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not one of which is either a Malicious Prosecution case or a case in which Edwards was counsel 
of record. 
Moreover, the above-mentioned witnesses do not have personal knowledge of this matter 
as required by § 90.604 of the Florida Statutes, which states in pertinent part that "a witness may 
not testify to a matter unless evidence is introduced which is sufficient to support a finding that 
the witness has personal knowledge of the matter." § 90.401 Fla. Stat. (2014). Likewise, the 
Collateral Matter Rule states that litigation of purely collateral matters for the sole purpose of 
impeaching a party or witness is improper. Dempsey v. Shell Oil Co., 589 So. 2d 373, 377 (Fla. 
4th DCA 1991). A matter is considered collateral if it is not material and would not be admitted 
for any purpose other than the contradiction. Id. Thus, unless these witnesses have knowledge 
and can speak to what Epstein believed when he filed suit against Edwards, their testimony 
would be irrelevant and collateral. Nearly all of the witnesses listed by Edwards were involved 
in other cases, including the criminal case, against Epstein; cases that have no bearing on the 
issues in this matter. Accordingly, any information and testimony about such cases would be 
collateral and inadmissible. 
As such, Epstein seeks to exclude testimony from the following witnesses, as any 
testimony to be offered by these witness would be irrelevant, misleading, confusing, and 
prejudicial, as they lack any knowledge regarding the issue at hand in this matter; to wit: whether 
or not Jeffrey Epstein had the requisite cause to file suit against Edwards for his actions taken in 
cases Edwards and RRA were prosecuting against Epstein when the same cases were known to 
have been used by Rothstein and other then unnamed partners at RRA to perpetuate, and further, 
RRA's Ponzi Scheme: 
2. 
21 
Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301
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3. 
4. 
5. 
6. 
7. 
8. Detective 
9. Chief 
10. John Connolly 
II. Charles Lichtman, Esquire 
12. Antonio Figueroa (Tony) 
13. Records Custodian of Palm Beach Police Department 
14. Records Custodian of United States Attorney's Office for the Southern District of Florida 
15. Records Custodian of the Federal Bureau of Investigations 
16. Spencer Kuvin, Esquire 
17. Theodore Leopold, Esquire 
18. Rinaldo Rizzo 
19. Adam Horowitz, Esquire 
20. Isidro M. Garcia, Esquire 
21. All of the Lawyers who Represented Victims of Jeffrey Epstein. This is so overbroad 
that Epstein cannot possibly make a determination as to whether or not he seeks to 
exclude anything under this blanket witness identification. 
As stated above, allegations in a different lawsuit against a defendant are not relevant and 
are highly prejudicial under § 90.403 of the Florida Statutes. See Long Term Care Found., Inc. v. 
Martin, 778 So. 2d 1100, 1102-03 (Fla. 5th DCA 2001). Likewise, "[i]t is inconsistent with the 
notions of fair trial for the state to force a defendant to resurrect a prior defense against a crime 
for which the defendant is not on trial." Jacobs v. Ad. Coast Ref, Inc., 165 So. 3d 714 (Fla. 4th 
DCA. 2015) (finding that "because the prior case was settled, none of the allegations therein 
were proven."). Accordingly, because not one of these witnesses has facts or information 
germane to this litigation between Epstein and Edwards, and Edwards's sole purpose in calling 
22 
Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301
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them to testify is to illicit testimony of other allegations made against Epstein, they should be 
precluded from testifying. 
G. 
Testimony or evidence that Epstein Settled Prior or Subsequent Claims, Suits, or 
Settlements, Including the Amounts Thereof for Plaintiffs Not Represented by Edwards. 
Pursuant to § 90.408 of the Florida Statutes, "[e]vidence of an offer to compromise a 
claim which was disputed as to validity or amount, as well as any relevant conduct or statements 
made in negotiations concerning a compromise, is inadmissible to prove liability or absence of 
liability for the claim or its value." § 90.408 FLA. STAT. (2016). The meaning of this statute is 
equally clear; to wit: "[n]o evidence of settlement is admissible at trial on the issue of liability." 
Saleeby v. Rocky Elson Const., Inc., 3 So. 3d 1078, 1083 (Fla. 2009). "[I]t is a practical 
impossibility to eradicate from the jury's minds the considerations that where there has been a 
payment there must have been liability." City of Coral Gables v. Jordan, 186 So. 2d 60, 63 (Fla. 
