IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, vs. Plaintiff/Counter-Defendant, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OMNIBUS MOTION IN LIMINE Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, herein moves for an Order in Limine precluding Defendant/Counter-Plaintiff Bradley Edwards ("Edwards") and his Counsel from making any mention or use of the below-listed items/matters/witness testimony at trial'. In support thereof, Epstein states: INTRODUCTION The pleadings in this matter establish that Mr. Edwards is intent on avoiding the actual facts he must prove to establish his sole remaining claim of Malicious Prosecution against Mr. Epstein. Instead, Edwards is seeking to present to the jury prior alleged bad acts of Epstein, completely separate and apart from the accusation made against Epstein in this lawsuit. Plaintiff has no evidence, nor can he prove, that Mr. Epstein lacked probable cause at the time he filed his lawsuit against Mr. Edwards. In its place, Edwards is creating a different case that relates, not to 1 This Motion only includes items known to Epstein as of the date of filing this Motion pursuant to this Court's Order in open Court on September 15, 2017, as them are still outstanding Discovery Motions and depositions scheduled for which an order in limine precluding evidence may be required. EFTA00585420