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Accordingly, and as demonstrated more fully below, denial of Edwards's Motion for Protective Order is mandated. MEMORANDUM OF LAW Rule 1.280(c) of the Florida Rules of Civil Procedure affords the Court discretion to grant protective orders "for good cause shown" and "to protect a party from annoyance embarrassment, oppression, or
d factually deficient Motion for Protective Order. In support thereof, Epstein states: INTRODUCTION On or about January 9, 2013, Edwards filed his Fourth Amended Counterclaim against Epstein, asserting therein that he suffered the following damages: "a) injury to his reputation; b) mental anguish, embarrassm
ttr-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to §768.79 of the Florida Statutes and Rule 1.442 of the Florida Rules of Civil Procedure, hereby files this Motion requesting that the Court enter an Order of entitlement to costs and attorneys' fees against Defendant/Counter- Plaintiff
n. Epstein subsequently dismissed his Complaint without prejudice. The counter- claim proceeded, undergoing several amendments. As it now stands, the Fourth Amended Counterclaim has two causes of action: abuse of process and malicious prosecution. Epstein moved for summary judgment arguing that the litigation p
NG MEMORANDUM OF LAW Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.510 of the Florida Rules of Civil Procedure, hereby files this Motion for Summary Judgment on the sole remaining count of Defendant/Counter-Plaintiff Bradley Edwards's ("Edwards") Fourth Amen
n. Epstein subsequently dismissed his Complaint without prejudice. The counter- claim proceeded, undergoing several amendments. As it now stands, the Fourth Amended Counterclaim has two causes of action: abuse of process and malicious prosecution. Epstein moved for summary judgment arguing that the litigation p
Entities connected to both the Florida Rules of Civil Procedure and Fourth Amended

Bradley Edwards
PERSON
Jeffrey Epstein
PERSONScott Rothstein
PERSONJack Scarola
PERSONJack Goldberger
PERSONMaria Farmer
PERSONTonja Haddad Coleman
PERSONAtterbury
ORGANIZATION
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATIONJane Doe
PERSON
Scarlett Johansson
PERSONPalm Beach Lakes Blvd
LOCATIONMarc Nurik
PERSON
Kenneth Marra
PERSONSearcy Denney Scarola
PERSON
George W. Bush
PERSONPalm Beach Lakes Boulevard
LOCATION
Donald Trump
PERSONTONJA HADDAD
ORGANIZATIONTHE CIRCUIT COURT
ORGANIZATION