Epstein Secrets

21 22 23 24 25 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800SSSSMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, vs. SCOTT ROTHSTEIN, INDIVIDUALLY and BRADLEY J. EDWARDS, INDIVIDUALLY, Defendants/Counter-Plaintiffs. / PROCE

. . EFTA00617907 2 1 2 1 7 8 9 10 11 12 13 -14 15 16 17 18 19 20 21 22 23 24 25 APPEARANCES: ON BEHALF OF THE PLAINTIFF EPSTEIN: W. CHESTER BREWER, JR., P.A. 250 S. Australian Ave., Suite 1400 West Palm Beach, FL 33401 By: W. CHESTER BREWER, JR. LAW OFFICES OF TONJA HAD

COURT: Thank you. Good morning. This is counter-defendant Epstein's motion for fees and costs pursuant to an offer

COUNTY, FLORIDA CASE NO.: 502009CA040800SSSSMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, vs. SCOT

e record, my name is Chester Brewer. I represent Mr. Epstein. We have with us also representing Mr. Epstein M

te 1400 West Palm Beach, FL 33401 By: W. CHESTER BREWER, JR. LAW OFFICES OF TONJA HADDAD, P.A. 315 S.E. 7th St. Ft. Lauderdale, FL 33301 By: TONJA HADDAD COLEMAN, ESQUIRE ATTERBURY, GOLDBERGER & WEISS, P.A. 250 S. Australian Ave Suite 1400 West Palm Beach, FL 33401 By: JACK GOLDBERGER, ESQUIRE ON BEHAL

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

01 By W. CHESTER BREWER, JR., P.A., ESQUIRE For Jeffrey Epstein: TONJA HADDAD, P.A. 315 S.E. 7th Street, Suite 301 Fort Lauderdale, FL 33301 By TONJA HADDAD COLEMAN, ESQUIRE For Jeffrey Epstein: ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Ave. South, Suite 1400 West Palm Beach, FL 33401 By JACK A. GOL

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and III individually, Defendants. TRANSCRIPT OF HEARING PROC

t- e80f1917-26f9-4cfa-bba3-4354ecd33a52 EFTA00598449 3 1 Thereupon, 2 the following proceedings began at 10:02 3 THE COURT: Okay. This is 4 Epstein vs. Rothstein. This is the motion of 5 the counterplaintiff for -- to add punitive 6 damages. I reviewed the materials you guys had 7 sent to m

involved 5:10 7:24 18:8 irrefutable 9:2,4 15:9 issue 12:18 16:10 issues 8:20 16:22 18:8 J J 1:6 2:13 JACK 2:11,17 jail 9:3 January 20:14 Jeffrey 1:3 2:3 7:22 Jennings 13:16 jgoldberger@... 2:11 jsx@searcyla... 2:17 Judge 1:17 4:9 8:14 13:21 14:11 16:18 JUDICIAL 1:1 jury 6:16 K Ken

es. 21 They were filed knowing that it was 22 Mr. Epstein's intent to assert his fifth 23 amendment privi

8 APPEARANCES: On behalf of Jeffrey Epstein: TONJA HADDAD, 315 Southeast 7 Street Suite 301 Fort Lauderdale, Florida 33301 (954)467-1223 BY: TONJA HADDAD COLEMAN, ESQ. and ATTERBURY, GOLDBERGER & WEISS, III. 250 Australian Avenue South Suite 1400 - One Clearlake Center West Palm Beach, Florida 33401 (561

1 IN THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants. TRANSCRIPT OF HEARING PROCEEDINGS DATE TAKEN: Mon

don't think this has anything whatsoever to do 23 with the matter, but I should let you know that I 24 handled the state claims that involved Mr. Epstein 25 when I was in Division B. So I have a significant www.phippsreporting.com 888 811-3408 EFTA00606512 1 amount of familiarity with the claim

6 35:1443:18,20 27:16 36:745:9,10 1:18 33:5 58:6 www.phippsreporting.com 888 811-3408 EFTA00606578 70 impeachment ... 27:5 3:24 5:11,13 Jeffrey (2) juncture (1) 7:10 influence (1) 7:21 17:20 1:4 6:11 5:24 implicitly (3) 33:1 29:21 31:5 jgoldberger@... jurisdiction (1) 27:22,24 30:2

hat I 24 handled the state claims that involved Mr. Epstein 25 when I was in Division B. So I have a signif

DBERGER, ESQUIRE [email protected] 12 13 TONJA HADDAD, PA 315 SE 7th Street 14 Suite 301 Fort Lauderdale, FL 33301 15 954.467.1223 BY: TONJA HADDAD COLEMAN, ESQUIRE [email protected] 16 17 On behalf of Bradley J. Edwards: 18 SEARCY, DENNEY, SCAROLA, BARNHART & SHIPLEY, P.A. 19 2139 Palm Beach

009CAO40B00/COM 1 4 THE COURT: Announce your appearances for the Court, MR. SCAROLA: Jack Scarola on behalf of Bradley Edwards, Your Honor. 3 JEFFREY EPSTEIN, MR. BREWER: Chester Brewer on behalf Plaintiff, of Jeffrey Epstein. SCOTT ROTHSTEIN, individbally, BRADLEY SWARDS, individually, MS. HADDAD: T

