Epstein Secrets

-Plaintiff, Bradley J. Edwards, individually, by and through his undersigned counsel, hereby files this Motion to Strike Plaintiff/Counter-Defendant Jeffrey Epstein's Motion for Summary Judgment on the Fourth Amended Counterclaim and Supporting Memorandum of Law, based on the law of the case doctrine. RELEVANT PR

of Law, based on the law of the case doctrine. RELEVANT PROCEDURAL BACKGROUND In the Fourth Amended Counterclaim, Edwards raised two claims against Epstein: 1) abuse of process and 2) malicious prosecution. As to the malicious prosecution claim, Edwards alleged that the filing of the original complaint

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hat I 24 handled the state claims that involved Mr. Epstein 25 when I was in Division B. So I have a signif

t, LLP, 88 So. 3d 240 (FIa. 3d DCA 2011) 3 Levin, Middlebrooks, Moves & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994) passim McCullough v. Kubiak, 4D13-4048 (Feb. 18, 2015) 9, 10 Microbilt Corporation v. Chex Systems, Inc., 2013 WL 6628619 (Dec. 16, 2013) 14 Montejo v. Martin Me

Steinberg argument a part of this case. Further, this Court's recent opinion in McCullough v. Kubiak, 4D13-4048 (Feb. 18, 2015) is instructive. In McCullough, this Court approved the trial court's dismissal of causes of action for both defamation and negligence based upon the litigation privilege. Id. In

BRADLEY J. EDWARDS, Appellant, v. JEFFREY EPSTEIN, Appellee. FOURTH DISTRICT COURT OF APPEAL STATE OF FLORIDA CASE NO.: 4D14-2282 L.T. Case No.: 502009CA040800 I ANSWER BRIEF OF APPELLEE JEFFR

as its finding that the litigation privilege was applicable specifically to Edwards's claims for malicious prosecution and abuse of process against Epstein, constituted issues of law. DelMonico, 116 So. 3d at 1211 (stating the determination of whether the litigation privilege extends to the alleged tor

BRADLEY J. EDWARDS, Appellant, v. JEFFREY EPSTEIN, Appellee. FOURTH DISTRICT COURT OF APP

night, LLP, 88 So. 3d 240 (FIa. 3d DCA 2011) 3 Levin, Middlebrooks, Moves & Mitchell, v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994) passim McCullough v. Kubiak, 4DI3-4048 (Feb. 18, 2015) 9, 10 Microbilt Corporation v. Chex Systems, Inc., 2013 WL 6628619 (Dec. 16, 2013) 14 Montejo v. Martin Me

Steinberg argument a part of this case. Further, this Court's recent opinion in McCullough v. Kubiak, 4D13-4048 (Feb. 18, 2015) is instructive. In McCullough, this Court approved the trial court's dismissal of causes of action for both defamation and negligence based upon the litigation privilege. Id. In

RECEIVED, 2/25/2015 3:10 PM, Clerk, Fourth District Court of Appeal BRADLEY J. EDWARDS, Appellant, v. JEFFREY EPSTEIN, Appellee. / FOURTH DISTRICT COURT OF APPEAL STATE OF FLORIDA CASE NO.: 4D14-2282 L.T. Case No.: 502009CA040800 ANSWER BRIEF OF APPELLEE JEF

as its finding that the litigation privilege was applicable specifically to Edwards's claims for malicious prosecution and abuse of process against Epstein, constituted issues of law. DelMonico, 116 So. 3d at 1211 (stating the determination of whether the litigation privilege extends to the alleged tor

t of Appeal BRADLEY J. EDWARDS, Appellant, v. JEFFREY EPSTEIN, Appellee. / FOURTH DISTRICT COURT O

t, LLP, 88 So. 3d 240 (FIa. 3d DCA 2011) 3 Levin, Middlebrooks, Moves & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994) passim McCullough v. Kubiak, 4D13-4048 (Feb. 18, 2015) 9, 10 Microbilt Corporation v. Chex Systems, Inc., 2013 WL 6628619 (Dec. 16, 2013) 14 Montejo v. Martin Me

Steinberg argument a part of this case. Further, this Court's recent opinion in McCullough v. Kubiak, 4D13-4048 (Feb. 18, 2015) is instructive. In McCullough, this Court approved the trial court's dismissal of causes of action for both defamation and negligence based upon the litigation privilege. Id. In

ieder, 19K) reports, "A deadline has passed without opposition from two parties whose depositions in the bitter lawsuit between disgraced financier Jeffrey Epstein's accused co-conspirator, Ghislaine Maxwell, and an Epstein accuser are set to be made public." According to McClatchy, "The two non-parties in the no

two parties whose depositions in the bitter lawsuit between disgraced financier Jeffrey Epstein's accused co-conspirator, Ghislaine Maxwell, and an Epstein accuser are set to be made public." According to McClatchy, "The two non-parties in the now-settled civil dispute between Maxwell and accuser Virgi

s vehicle, argued briefly with a 59-year-old man, Jeffrey Austin, then returned with a rifle and shot him.

delphia Inquirer <https://www.chicagotribtme.com/coronavirus/ct-nw-cdc-guidlines-covid-masks- 20201111-penwj4sb2ve531qecj3dx4mv14-story.html> (11/11, McCullough, 347K) says that with the EFTA00137121 announcement, the CDC "caught up with the mounting science that shows masks do indeed protect wearers," an

