Epstein Secrets

-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

n appeal must govern the case in the same court and the trial court, through all subsequent stages of the proceedings." Florida Dept. of Transp. v. Juliano, 801 So.2d 101, 105-06 (Fla. 2001) (citing Greene v. Massey, 384 So.2d 24, 28 (Fla. 1980) ("All points of law which have been adjudicated become th

rejected it and approved this Court's ruling on that issue, and "the facts on which this decision [was] based continue to be the facts of the case." Juliano, 801 So.2d at 106. Therefore, the law of the case doctrine binds this Court to follow the Fourth District's holding (and therefore this Court's pri

HE COURT: Let's go ahead and proceed with the substance of the motion and we will go from there, please. MS. HADDAD COLEMAN: Good morning, Judge. Jeffrey Epstein's motion for summary judgment is based on a very simple issue that was not addressed by this Court in a Palm Beach Reporting Service, Inc. 561-471-2

12 13 14 15 16 17 18 19 20 21 22 23 24 25 THE COURT: We have various motions on the Edwards counterclaim that was brought against Mr. Epstein relative to the remaining count of malicious prosecution. I have read as much as the materials that someone can sit down and read for the better

id, I would like to begin with Plaintiff/Counter-Defendant Epstein's motion for summary judgment on Defendant/ Cou

H COUNTY, FLORIDA Case No. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, indiv

he Edwards counterclaim that was brought against Mr. Epstein relative to the remaining count of malicious pro

e this court should not be entertaining the merits of this. The law is determined by the Fourth District and under the law and case doctrine. And Juliano is the Florida Supreme Court case that establishes that any determination of law made by an appellate court is binding through all subsequent pro

PLAINTIFF/COUNTER-DEFENDANT'S RESPONSE IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' MOTION TO STRIKE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT ON THE FOURTH AMENDED COUNTERCLAIM AND SUPPORTINGMEMORANDUM OF LAW Plaintiff/Counter-Defendant Jeffrey Epstein, by and

UCTION Edwards's Motion to Strike is based solely upon his erroneous argument that this Court's consideration of the probable cause issue raised in Epstein's Motion for Summary Tonga Haddad. P.A. • 315 SE 7th Street, Fon Lauderdale, FL 33301. EFTA00808559 Judgment is batted by the law of the case doc

IRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. BRADL

or judicial proceeding . . ."). Accordingly, Edwards's Motion to Strike should be denied on the grounds of both the law of the case and estoppel. B. Epstein Did Not "Actually Present" to the Fourth District Court of Appeal the Issue of Probable Cause The positions Edwards now takes in his Motion to Stri

doctrine is limited to those questions of law that were "actually presented" and "actually decided" on a former appeal. Florida Dep't of Transp. v. Juliano, 801 So. 2d 101, 105-06 (Fla. 2001). The doctrine allows the trial court, upon remand from the appellate court, to consider a party's alternative a

ousing Unit ("SHU"), even though he did not conduct those counts. Id. ¶¶ 16, 30, 36, 38, 40. During that time period, one of the inmates in the SHU—Jeffrey Epstein—hanged himself in his cell. Id. ¶q 1, 26-27. Thomas now moves to compel the Government to produce evidence in connection with the trial scheduled t

3. Thomas seeks three categories of information: (1) "[t]re report of the Inspector General" for the United States Department of Justice related to Epstein's death, and "any and all supplemental memorandums, written statements, photos, videos, and incident reports" obtained by the Inspector General's i

that time period, one of the inmates in the SHU—Jeffrey Epstein—hanged himself in his cell. Id. ¶q 1, 26-

a defendant must make a "particularized showing that materials exist requiring disclosure" in order to sustain a motion to compel. United States v. Juliano, No. 99 Cr. 1197, 2000 WL 640644, at *2 (S.D.N.Y. May 18, 2000); see United States v. Evanclzik, 413 F.2d 950, 953 (2d Cir. 1969) ("[T]he assurance

ousing Unit ("SHU"), even though he did not conduct those counts. Id. ¶¶ 16, 30, 36, 38, 40. During that time period, one of the inmates in the SHU—Jeffrey Epstein—hanged himself in his cell. Id. ¶q 1, 26-27. Thomas now moves to compel the Government to produce evidence in connection with the trial scheduled t

