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ne issue as to any material facts and that Bradley J. Edwards, Esq. is entitled to summary judgment for all claims brought against him in Plaintiff Jeffrey Epstein's Complaint. Not only is there an absence of competent evidence to demonstrate that Edwards participated in any fraud against Epstein, the evidence un
intiff Jeffrey Epstein's Complaint. Not only is there an absence of competent evidence to demonstrate that Edwards participated in any fraud against Epstein, the evidence uncontrovertibly demonstrates the propriety of every aspect of Edwards' involvement in the prosecution of legitimate claims against E
inafter "Epstein Depo.") at 67-68. Therefore summary judgment should be granted for Edwards on all claims involving any Ponzi scheme by Rothstein. b. Epstein Did Not Suffer Any Harm from Allegedly Fraudulent Presentations to Investors. 7 EFTA00725975 At various points in his Complaint, Epstein seems t
, Plaintiff, vs. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S MOTION FOR SETTLEMENT CONFERENCE, OR IN THE AL
Y, FLORIDA Case No.: 50 2009 CA 0408003OOOCMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv
ction may not invoke the fifth amendment and refuse to comply with the defendant's discovery requests, thereby thwarting the defendant's defenses." Rollins Burdick Hunter of New York Inc. v. Euroclassic Limited, Inc., 502 So. 2d 959 (Fla. 3"I Dist. Court App. 1983). Here, Epstein is trying to do precisely what the "w
mmary judgment in the Ponzi Scheme Action. SJ Motion at 1 (Edwards "is entitled to summary judgment for all claims brought against him in Plaintiff Jeffrey Epstein's Complaint" because "the evidence uncontrovertibly demonstrates the propriety of every aspect of Edwards' involvement in the prosecution of legitimat
alternative sources before it may be subpoenaed from any non-party in New York. In fact, Edwards concedes in his own Florida court filings that the Epstein interview is, at best, cumulative of "overwhelming evidence" he has already obtained from several alternative sources. Second, even if Edwards were
made of a confidential unpublished interview of Jeffrey Epstein. PRELIMINARY STATEMENT In this ancillar
d not, publish the information imparted to me by Mr. Epstein during the interview. Rush Supp. Aft 17 (emphasi
o. Nov. 12, 1992) 24, 26 People v. Royster, 43 .U1758, 842 ad 12 (1st Dep't 2007) 26 Pugh v. Avis Rent A 1997 WL 669876 ( Oct. 28, 1997) 27 Rollins Burdick Hunter of N. Y., Inc. v. Euroclassics Ltd., 502 So.2d 959 (Fla. Dist. Ct. App. 1983) 21 Russman v. Bd. of Ed., 260 F.3d 114 (2d Cir. 2001) 13 S&I Inve
position to PlaintifUCounter-Defendant Jeffrey Epstein's Motion for Temporary Stay of Proceedings, and as grounds therefor states as follows: un 5 ana Jeffrey Epstein initiated this litigation in 2009. For three years, he carried the burden of proof to establish that Bradley Edwards had fabricated his clients' sex
n 2009. For three years, he carried the burden of proof to establish that Bradley Edwards had fabricated his clients' sexual assault claims against Epstein, in furtherance of a Ponzi scheme. Substantial discovery was taken by both parties. In 2012, Epstein voluntarily dismissed his complaint, and the so
DCA 2010) (stating that, in the context of arbitration, a party's "active participation in litigation" serves to waive the right to arbitration). b. Epstein is Estopped from Seeking a Stav/Continuance. Epstein's attempt to stay/continue this case is also barred by the doctrine of equitable estoppel, whi
UNTY, FLORIDA CASE NO.: 502009CA040800)OOOCMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv
ent. 994 So. 2d at 478. Moreover, "[a] civil litigant's fifth amendment right to avoid self-incrimination may be used as a shield but not a sword." Rollins Burdick Hunter of New York, Inc. v. Euroclassics Ltd., Inc., 502 So. 2d 959, 962 (Fla. 3d DCA 1987). Thus, "where the party claiming a Fifth Amendment privilege i
ugh his undersigned counsel, hereby submits this Response in Opposition to Plaintiff/Counter-Defendant Jeffrey Epstein’s Motion for Summary Judgment. Epstein seeks Summary Judgment on the claims of abuse of process and malicious prosecution set forth in Brad Edwards’ Fourth Amended Counterclaim. Each of th
Page: HOUSE_OVERSIGHT_013304 →action may not invoke the fifth amendment and refuse to comply with the defendant’s discovery requests, thereby thwarting the defendant’s defenses.” Rollins Burdick Hunter of New York, Inc. v. Euroclassic Limited, Inc., 502 So. 2d 959 (Fla. 3d DCA 1983).. For the same reasons, Epstein should be precluded from advancing
Page: HOUSE_OVERSIGHT_013316 →Epstein. Sexual Abuse of Children By Epstein 1. Defendant Epstein has a nexual preference for young children. Depos
Page: HOUSE_OVERSIGHT_013319 →Entities connected to both Jeffrey Epstein and Rollins Burdick Hunter

Ghislaine Maxwell
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSONJane Doe
PERSONMaria Farmer
PERSONMartin Weinberg
PERSON
Kenneth Marra
PERSON
Bill Clinton
PERSON
Paul Cassell
PERSON
Bill Richardson
PERSON
Mark Epstein
PERSONScott Rothstein
PERSONJack Scarola
PERSON
Bernie Sanders
PERSONTommy Mottola
PERSONTonja Haddad Coleman
PERSON
Al Gore
PERSON