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80119-MARRA-JOHNSON JANE DOE NO. 2, Plaintiff, V. JEFFREY EPSTEIN, Defendant. _____________ / 0 DEFENDANT EPSTE
ocket 05/06/2010 Page 2 of 31 Jane Doe No. 2 v. Epstein Case No. 08-CV-80119-Marra-Johnson Page 2 in m
f Count III, Plaintiff "demands judgment against Jeffery Epstein for all damages available under 18 U.S.C. §2255(a
JEFFREY EPSTEIN, Defendant. _____________ / 0 DEFENDANT EPSTEIN'S MOTION FOR SUMMARY JUDGMENT, INCLUDING SUPPORT
8691 [email protected] Counsel for Defendant Jeffrey Epstein Case 9:08-cv-80119-KAM Document 539
itled to judgment as a matter of law. Celotex v. Catrett, 477 U.S. 317, 106 S.Ct. 2548, 2552, 91 L.Ed.2d 2
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. BRADLEY J. EDWARDS, et al., Defendant/Counter-Plaintiffs. No. 50 2009 CA 040800XXXXMBAG JUDGE HAFELE MOTION F
unter Plaintiff Bradley J. Edwards' malicious prosecution claim fails as a matter of law on an essential element: the absence of probable cause for Epstein's underlying lawsuit. The Court has yet to hear argument from the parties on the issue of probable cause. Oral argument is therefore respectfully r
e of these potentially explosive facts, putative defendant Epstein had allegedly offered $200,000,000.00 for settle
IRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. BRADL
essential element of a party's cause of action necessarily renders all other facts offered by the non-moving party immaterial. See Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). "Just because conflicting evidence exists does not mean probable cause is a jury question." C.A. Hansen Corp. v. Wicker
udgment, pursuant to Rule 56, Federal Rules of Civil Procedure, and states: I. STATEMENT OF UNCONTROVERTED FACTS I. On or about September 24, 2007, Jeffrey Epstein entered into a Non-Prosecution Agreement with the United States Attorney's Office for the Southern District of Florida. 2. On or about October 29,
of felony procurement of a minor to engage in prostitution in the Circuit Court, Fifteenth Judicial Circuit, in and for Palm Beach County, Florida. Epstein was sentenced the same date, and is currently imprisoned in Palm Beach County, Florida. 4. Jeffrey Epstein has not had any federal criminal charges
OVERTED FACTS I. On or about September 24, 2007, Jeffrey Epstein entered into a Non-Prosecution Agreement
establish the existence of an element essential to the party's case, and on which the party will bear the burden of proof at trial. Celotex Corp. I Catrett , 477 U.S. 317, 321 (1986). At the summary judgment stage, the district court's task is to determine if there is no genuine issue as to any materia
Case No. 50 2009 CA 040800XXXXMBAG VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' COUNTERCLAIM AND SUPPORTING MEMORANDUM OF LAW Plaintiff/Counter-Defend
DGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' COUNTERCLAIM AND SUPPORTING MEMORANDUM OF LAW Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.510 of the Florida Rules of Civil Procedure, files this Motion for Summary Judgmen
CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1
mplete failure of proof of an essential element necessarily renders all other facts offered by the non-moving party immaterial. See Celotex Corp. v. Catrett, 477 U.S. 317, 323 (1986). B. SUMMARY JUDGMENT SHOULD BE ENTERED IN FAVOR OF EPSTEIN ON EDWARDS' COUNTERCLAIM FOR ABUSE OF PROCESS BECAUSE EDWARD
epositions, answers to interrogatories and reasonably inferred, for the purpose of these motions, are as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls, including Petitioners Jane Doe 1 and Jane Doe 2 (hereinafter, "Petitioners"), at his mansion in Palm Beac
Page: EFTA00010507 →re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls
Page: EFTA00010507 →er, "DE 407" at 1 1.) Because EFTA00010507 --- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit
Page: EFTA00010508 →ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori
Page: EFTA00010510 →epositions, answers to interrogatories and reasonably inferred, for the purpose of these motions, are as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls, including Petitioners Jane Doe 1 and Jane Doe 2 ( hereinafter, "Petitioners"), at his mansion in Palm Bea
Page: EFTA00027666 →re as follows: From between about 1999 and 2007, Jeffrey Epstein sexually abused more than 30 minor girls
Page: EFTA00027666 →er, "DE 407" at 9 1.) Because EFTA00027666 --- PAGE BREAK --- Case 9:08-cv-80736-KAM Document 435 Entered on FLSD Docket 02/21/2019 Page 2 of 33 Epstein and his co-conspirators knowingly traveled in interstate and international commerce to sexually abuse Jane Doe 1, Jane Doe 2 and others, they commit
Page: EFTA00027667 →ern about "the effect of taking the position that Mr. Epstein's house is in the special maritime and territori
Page: EFTA00027669 →Entities connected to both Jeffrey Epstein and Catrett

Bradley Edwards
PERSON
United States
LOCATIONJack Goldberger
PERSONJane Doe
PERSON
Martha Stewart
PERSON
Department of Justice
ORGANIZATION
Kenneth Marra
PERSON
Alexander Acosta
PERSONFBI
ORGANIZATION
Jay Lefkowitz
PERSON
Palm Beach
LOCATIONScott Rothstein
PERSON
Ken Starr
PERSONJack Scarola
PERSON
the United States District Court
ORGANIZATION
Barry Krischer
PERSONAtterbury Goldberger & Weiss
ORGANIZATION
Jeffrey Marc Herman
PERSONPalm Beach Lakes Blvd
LOCATIONU.S. Attorney's Office
ORGANIZATION