Epstein Secrets

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

DCA 2013) 12 American Nat. Title & Escrow of Florida, Inc. v. Guarantee Title & Trust, Co., 748 So. 2d 1054 (Fla. 4th DCA 1999) 13 DelMonico v. Traynor, 116 So. 3d 1205 (Fla. 2013) 2, 10, 18, 19 Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007) passim Fridovich

Jewelry, Inc., 2012 WL 4138028 M. Fla. Sept. 19, 2012) (`[t]he decision to file a lawsuit clearly relates to a judicial proceeding'); DelMonico v. Traynor, 116 So.3d 1205, 1217, 1219 (Fla. 2013) (privilege applies when statements or actions occur `either in front of a judicial officer or in pleading o

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

Jewelry, Inc., 2012 WL 4138028 (. Fla. Sept. 19, 2012) (`[t]he decision to file a lawsuit clearly relates to a judicial proceeding'); DelMonico v. Traynor, 116 So.3d 1205, 1217, 1219 (Fla. 2013) (privilege applies when statements or actions occur `either in front of a judicial officer or in pleading o

DCA 2013) 12 American Nat. Title & Escrow of Florida, Inc. v. Guarantee Title & Trust, Co., 748 So. 2d 1054 (Fla. 4th DCA 1999) 13 DelMonico v. Traynor, 116 So. 3d 1205 (Fla. 2013) 2, 10, 18, 19 Echevarria, McCalla, Raymer, Barren & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007) passim Fridovich

-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

DCA 2013) 12 American Nat. Title & Escrow of Florida, Inc. v. Guarantee Title & Trust, Co., 748 So. 2d 1054 (Fla. 4th DCA 1999) 13 DelMonico v. Traynor, 116 So. 3d 1205 (Fla. 2013) 2, 10, 18, 19 Echevarria, McCalla, Raymer, Barren & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007) passim Fridovich

ly, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. Case No. 50 2009 CA 040800XXXXMBAG Judge: CROW PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR ATTORNEYS' FEES PURSUANT TO §57.105 OF THE FLORIDA STATUTES Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his

R-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR ATTORNEYS' FEES PURSUANT TO §57.105 OF THE FLORIDA STATUTES Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to §57.105 of the Florida Statutes, hereby moves this Court for an award of attorneys' fees

CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, Counter-Defendant, vs. SCO

0 So. 2d 380 (Fla.2007); Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994); DelMonico v. Traynor, 2013 WL 535451 (Fla.2013); Am. Nat'l Title & Escrow of Fla. v. Guarantee Title & Trust Co., 748 So.2d 1054, 1055 (Fla. 4th DCA 2000) (affirming th

-Defendant, VS. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter- Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OBJECTION AND RESPONSE TO IMPROPER FILING OF SUPPLEMENTAL AUTHORITY INTRODUCTION In December 2009, Jeffrey Epstein ("Epstein") filed suit against

-DEFENDANT JEFFREY EPSTEIN'S OBJECTION AND RESPONSE TO IMPROPER FILING OF SUPPLEMENTAL AUTHORITY INTRODUCTION 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 Countercla

COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, VS. SCOT

0 So. 2d 380 (Fla.2007); Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994); DelMonico v. Traynor, 2013 WL 535451 (Fla.2013); Am. Nat'l Title & Escrow of Fla. v. Guarantee Title & Trust Co., 748 So. 2d 1054, 1055 (Ha. 4th DCA 2000) (affirming th

S. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter- Plaintiffs. ORDER GRANTING PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT THIS CAUSE came before the court on Plaintiff/Counter-Defendant Jeffrey Epstein's Motion for Summary Judgment as to De

ing 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 Countercla

H COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, VS. SCOT

950 So. 2d 380 (Fla.2007); Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, M. v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994); DelMonico v. Traynor, 2013 WL 535451 (Fla.2013); Am. Nat'l Title & Escrow of Fla. v. Guarantee Title & Trust Co., 748 So.2d 1054, 1055 (Fla. 4th DCA 2000) (affirming th

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

950 So. 2d 380 (F1a.2007); Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, M. v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994); DelMonico v. Traynor, 2013 WL 535451 (Fla.2013); Am. Nat'l Title & Escrow of Fla. v. Guarantee Title & Trust Co., 748 So. 2d 1054, 1055 (Fla. 4th DCA 2000) (affirming t

-Defendant, VS. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter- Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFFS' MOTION FOR RECONSIDERATION INTRODUCTION In December 2009, Jeffrey Epstein ("Epstein") filed suit against Sc

TER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFFS' MOTION FOR RECONSIDERATION INTRODUCTION 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 Countercla

OUNTY, FLORIDA CASE NO. 502009CA0408003OOOCMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, VS. SCOT

950 So. 2d 380 (Fla.2007); Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, M. v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994); DelMonico v. Traynor, 2013 WL 535451 (Fla.2013); Am. Nat'l Title & Escrow of Fla. v. Guarantee Title & Trust Co., 748 So. 2d 1054, 1055 (Fla. 4th DCA 2000) (affirming t

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

The rule of absolute immunity extends to the parties, judges, witnesses, and counsel involved and related to the judicial proceedings. DelMonico v. Traynor, 50 So.3d 4, 7 (Fla. Dist. Ct. App. 2010). The Florida Supreme Court found that absolute litigation immunity was designed to allow a party to `pro

elry, Inc., 2012 WL 4138028 (S.D. Fla. Sept. 19, 2012) (`[t]he decision to file a lawsuit clearly relates to a judicial proceeding'); DelMonico v. Traynor, 116 So.3d 1205, 1217, 1219 (Fla. 2013) (privilege applies when statements or actions occur `either in front of a judicial officer or in pleading o

. Harold E. WOLFE, Jr., et al., Appellants, v. Jeffrey T. FOREMAN, et al., Appellees. No. 3D10-3055. I

... so long as the act has some relation to the proceeding." Echevarria, 950 So.2d at 384 (quoting Levin, 639 So.2d at 608), see also DelMonico v. Traynor, — So.3d 38 Fla. L. Weekly S106, 2013 WL 535451 (Fla.2013) (clarifying that, although not all statements made outside of the formal judicial pro