745.pdf

NOT A CERTIFIED COPY JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiff. Electronically Filed 10/04/2013 05:03:10 PM ET IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50 2009 CA 040800XXXXMBAG I ---------------- NOTICE OF E-FILING EXHIBITS Plaintiff/Counter-Defendant Jeffrey Epstein, by and through his undersigned counsel and pursuant to Rule 2.516 of the Florida Rules of Judicial Administration, hereby files his exhibits to Plaintiff/Counter-Defendant Jeffrey Epstein's Motion for Summary Judgment on Defendant/Counter-Plaintiff Bradley Edwards's Fourth Amended Counterclaim and Supporting Memorandum of Law ("Motion"), previously filed and accepted by the Palm Beach County, Florida Civil Division Filing # 5846906. The files accompanying this Notice of Filing Exhibits were previously filed on September 26, 2013 and again on October 2, 2013, but moved to Pending Queue due to procedural issues. This filing is an attempt to correct those procedural issues. The attachment hereto contains the exhibits to the above referenced Motion, which is not being re-filed contemporaneously herewith. However, the exhibits are being divided based upon the filing requirements of the rules of e-filing; each new exhibit begins when so marked on the is so marked on the bottom of the first page of said exhibit. NOT A CERTIFIED COPY Epstein v. Rothstein, et al. WE HEREBY CERTIFY that a true and correct copy of the foregoing was served, via electronic service (through the e-file portal), to all parties on the attached service list, this October 3, 2013. 2 /s/ Tonja Haddad Coleman Tonja Haddad Coleman, Esq. Florida Bar No.: 176737 Tonja Haddad, PA 5315 SE 7' 11 Street Suite 301 Fort Lauderdale, Florida 33301 954.467.1223 9 54 .3 3 7. 3 716 (facsimile) Attorneys for Epstein NOT A CERTIFIED COPY SERVICE LIST CASE NO. 502009CA040800XXXXMBAG Jack Scarola, Esq. jsx@searcylaw.com; mep@searcylaw.com Searcy Denney Scarola et al. 2139 Palm Beach Lakes Blvd. West Palm Beach, FL 33409 Jack Goldberger, Esq. jgoldberger@agwpa.com; smahoney@agwpa.com Atterbury, Goldberger, & Weiss, PA 250 Australian Ave. South Suite 1400 West Palm Beach, FL 33401 Marc Nurik, Esq. 1 East Broward Blvd. Suite 700 Fort Lauderdale, FL 33301 Bradley J. Edwards, Esq. brad@pathtojustice.com Farmer Jaffe Weissing Edwards Fistos Lehnnan 425 N Andrews Avenue Suite 2 Fort Lauderdale, Florida 33301 Fred Haddad, Esq. Dee@FredHaddadLaw.com 1 Financial Plaza Suite 2612 Fort Lauderdale, FL 33301 W. Chester Brewer, Jr., Esq. wcblaw(a}ao I .com; wcbcg@aol.com W. Chester Brewer, Jr., P.A. One Clearlake Centre, Suite 1400 250 Australian Avenue South West Palm Beach, FL 33401 (can't) 3 Epstein v. Rothstein, et al. NOT A CERTIFIED COPY Tonja Haddad Coleman, Esquire Tonja@tonjahaddad.com; efiling@tonjahaddad.com Law Offices of Tonja Haddad, P.A. 315 SE 7th Street, Suite 301 Fort Lauderdale, FL 33301 Attorneys for Jeffrey Epstein 4 Epstein v. Rothstein, et al. NOT A CERTIFIED COPY Summary Form THE FLORIDA BAR Daily News Summary An electronic digest of media coverage of interest to leaders of The Florida Bar compiled each workday by the Public Information and Bar Services Department. Distributed to Board of Governors, section and committee chairs, staff members, Florida Supreme Court justices and selected other persons. For fax/photocopies of full-text articles, contact the Public Information & Bar Services Department at 850/561-5834 or e-mail pubinfo@tlabar.org. Please visit our Web site (http://www.floridabar.org/DIVCOM/PI/PlNewsSummarv.nsff) for links to full text of articles. Nov. 1, 2010 --Legal Profession-- ON HER TOES--Florida Trend, http://www.floridatrend.com, Nov. 1, 2010. Pagel of 4 Not only is Pamela C. Marsh the first woman to be appointed U.S. Attorney for Florida's Northern District, she's