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vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiff. AFFIDAVIT OF JEFFREY EPSTEIN The undersigned, Jeffrey E. Epstein, having first been duly sworn, hereby deposes and says: 1. I am over eighteen (18) years old and have personal knowledge of the facts stated here
or leave to file the supplemental argument contained herein on the following grounds: 1. The trial judge entered summary final judgment in favor of Epstein on the ground that the litigation privilege bars the malicious prosecution and abuse of process claims filed against Epstein by the appellant, Brad
unrelated to the underlying litigation against me, and (b) asserting my causes of action against Edwards and Rothstein in the Action. FURTHER AFFI JEFFREY EPS STATE OF NEW YORK ) ) ss.: COUNTY OF NEW YORK ) _ - Sworn and subscribed to before me, the undersigned authority, by Jeffrey Epstein, this 25t
e of these potentially explosive facts, putative defendant Epstein had allegedly offered $200,000,000.00 for settle
. 4D14-2282 BRADLEY J. EDWARDS, Appellant, v. JEFFREY EPSTEIN, Appellee. MOTION FOR LEAVE TO FILE SUP
three defendants -7- EFTA00612489 including: Edwards, and his then partner Scott Rothstein. The four counts alleged: (1) violations of Florida's Civil Remedies for Criminal Practices Act; (2) violations of Florida's Racketeering Influenced and Corrupt Organization Act; (3) abuse of process; and (4) fraud. Epstein's complaint set for
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
and engaging in improper litigation tactics in order to promote and sustain that Ponzi scheme. Epstein brought claims for violations of Florida 's Civil Remedies for Criminal Practices Act, violations of Florida's Racketeer Influenced and Corrupt Organization (RICO), abuse of process, fraud and conspiracy to commit fraud. Rothstein di
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
in's complaint alleges claims against Rothstein and Edwards for fraud, violation of Florida's civil racketeering statute and violation of Florida's Civil Remedies for Criminal Practices Act. Ponzi Scheme Complaint ¶¶ 26, 54-68, 73-78.4 The complaint also pleads an abuse of process claim alleging that after the thrce sex abuse suits were
Entities connected to both Jeffrey Epstein and Civil Remedies for Criminal Practices Act

George W. Bush
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJane Doe
PERSONthe Southern District
LOCATIONScott Rothstein
PERSONJack Scarola
PERSONGoldberger & Weiss
ORGANIZATIONFlorida Bar
ORGANIZATION
Adler
PERSONE.W.
PERSON
Rosenfeldt
PERSONBurlington & Rockenbach
ORGANIZATIONValdes
PERSONMancusi
PERSONPayless Flea Market, Inc.
ORGANIZATION