Epstein Secrets

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

ired to prove harm. See, e.g., Bortell v. White Mountains Ins. Group, Ltd., 2 So.3d 1041, 1047 (Fla. 4th Dist. Ct. App. 2009); S & I Investments v. Payless Flea Market, Inc., 36 So.3d 909, 917 (Fla. 4'h Dist. Ct. App. 2010). Epstein was not harmed by Rothstein's misrepresentations to other people that he knew nothing abo

efendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S NOTICE OF PROPOSED JURY INSTRUCTIONS AND VERDICT FORM Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), pursuant to Florida Rule of Civil

PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S NOTICE OF PROPOSED JURY INSTRUCTIONS AND VERDICT FORM Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), pursuant to Florida Rule of Civil Procedure 1.470, files this Notice of Proposed Jury Instructions and Verdict Form. Epstein adopts Defendant/Co

OUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

been sued and who brought a counterclaim against Mr. Epstein. His job is to present his client's side of thing

al damages such as one dollar. Source: Abuse of Process: Valdes v. GAB Robins N. Am. Inc., 924 So. 2d 862 (Fla. 3d DCA 2006); S & I Investments v. Payless Flea Market, Inc., 36 So. 3d 909, 917 (Fla. 4th DCA 2010). Nominal damages are sufficient to recover on an action for abuse of process. See Stole,. v. Levinson, 394

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

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 Investments v. Payless Flea Market, Inc., 36 So.3d 909 (Fla. Dig. Ct. App. 2010) 18 Saxton v. Arkansas Gazette Co., 264 Ark. 133 (1978) 29 Smith v. Moore, 31 III3d 628, 818 2d 603 (2

plaintiff suffered damage.” S & I Investments v. Payless Flea Market, Inc., 36 So.3d 909, 917 (Fla, 4" Dist. Ct. App. 2010)

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

Epstein. Sexual Abuse of Children By Epstein 1. Defendant Epstein has a nexual preference for young children. Depos