3d DCA 1966) ("The public policy of this state favors amicable settlement of disputes and the 
avoidance of litigation. This policy is implemented by excluding evidence of an offer to 
compromise and a release or covenant not to sue tort feasors."). While the disposition of the 
cases that Edwards was prosecuting against Epstein on behalf of three plaintiffs may in certain 
limited respects be germane to this litigation, as evidence, for example, to establish the absence 
of any damages of Edwards, any other settlements are not. 
As seen from Edwards's trial witness list, and his exhibit list items above, it is apparent 
that he intends to use as much information from other cases as possible solely to impermissibly 
"inflame[] the jury or appeal[] improperly to the jury's emotions,"' or "solely to prove bad 
character." Wright v. State, 19 So. 3d 277 (Fla. 2009); Byrd v. BT Foods, Inc., 26 So. 2d 600 
(Fla. 4th DCA 2009). "(I)f the introduction of the evidence tends in actual operation to produce a 
confusion in the minds of the jurors in excess of the legitimate probative effect of such evidence 
23 
Tonja Haddad, P.A. • 315 SE 7'h Street, Fort Lauderdale, FL 33301
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if it tends to obscure rather than illuminate the true issue before the jury then such evidence 
should be excluded." City of Miami v. Calandro, 376 So. 2d 271, 272 (Fla. 3d DCA 1979) 
(citing Perper v. Edell, 44 So. 2d 78 (Fla. 1949)). See also Agrofollajes, S.A. v. E.I. Du Pont De 
Nemours & Co., Inc., 48 So. 3d 976 (Fla. 3d DCA 2010) (probative value outweighed by 
prejudicial effect when evidence improperly becomes focus of trial); Maldonado v. Allstate Ins. 
Co., 789 So. 2d 464 (Fla. 2d DCA 2001) (probative value of bicyclist's status as an illegal alien 
was outweighed by unfair prejudice, confusion of the issues, and misleading of the jury, as the 
evidence and instruction concerning status as an illegal alien improperly changed the focus of the 
jury's attention). 
CONCLUSION 
For the reasons stated above, and in reliance upon the applicable law cited herein, Jeffrey 
Epstein respectfully requests that this Court enter an Order in Limine precluding Bradley J. 
Edwards, his counsel, and his witnesses from making any argument, statement, evidence, or 
comment, as well as precluding from use at trial, the items/witnesses/arguments listed above. 
WE HEREBY CERTIFY that a true and correct copy of the foregoing was served, via 
electronic service, to all parties on the attached service list, this September 25, 2017. 
/s/ Tonja Haddad Coleman 
Tonja Haddad Coleman, Esq. 
Florida Bar No.: 176737 
Tonja Haddad, PA 
5315 SE Th Street 
Suite 301 
Fort Lauderdale, Florida 33301 
(facsimile) 
Attorneys for Epstein 
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Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301
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SERVICE LIST 
CASE NO. 502009CA040800XXXXMBAG 
Jack Scarola, Es . 
• 
Searcy Denney Scarola et al. 
2139 Palm Beach Lakes Blvd. 
West Palm Beach, FL 33409 
Jack Goldbe er, Es . 
• 
Atterbury, Goldberger, & Weiss, PA 
250 Australian Ave. South, Suite 1400 
West Palm Beach, FL 33401 
Marc Nurik, Esq. 
I East Broward Blvd., Suite 700 
Fort Lauderdale, FL 33301 
Bradley J. Edward Es 
Es . 
Fanner Jaffe Weissing Edwards Fistos Lehrman 
425 N Andrews Avenue, Suite 2 
Fort Lauderdale, Florida 33301 
Fred Haddad,
1 Financial Plaza, Suite 2612 
Fort Lauderdale, FL 33301 
Ton'a Haddad Coleman 
Law Offices of Tonja Haddad, P.A. 
315 SE 7th Street, Suite 301 
Fort Lauderdale, FL 33301 
W. Chester Brewer, Jr. 
W. Chester Brewer, Jr., P.A. 
250 S. Australian Avenue, Suite 1400 
West Palm Beach, FL 33401 
25 
Tonja Haddad, P.A. • 315 SE 7th Street, Fort Lauderdale, FL 33301
EFTA00802184