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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
on for misconduct!" Id. at 593 (quoting Levin, 639 So. 2d at 608). 15 EFTA00589635 Appellant correctly acknowledges that in Echevarria, Mc Calla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007) the Florida Supreme Court not only reaffirmed the Levin decision but also expanded it to 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
bsequent civil action for misconduct?" Id. at 593 (quoting Levin, 639 So. 2d at 608). Appellant correctly acknowledges that in Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007) the Florida Supreme Court 15 EFTA00714938 not only reaffirmed the Levin decision but als
COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, VS. SCOT
S. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter- Plaintiffs. ORDER GRANTING PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JU DGMENT THIS CAUSE came before the court on Plaintiff/Counter-Defendant Jeffrey Epstein's Motion for Summary Judgment as to D
ving heard argument of counsel, and being otherwise duly advised in the premises, finds and decides as follows: In December 2009, Jeffrey Epstein ("Epstein") filed suit against Scott Rothstein ("Rothstein") and Bradley J. Edwards ("Edwards"). In response to Epstein's lawsuit, Edwards filed a Counterclai
iled and were related to the judicial proceedings, both causes of action were completely barred. Id. (emphasis added); see also Echevarria, McCalla, Raymer, Barrett &Frappier v. Cole, 950 So. 2d 380 (F1a.2007); Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, M. v. U.S. Fire Ins. Co., 639 So. 2d 6
TIEFEL,WILLIAM SMITH,HAROLD B COLE,JEFFREY A BRAUER,CAMILLA T LUBOTTA,JACK
OBERT A THE BREAKERS PALM BEACH INC EPSTEIN,JEFFREY TIEFEL,WILLIAM R MCCLOSKEY,
STEPHAICH,LOUISE TORREY,DAVID L RAYNER,WILLIAM DERRIN,SCOTT J 210 VIA DEL
adings and discovery responses, and as conceded by Edwards's counsel at oral argument, the events giving rise to Edwards's purported claims against Epstein occurred solely in the course of, and were related to, the litigation, just as occurred in the Wolfe case, mandating Summary Judgment. Wolfe v. For
bsequent civil action for misconduct?" Id. at 593 (quoting Levin, 639 So. 2d at 608). Appellant correctly acknowledges that in Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007) the Florida Supreme Court 15 EFTA00613604 not only reaffirmed the Levin decision but als
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 →Epstein. Sexual Abuse of Children By Epstein 1. Defendant Epstein has a nexual preference for young children. Depos
Page: HOUSE_OVERSIGHT_013319 →al complaint with obstruction of justice in eanneetinn with trying to obtain $50,000 from civil attorneys pursuing civil sexual assault cases against Rpatein as payment for producing the book to the attorneys. See Criminal Complaint at 4, US. v. Rodriguez, No. 9:10-CR-80015-KAM (S.D. Fla. 2010) (Exhibit “G
Page: HOUSE_OVERSIGHT_013327 →Entities connected to both Jeffrey Epstein and Raymer

Ghislaine Maxwell
PERSON
George Mitchell
PERSON
George W. Bush
PERSON
Donald Trump
PERSON
Bradley Edwards
PERSON
JPMorgan Chase
ORGANIZATIONJack Goldberger
PERSON
Sarah Kellen
PERSONJane Doe
PERSON
Michael Cohen
PERSONMaria Farmer
PERSON
Virginia Giuffre
PERSON
Bill Richardson
PERSON
Jay Lefkowitz
PERSON
David Rodgers
PERSON
Palm Beach
LOCATION
Scarlett Johansson
PERSONDoug Band
PERSON
Michael Jackson
PERSONScott Rothstein
PERSON