EFTA00294302 02/01/2012 10:18 FAX 5616845818 SEARCY DENNEY litotsiots Edu rds adv. Epstein la Cas. No.: 502009CA040800XXXXMBAG Res' onse in Opposition to Epstein's Motion for Protective Order Relating to his Deposition and in Support of Edwards' Motion to Compel and Impose Sanctions Par 13 of 15 The fact is that EPSTEIN, and his counsel, know that each of the discovery efforts that EDWARDS took in prosecuting claims on behalf of his clients, about which they are currently con plaining, were taken in good faith and for proper purposes. EPSTEIN and his counsel know that there was no good faith basis for the lawsuit filed and prosecuted against EDWARDS. EP: TEIN knows that there is no support for his ever-changing theory of abuse of process. EPSTEIN knows that each act he has taken in prosecuting this frivolous action against EDWARDS, including the filing of the original complaint and each amendment, the filing of motions, serving of subpoenas, taking of depositions, continually misrepresenting facts to this Court, and continually disseminating the various versions of his baseless action to many other peddle in the legal community, was done in bad faith. Each act that EPSTEIN has taken has be with the most malicious intent possible, and only to satisfy one of his improper ulterior mo ves, which include but cannot be limited to: intimidating and harassing EDWARDS, atte pting to damage and tarnish EDWARDS' reputation, invading EDWARDS' privacy, cad ing EDWARDS to lose valuable time and expense, extorting EDWARDS through bullying tactics, attempting to force EDWARDS into abandoning his legitimate counter-claim needed to vindicate himself, and to inflict as much stress and emotional pain as possible as a means of gett Ing revenge against EDWARDS. It is clear that EPSTEIN wants revenge for EDWARDS' sucOessfully prosecuting EPSTEIN for his molestation of children, for vigorously pursuing an l action in Federal Court to overturn EPSTEIN's Non-Prosecution Agreement, for informing au rities of EPSTEIN's probation violations, and for exposing EPSTEIN's criminal enterprise that orked in concert to molest dozens of underage children. EFTA00294303 02/01/2012 16:16 FAX 5616645816 SPAPCIt DtIVEY 2014/015 EdwocIsadv.Epstein Call4o.:502009CA040800XXXXMBAG Rcaponse in Opposition to Epstein's Motion for Protective Order Relating to his Deposition and in SupponofEdwavieNkitionoaCompehmdlincameSamtions Pagd14of15 For all these reasons, EDWARDS is now clearly entitled to ask EPSTEIN about the disc very that was going on in the civil cases and whether it was going to produce highly rele ant information to support the claims of EDWARDS' three clients. I HEREBY CERTIFY that a true and correct copy of the foregoing has been furnished by Fax d U.S. Mail to all counsel on the attached ) 1st day of February, 2012. Jack Flori.: No.: 169440 Se• enney Scarola Barnhart & Shipley, P.A. 21.9 alm Beach Lakes Boulevard t Palm Beach, Florida 33409 Phone: (561) 686-6300 Fax: (561) 383-9451 Attorneys for EDWARDS EFTA00294304 02/01/2012 16:16 FAX 5616845816 SEARCY DENNEY '&15/015 F,dwards adv. Epstein Cast No.; 502009CA040800XXXXMBAG Resionse in Opposition to Epstein's Motion for Protective Order Relating to his Deposition and in Support of Edwards' Motion to Compel and hnposc Sanctions Page IS of IS COUNSEL LIST Jack A. Goldberger, Esquire Attirbury, Goldberger & Weiss, P.A. 25 Australian Avenue South, Suite 1400 Wet Palm Beach, FL 33401 Ph e: (561) 659-8300 : (561) 835-8691 F r, Jaffe, Weissing, Edwards, Fistos & Le an, PL 42 N. Andrews Avenue, Suite 2 Fort Lauderdale, FL 33301 Ph e: (954) 524-2820 Fa (954) 524-2822 Mac S. Nurik, Esquire One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 Phoine: (954) 745-5849 Fax (954) 745-3556 Joseph L. Ackerman, Jr., Esquire Foter White Burnett, P.A. 901 Phillips Point West 771S Flagler Drive West Palm Beach, FL 33401-6170 Phone: (561) 802-9044 Fax (561) 802-9976 EFTA00294305