Wieder, 19K) reports, "A deadline has passed without opposition from two parties whose depositions in the bitter lawsuit between disgraced financier Jeffrey Epstein's accused co-conspirator, Ghislaine Maxwell, and an Epstein accuser are set to be made public." According to McClatchy, "The two non-parties in the n

two parties whose depositions in the bitter lawsuit between disgraced financier Jeffrey Epstein's accused co-conspirator, Ghislaine Maxwell, and an Epstein accuser are set to be made public." According to McClatchy, "The two non-parties in the now-settled civil dispute between Maxwell and accuser Virgi

s vehicle, argued briefly with a 59-year-old man, Jeffrey Austin, then returned with a rifle and shot him.

yers of cloth with lower thread counts, in some cases filtering nearly 50% of fine particles less than 1 micron." The Philadelphia Inquirer (11/11, McCullough, 347K) says that with the announcement, the CDC "caught up with the mounting science that shows masks do indeed protect wearers," and, "equally sig

g to Investigate Past Reports of Sexual Abuse The New York Daily News (07/27, Newman) reported that women abused in their youth by prolific predator Jeffrey Epstein on Thursday demanded $600 million from the FBI for allegedly failing to investigate the now-dead financier in the decades before his arrest. The art

filed a notice of claim to the FBI last week, a prerequisite to suing a federal agency. The article quoted Jennifer Freeman, a lawyer representing Epstein victims, who said, "Had the FBI done its job, hundreds of Epstein's sex trafficking victims would have been spared, over the course of 25 years, we

dia Platform to Censor Covid 'Misinformation' • Jeffrey Epstein Victims Plan to Sue FBI for $600M for Fai

ing conspiracy for nearly a quarter of a century,". How the FBI Helps Middle Tennessee School Districts Increase School Safety WKRN (ABC-2) (07/27, McCullough) reported that as students head back to school in the coming days, and with the Covenant School shooting only a few months behind, school districts

federal agencies and officials, including the FBI and the Department of Health and Human Services, from communicating with social-media platforms. Jeffrey Epstein Victims Plan to Sue FBI for $600M for Failing to Investigate Past Reports of Sexual Abuse The New York Daily News (07/27, Newman) reported that wom

filed a notice of claim to the FBI last week, a prerequisite to suing a federal agency. The article quoted Jennifer Freeman, a lawyer representing Epstein victims, who said, "Had the FBI done its job, hundreds of Epstein's sex trafficking victims would have been spared, over the course of 25 years, we

dia Platform to Censor Covid 'Misinformation' • Jeffrey Epstein Victims Plan to Sue FBI for $600M for Fai

ing conspiracy for nearly a quarter of a century,". How the FBI Helps Middle Tennessee School Districts Increase School Safety WKRN (ABC-2) (07/27, McCullough) reported that as students head back to school in the coming days, and with the Covenant School shooting only a few months behind, school districts

Wieder, 19K) reports, "A deadline has passed without opposition from two parties whose depositions in the bitter lawsuit between disgraced financier Jeffrey Epstein's accused co-conspirator, Ghislaine Maxwell, and an Epstein accuser are set to be made public." EFTA01658793 According to McClatchy, "The two non-p

two parties whose depositions in the bitter lawsuit between disgraced financier Jeffrey Epstein's accused co-conspirator, Ghislaine Maxwell, and an Epstein accuser are set to be made public." EFTA01658793 According to McClatchy, "The two non-parties in the now-settled civil dispute between Maxwell an

s vehicle, argued briefly with a 59-year-old man, Jeffrey Austin, then returned with a rifle and shot him.

yers of cloth with lower thread counts, in some cases filtering nearly 50% of fine particles less than 1 micron." The Philadelphia Inquirer (11/11, McCullough, 347K) says that with the announcement, the CDC "caught up with the mounting science that shows masks do indeed protect wearers," and, "equally sig

potential that was fully realized in the mind of Jeffrey Dahmer who flagellated, cannibalized, dismembered

y Press. Kiernan, B. (2007). Blood and Soil: A World History of Genocide and Extermination from Sparta to Darfur. New Haven, Yale University Press. McCullough, M.E. (2008). Beyond Revenge. John Wiley & Sons. Pinker, S. (2011) The Better Angels of Our Nature. New York, Viking Press Wrangham, R.W., & Peters

6/17 Page 2 of 7 3. Attached as Exhibit B is a true and correct copy of an article by Sharon Churcher entitled “Teenage girl recruited by paedophile Jeffrey Epstein reveals how she twice met Bill Clinton,” DAILY MAIL, dated March 5, 2011. 4. Attached as Exhibit C is a true and correct copy of a statement on beha

tos What Marcia Brady Looks Unsecured Loansin 24 hours That Will Leave You Like Now Is Incredible Snapcap.com Speechless Definition History Fanatic McCullough who played on Live and Let Die Bond theme dies aged 72 Remembering his pal Bargain shopper! Dre Barrymore sports colorful silk jacket as she loads u

E FBI to reopen case = Epstein’s Girl Friday http:/Awww.dailym ail.co.uk/news/article- 1363452/Bill-Clinton- 15-year-old-masseuse-|-met-twice-claims-Epsteins-girl.htm! 1/31 HOUSE_OVERSIGHT_014669 --- PAGE BREAK --- Case 1:15-cv-07433-RWS Document 539-2 Filed 01/06/17 Page 3of5 6/15/2016 against sex of