also the district's first U.S. Attorney who's a former ballerina. Marsh says she's honored that President Barack Obama picked her to lead the U.S. Attorney's Northern District office, but she says being a woman has less impact on her approach to her job than her ballet experience. Dancing professionally for ballet companies in Seattle and Fort Worth in the mid- 1980s, she says, helped her become a more dogged prosecutor. Marsh manages the district's 36 assistant U.S. attorneys and helps them focus on the department's priorities, including healthcare fraud, drug trafficking and Internet crimes against children. STAYING ATOP THE PILE--Pensacola News Journal/Pensacola Business Journal, http://www.pnj.com, Oct. 31, 2010. The mountain of lawsuits piling up as a result of the BP oil spill could become the largest and most expensive collection of tort damage cases in American legal history. Billions of dollars in damages are at stake as thousands of individuals and business owners sue BP, Transocean and Halliburton. Pensacola attorney Brian Barr is one of four lawyers chosen from a national pool by U.S. District Judge Carl Barbier to guide the damage suits -all consolidated in his court -to trial. Barr's job as a member of the Plaintiffs' Steering Committee's four-person executive council will be to coordinate litigation procedures for hundreds of other lawyers representing individual plaintiffs. --Judiciary-- JU OGE TURNER: PLEASE LET ME BACK ON THE BENCH. NO DECISION EXPECTED FOR WEEKS--Orlando Sentinel, http://www.orlandosentinel.com, Oct. 29, 2010. He admitted breaking campaign-finance regulations, financial-disclosure requirements and tax law, but Orange-Osceola Circuit Judge N. James Turner asked the Judicial Qualifications Commission Thursday [Oct. 28] not to throw him out of office. Turner, 64, was on trial, accused of being a bad judge. Among the many allegations was that he touched women at the Osceola County Courthouse, where he worked, as well as hugged and kissed one deputy clerk several times a day. Turner has been off work since April, when Chief Judge Belvin Perry Jr. suspended him. Testimony concluded Thursday, but there was no immediate verdict. The JQC will produce a written report and forward it to the Florida Supreme Court, which will make the final decision. EXHIBIT L http://www.floridabar.org/DIVCOM/PI/l ffbd43bl28d017852577... 9/25/2013 NOT A CERTIFIED COPY Summary Form --Lawyer Ethics/Legal Discipline-- SCOTT ROTHSTEIN SCANDAL; ONE YEAR LATER--Sun-Sentinel, http://www.sun- sentinel.com, Oct. 31, 2010. Page 2 of 4 Fallout from the largest fraud in South Florida history continues after the dark secret behind Scott Rothstein's success was revealed a year ago this week. The Ponzi schemer now sits in prison with limited contact from the outside world. While Rothstein's name has been wiped from buildings and billboards, the path of financial destruction left in his wake remains. With the one- year anniversary of the scandal, questions still loom. The Florida Bar has investigated 64 complaints against 49 RRA attorneys and all but four attorneys have been cleared by the Bar of any wrongdoing. Rothstein was disbarred. --Civil Justice Issues-- JUDGE: 357 IDLE FORECLOSURE SUITS GONE IN 2 1/2 HOURS--The Bradenton Herald, http://www.bradenton.com, Oct. 30, 2010. The foreclosure case was filed in March 2007. Within a month, all of the parties were served with copies of the suit. Then, nothing. The court case sat idle for the next 3 1/2 years, seemingly forgotten among the thousands of foreclosures clogging the legal system. That was until Thursday, when 12th Circuit Court Judge Paul E. Logan dismissed it for inactivity. In the span of 2 1/2 hours, he threw out 357 foreclosure cases because they had been inactive for at least 10 month