Epstein: e There Is also a motion directed to 8 K. CHESTER BREWER, JR., P.A. 250 S. Australian Avenue, Suite 33401 striking the affidavit of Mr. Epstein filed 9 West Palm Beach, FL 33401 :o in support of the motion. By W. CHESTER BREWER, JR., P.A., ESQUIRE 21 THE COURT: You had mentioned that t

:2,6,17 hopefully 5:4 I include 4:5 includes 4:16 individually 1:8,8 intend 5:4 intended 4:22 interrupted 3:17 issues 4:16 J Jack 2:6 3:3 Jeffrey 1:5 2:7,11 3:6.8 JR 2:8,9 Judge 1:16 judgment 3:22 4:4 4:7.15 JUDICIAL 1:1 jurisdiction 5:14.20 K know 3:16 5:22 L Lakes 1:22 2:5 laryngi

an Avenue, Suite 33401 striking the affidavit of Mr. Epstein filed 9 West Palm Beach, FL 33401 :o in suppo

E. 7th Street, Suite 301 14 And, obviously, our response to the 13 Fort Lauderdale, FL 33301 15 motion for sumnary judgment, as wall, which By TONJA HADDAD COLEMAN, ESQUIRE 16 Includes a variety of legal issues. 14 15 17 THE COURT: Can you be ready by 16 IS Tuesday, October 3rd? It sounds like it's 17

rivilege is very clearly defined in Florida Rule of Civil Procedure 1.280(b)(3). And, Your Honor, that is quoted in the response in opposition to Jeffrey Epstein's motion to overrule objections and compel answers to these questions. It is quoted in its entirety at page two of our response. And it says that a

urt is aware, the only thing pending at this point in time in the case is Mr. Edwards' claim of abuse of process malicious prosecution against Mr. Epstein. The abuse of process claim has been disposed of. It was successfully won on the summary judgment and is no longer an issue. So the only operativ

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

f abuse of process malicious prosecution against Mr. Epstein. The abuse of process claim has been disposed o

01 By W. CHESTER BREWER, JR., P.A., ESQUIRE For Jeffrey Epstein: TONJA HADDAD, P.A. 315 S.E. 7th Street, Suite 301 Fort Lauderdale, FL 33301 By TONJA HADDAD COLEMAN, ESQUIRE For Jeffrey Epstein: ATTERBURY, GOLDBERGER & WEISS, P.A. 250 Australian Ave. South, Suite 1400 West Palm Beach, FL 33401 By JACK A. GOL

-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

) 27:22,24 30:21 imploded (1) 27:5 influence (1) 33:1 information (2) 8:1 13:24 3:24 5:11,13 7:21 17:20 29:21 31:5 33:12 38:9 39:20 40:9 Jeffrey (2) 1:4 6:11 jgoldberger@... 2:11 job (2) juncture (1) 5:24 jurisdiction (1) 28:17 jury (3) 19:5 inherent (1) 44:2 48:5 58:I9 61:13 17:

hat I 24 handled the state claims that involved Mr. Epstein 25 when I was in Division B. So I have a signif

/ FOURTH DISTRICT COURT OF APPEAL STATE OF FLORIDA CASE NO.: 4D14-2282 L.T. Case No.: 502009CA040800 ANSWER BRIEF OF APPELLEE JEFFREY EPSTEIN TONJA HADDAD COLEMAN, ESQ. Florida Bar No.: 176737 TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 JOHN BERANEK Fla. Bar No.: 0005419

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

FOURTH DISTRICT COURT OF APPEAL STATE OF FLORIDA CASE NO.: 4D14-2282 L.T. Case No.: 502009CA040800 I ANSWER BRIEF OF APPELLEE JEFFREY EPSTEIN TONJA HADDAD COLEMAN, ESQ. Florida Bar No.: 176737 TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 (954) 467-1223 6 4 337-3716 facsimil

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY CIVIL DIVISION CASE NO.: 502009CA040800 AG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTFIS LIN, etc., et al., Defendant(s). ORDER ON COUNTER-PLAINTIFF EDWARDS' RENEWED MOTION FOR LEAVE TO ASSERT CLAIM F

IL DIVISION CASE NO.: 502009CA040800 AG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTFIS LIN, etc., et

NTY CIVIL DIVISION CASE NO.: 502009CA040800 AG JEFFREY EPSTEIN, Plaintiff(s), vs. SCOTT ROTFIS LIN, e

County, Florida. DAVID F. CROW CIRCUIT COURT JUDGE Copy furnished: JACK SCAROLA, ESQUIRE, 2139 Palm Beach Lakes Blvd., West Palm Beach, FL 33409 TONJA HADDAD COLEMAN, ESQUIRE, 315 S. E. 7th St., Suite 301, Ft. Lauderdale, FL 33301 FRED HADDAD, ESQUIRE, One Financial Plaza, Suite 2612, Ft. Lauderdale, FL 33394 JA

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

/ FOURTH DISTRICT COURT OF APPEAL STATE OF FLORIDA CASE NO.: 4D14-2282 L.T. Case No.: 502009CA040800 ANSWER BRIEF OF APPELLEE JEFFREY EPSTEIN TONJA HADDAD COLEMAN, ESQ. Florida Bar No.: 176737 TONJA HADDAD, PA 315 SE 7th Street Suite 301 Fort Lauderdale, Florida 33301 (954) 467-1223 (954) 337-3716 (facsi