3. Thomas seeks three categories of information: (1) "[t]re report of the Inspector General" for the United States Department of Justice related to Epstein's death, and "any and all supplemental memorandums, written statements, photos, videos, and incident reports" obtained by the Inspector General's i

that time period, one of the inmates in the SHU—Jeffrey Epstein—hanged himself in his cell. Id. ¶q 1, 26-

a defendant must make a "particularized showing that materials exist requiring disclosure" in order to sustain a motion to compel. United States v. Juliano, No. 99 Cr. 1197, 2000 WL 640644, at *2 (S.D.N.Y. May 18, 2000); see United States v. Evanclzik, 413 F.2d 950, 953 (2d Cir. 1969) ("[T]he assurance

ousing Unit ("SHU"), even though he did not conduct those counts. Id. ¶¶ 16, 30, 36, 38, 40. During that time period, one of the inmates in the SHU—Jeffrey Epstein—hanged himself in his cell. Id. ¶q 1, 26-27. Thomas now moves to compel the Government to produce evidence in connection with the trial scheduled t

3. Thomas seeks three categories of information: (1) "[t]re report of the Inspector General" for the United States Department of Justice related to Epstein's death, and "any and all supplemental memorandums, written statements, photos, videos, and incident reports" obtained by the Inspector General's i

that time period, one of the inmates in the SHU—Jeffrey Epstein—hanged himself in his cell. Id. ¶q 1, 26-

a defendant must make a "particularized showing that materials exist requiring disclosure" in order to sustain a motion to compel. United States v. Juliano, No. 99 Cr. 1197, 2000 WL 640644, at *2 (S.D.N.Y. May 18, 2000); see United States v. Evanclzik, 413 F.2d 950, 953 (2d Cir. 1969) ("[T]he assurance

PLAINTIFF/COUNTER-DEFENDANT'S RESPONSE IN OPPOSITION TO: DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' MOTION TO STRIKE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT ON THE FOURTH AMENDED COUNTERCLAIM AND SUPPORTINGMEMORANDUM OF LAW Plaintiff/Counter-Defendant Jeffrey Epstein respect

49 Introduction Edwards' motion to strike is based solely upon his argument that this Court's consideration of the probable cause issue raised in Epstein's motion for summary judgment is barred by the law of the case doctrine. Edwards argues that the probable cause issue was raised by Epstein as a po

IRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. BRADL

octrine is limited to those questions of law that were "actually presented" and "actually decided" on a former appeal." Florida Dep't of Transp. v. Juliano, 801 So. 2d 101, 105-06 (Fla. 2001). The doctrine allows the trial court upon remand from the appellate court to consider a party's alternative arg

ousing Unit ("SHU"), even though he did not conduct those counts. Id. ¶¶ 16, 30, 36, 38, 40. During that time period, one of the inmates in the SHU—Jeffrey Epstein—hanged himself in his cell. Id. ¶q 1, 26-27. Thomas now moves to compel the Government to produce evidence in connection with the trial scheduled t

33. Thomas seeks three categories of information: (1) "Nile report of the Inspector General" for the United States Department of Justice related to Epstein's death, and "any and all supplemental memorandums, written statements, photos, videos, and incident reports" obtained by the Inspector General's i

that time period, one of the inmates in the SHU—Jeffrey Epstein—hanged himself in his cell. Id. ¶q 1, 26-

a defendant must make a "particularized showing that materials exist requiring disclosure" in order to sustain a motion to compel. United States v. Juliano, No. 99 Cr. 1197, 2000 WL 640644, at ■2 (S.D.N.Y. May 18, 2000); see United States v. Evanchik, 413 F.2d 950, 953 (2d Cir. 1969) ("[T]he assurance b