EFTA00807770.pdf

IN THE CIRCUIT COURT OF THE H1-1 EENTH 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, Defendants. ORDER GRANTING MOTION TO PERMIT BRADLEY J. EDWARDS TO TAKE THE LIMITED DEPOSITION OF JEFFREY EPSTEIN THIS CAUSE having come before the Court for hearing on May 23, 2018, upon Bradley J. Edwards' ("Edwards") Motion to Permit Bradley J. Edwards to Take the Limited Deposition of Jeffrey Epstein, and the Court, having reviewed the file, considered the arguments of counsel, and being fully advised in the premises, it is hereby ORDERED and ADJUDGED that the Motion is GRANTED as stated on the record and summarized as follows: Edwards may take the limited deposition of Jeffrey Epstein ("Epstein") regarding Epstein's possession of Edwards' alleged privileged materials originating from the disc that is the subject of the Bankruptcy proceeding (the "alleged privileged materials"), some of which were identified by Epstein as exhibits on his Clerk's Trial Exhibit List. The Court recognizes that no judge has made a determination that the exhibits are, in fact, privileged and that Epstein has requested an in camera inspection of them. (5/23/18 Tr. 13:9-23.) Epstein's deposition shall be limited to the following topics: 1 EFTA00807770 Order Granting Bradley J. Edwards' Motion to Take Limited Deposition of Jeffrey Epstein Epstein v. Rothstein, Edwards and L.M. Case No.: 502009CA041800XXXXMBAG 1. Whether and to what extent Epstein reviewed any of the alleged privileged materials prior to March 2018 (5/23/18 Tr. 19:7-12); 2. Whether and to what extent Epstein reviewed any of the alleged privileged materials after March 2018 (5/23/18 Tr. 19:7-12); 3. Whether Epstein has any knowledge regarding compliance with the Court's verbal rulings on the record at the March 8, 2018, hearing regarding destruction of those documents Edwards has claimed are privileged (5/23/18 Tr. 19:13-18); 4. Whether and to what extent Epstein has shared any of the alleged privileged materials with anyone other than his attorneys (5/23/18 Tr. 19:19-22); and 5. Which, if any, of the alleged privileged materials Epstein plans to use to testify at trial. Epstein may avoid questions on this topic if there is a stipulation on the record that he is not testifying at trial (5/23/18 Tr. 19:22-20:2). Epstein's deposition shall be conducted in this matter on the same date his deposition is conducted in the bankruptcy proceeding. Epstein's deposition shall first be conducted in the bankruptcy proceeding and then, immediately following, will be conducted in this matter. Epstein's counsel may assert objections, as appropriate, including, but not limited to, attorney-client privilege, work product and Fifth Amendment objections. Epstein's answering of any question, however, will not be raised or relied upon in this matter or any other by Edwards or any Intervenors, or any other person or entity, nor will it be construed by this Court, or any other court, as a waiver of Epstein's attorney-client privilege, work product protections or Fifth, Sixth and Fourteenth Amendment Rights as guaranteed by the United States Constitution and Article I, 2 EFTA00807771 Order Granting Bradley J. Edwards' Motion to Take Limited Deposition of Jeffrey Epstein Epstein v. Rothstein, Edwards and L.M. Case No.: 502009CA040800XXXXMBAG Sections 2, 9 and 16 of the Florida Constitution, whether in this or any other proceeding, with respect to any question asked of him or to any subject matter relating to any answers Epstein may provide at this deposition. DONE AND ORDERED at West Palm Beach, Palm Beach County, Florida, this day of 2018. THE HONORABLE DONALD W. HAFELE CIRCUIT COURT JUDGE Copies have been furnished to all counsel on the attached counsel list. COUNSEL LIST Jack Scarola Karen E. Te David P. Vitale Jr. Searcy Denney Scarola Barnhart & Shipley PA 2139 Palm Beach Lakes Boulevard West Palm Beach, FL 33409 Attorneys for Defendant/Counter-Plaintiff Bradley J. Edwards 3 EFTA00807772 Order Granting Bradley J. Edwards' Motion to Take Limited Deposition of Jeffrey Epstein Epstein v. Rothstein, Edwards and L.M. Case No.: 502009CA040800XXXXMBAG Bradley J. Edwards, Esquire Edwards Pottin er LLC 425 N Andrews Avenue, Suite 2 rt Lauderdale. F 301 Attorneys for Defendant/Counter-Plaintiff Bradley J. Edwards Jack A. Goldber er Esquire Atterbury Goldberger & Weiss, P.A. 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Attorneys for Plaintiff/Counter-Defendant Jeffrey Epstein Nichole J. Segal, Esquire Philip M. Burlington Burlington & Rockenbach, P.A. 444 W Railroad Avenue, Suite 350 West Palm Beach, FL 33401 ttorneys or e en ant/Counter-Plaintiff Bradley J. Edwards Scott J. Link, Esquire Kara Berard Rockenbach, Esquire Rachel J. Glasser Esquire Link & Rockenbach, PA 1555 Palm Beach Lakes Boulevard, Suite 930 West Palm Beach. FL 33401 Attorneys for Plaintiff/Counter-Defendant Jeffrey Epstein EFTA00807773 Order Granting Bradley J. Edwards' Motion to Take Limited Deposition of Jeffrey Epstein Epstein v. Rothstein, Edwards and L.M. Case No.: 502009CA040800XXXXMBAG Marc S. Nurik, Esquire Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale. FL 33301 Attorneys for Defendant Scott Rothstein Paul Cassell, Esquire 383 S. University Salt Lake Cit UT 84112-0730 ttorneys orLimited Intervenors L.M., E.W. and Jane Doe Jay Howell, Esquire Jay Howell & Associates 644 Cesery Blvd., Suite 250 Jacksonville, FL 32211 Attorneys for Limited Intervenors L.M., E.W. and Jane Doe EFTA00807774