Epstein Secrets

OF FLORIDA FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, -VS- SCOTT individually, Intervenors.' ROTHSTEIN, BRADLEY J. individually, and and JANE DOE, Respondents CASE NO. 4D18-0762 RESPONSE TO EMERGENCY PETITION FOR WRIT OF MANDAMUS SEARCY DENNY SCAROLA BARNHART & SHIPLEY, P.A. 2139 Palm Bea

ATE OF SERVICE 29 ii EFTA00808516 TABLE OF AUTHORITIES CASES PAGE Abrams v. Paul, 453 So.2d 826 (Fla. 1st DCA 1984) 17 Alamo Rent-A-Car v. Mancusi, 24 632 So.2d 1352 (Fla. 1994) Bennett v. Continental Chemicals, Inc., 19 492 So.2d 724 (Fla. 1st DCA 1986) Campbell v. Wells Fargo Bank, N.A.

likely default by Rothstein, the identical allegations will be terminated in Epstein's favor, a directly opposite result). See Alamo Rent-A-Car v. Mancusi, 632 So.2d 1352 (Fla. 1994). Thus, Edwards's malicious prosecution claim was not a compulsory counter-claim and would at best be considered a permi

case are Jeffrey Epstein (via video deposition), Bradley Edwards, Scott Rothstein (via video deposition), and Mr. Edwards' clients (L.M., E.W. and Jane Doe). Source: Florida Standard Jury Instruction (Civil) 201.1 Given Given as Modified Denied Withdrawn 5 EFTA00804794 PLAINTIFF/COUNTER-DEFENDA

in's position this will allow the jury to better understand why they are being instructed on probable cause, malice, etc.; Alamo Rent-A-Car Inc. v. Mancusi, 632 So. 2d 1352 (Fla. 1994); Rivernider v. Meyer, 174 So. 3d 602 (Fla. 46 DCA 2015); Hickman v. Barclay's Intl Realty, Inc., 16 So. 3d 154, 155 (Fl

ge female plaintiff. To augment his concocted story, Rothstein invited D3 to his office to view the thirteen banker's boxes of actual case files in Jane Doe in order to demonstrate that the claims against Epstein were legitimate and that the evidence against Epstein was real. In particular, Rothstein cla

dant, and (6) the plaintiff suffered damage as a result of the original proceeding." Fischer, 169 So. 3d at 1206 (quoting Alamo Rent—A—Car, Inc. v. Mancusi, 632 So.2d 1352, 1355 (Fla.1994)). The holding in Fischer was restated in Rivernider v. Meyer, No. 4D14-819, 2015 WL 5244635 (Fla. 4th DCA Sept. 9,

TRICT JEFFREY EPSTEIN, Petitioner, -VS- SCOTT individually, EDWARDS, L.M., E.W., Intervenors. ROTHSTEIN, BRADLEY J. individually, and and JANE DOE, Respondents CASE NO. 4D18-0762 APPENDIX TO RESPONSE TO PETITION FOR WRIT OF MANDAMUS PAGE 1. Non-Prosecution Agreement, dated September 24, 200

, the facts this Court will consider when it determines whether Defendant has proved Plaintiff lacked probable cause. See Alamo Rent-A-Car, Inc. v. Mancusi, 632 So. 2d 1352, 1357 (Fla. 1994) (jury decides disputed issues of fact, but court determines whether those facts establish probable cause) (citati