Filing # 75231691 E-Filed 07/19/2018 04:20:29 PM 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 El., individually, Defendant, RESPONSE IN OPPOSITION TO DEFENDANT JEFFREY EPSTEIN'S MOTION TO COMPEL BRADLEY EDWARDS TO IDENTIFY HIS TRIAL WITNESSES Plaintiff, Bradley J. Edwards, by and through undersigned counsel, hereby files this Response in Opposition to Defendant Jeffrey Epstein's Motion to Compel Bradley Edwards to Identify His Trial Witnesses, and as grounds therefor states as follows: Epstein's Standard for Admissibility of Witness Testimony Although Epstein's Motion concerns the disclosure of trial witnesses, he spend much of his time arguing about the admissibility of potential witness testimony in this malicious prosecution case. In doing so, Epstein concedes that the standard for the admissibility of witness testimony in this case is as follows: [U]nless Edwards' listed witnesses have personal knowledge of the matter at issue and can speak to what Epstein believed when he filed suit against Edwards, the witnesses' testimony would be irrelevant and collateral, and thus, inadmissible, even for purposes of impeachment. Mot. at p. 14 (emphasis added). EFTA00808620