EFTA00807765.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, 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 the 49 exhibits identified on Epstein's Clerk's Trial Exhibit List which Edwards claims are privileged. 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. Epstein's deposition shall be limited to the following topics: 1. Whether and to what extent Epstein reviewed any of the 49 exhibits prior to March 2018: EFTA00807765 Order Granting Bradley J. Edwards' Motion to Take Limited Deposition ofJeffrey Epstein Epstein v. Rothstein, Edwards and L.M. Case No.: 502009CA040800YOMMBAG 2. Whether and to what extent Epstein reviewed any of the 49 exhibits after March 2018; 3. Whether Epstein has any knowledge regarding compliance with the Court's verbal rulings on the record at the March 8, 2018, hearing concerning destruction of those documents Edwards has claimed are privileged; 4. Whether and to what extent Epstein has shared any of the 49 exhibits with anyone other than his attorneys and their staff; and 5. Which, if any, of the alleged 49 exhibits Epstein plans to testify about at trial. Epstein may avoid questions on this topic if there is a stipulation on the record that he is not testifying at the upcoming trial or, if testifying, not planning on testifying about any of the 49 exhibits. Epstein's deposition shall be conducted in this matter at the same time his deposition is conducted in the bankruptcy proceeding. Epstein's counsel may assert objections, as appropriate, including attorney-client privilege, work product and Fifth Amendment objections. Epstein's answering of any specific question as ordered, however, will not be raised or relied upon in this matter or any other by Edwards or any Intervenors, nor construed by this Court, as a waiver of his attorney-client privilege, work product or his Fifth, Sixth and Fourteenth Amendment Rights as guaranteed by the United States Constitution and Article I, Sections 2, 9 and 16 of the Florida Constitution with respect to any other question asked of him or to any subject matter relating to any answers Epstein may provide at this deposition. 2 EFTA00807766 Order Granting Bradley J. Edwards' Motion to Take Limited Deposition ofJeffrey Epstein Epstein v. Rothstein, Edwards and L.M. Case No.: 502009CA040800YOMMBAG 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 Bradley J. Edwards, Esquire Edwards Pottin er LLC 425 N Andrews Avenue, Suite 2 01 Attorneys for Defendant/Counter-Plaintiff Bradley J. Edwards Jack A. Goldber er, Esquire Atterbury Goldberger & Weiss, P.A. 3 EFTA00807767 Order Granting Bradley J. Edwards' Motion to Take Limited Deposition of Jeffrey Epstein Epstein v. Rothstein, Edwards and L.M. Case No.: 502009CA040800YOOOCMBAG 250 Australian Avenue S, Suite 1400 West Palm Beach, FL 33401 Phone: (561) 659-8300 Fax: (561) 835-8691 Attorneys for Plaintiff/Counter-Defendant Jeffrey Epstein Nichole J. Segal, Esquire Philip M. Burlington Burlington & Rockenbach, 444 W Railroad Avenue, Suite 350 West Palm Beach, FL 33401 Phone: Attorneys for Defendant/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 33401 Attorneys for Plaintiff/Counter-Defendant Jeffrey Epstein Marc S. Nurik, Esquire Law Offices of Marc S. Nurik One E Broward Blvd., Suite 700 Fort Lauderdale, FL 33301 orneys or e en an cott Rothstein Paul Cassell, Esquire 383 S. University Salt Lake City, UT 84112-0730 l iWineysorRillervenors L.M., E.W. and Jane Doe EFTA00807768 Order Granting Bradley J. Edwards' Motion to Take Limited Deposition ofJeffrey Epstein Epstein v. Rothstein, Edwards and M. Case No.: 502009CA040800YOOOCMBAG 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 EFTA00807769