Epstein Secrets

40800XXXXMBAG Plaintiff/Counter-Defendant, JUDGE HAFELE v. BRADLEY J. EDWARDS, et al., Defendant/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RENEWED MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S FOURTH AMENDED COUNTERCLAIM, OR, IN THE ALTERNATIVE, MOTION F

DERATION OF ORAL SUMMARY JUDGMENT RULING, REOUEST FOR ORAL ARGUMENT 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, hereby files this Renewed Motion for

of March 23, 2010; dockets and pleadings in LM v. Jeffrey Epstein, 502008C44028051)OOCXMB AB; EW v. Jeffrey Epstein, 502008CA028058DOCAMB AB; LM v. Jay Epstein, 09-81092 Marra/Johnson and Jane Doe v. Jeffrey Epstein, 08-80893-CIV Marra/Johnson; copies of subpoenas; Deposition Transcript of Jeffrey Epstein,

e of these potentially explosive facts, putative defendant Epstein had allegedly offered $200,000,000.00 for settlem

CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY JEFFREY EPSTEIN, No. 50 2009 CA 040800XXXXMBAG Plaintif

(the "Epstein Cases"). See pleadings in LM v. Jee•ey Epstein, 502008CA028051XXXXMB AB; EW v. Jeffrey Epstein,

the plaintiff; 3) its bona fide termination in favor of the plaintiff; 4) the absence of probable cause for the prosecution; 5) malice; 6) damages. Duval Jewelry Co. v. Smith, 102 Fla. 717, 136 So. 878, 880 (1931). The fourth element, the absence of probable cause, is at issue here. In Goldstein v. Sabella, 88 S

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

1, 1185 (Fla. 1977) ("It is recognized that malice may be inferred from the absence of probable cause. Adams v. WhiWeld, 290 So. 2d 49 (Fla. 1974); Duval Jewelry Co. v. Smith, 102 Fla. 717, 136 So. 878 (Fla. 1931). However, malice is not legally synonymous with the absence of probable cause. White v. Miami Home

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

the plaintiff; 3) its bona fide termination in favor of the plaintiff; 4) the absence of probable cause for the prosecution; 5) malice; 6) damages. Duval Jewelry Co. v. Smith, 102 Fla. 717, 136 So. 878, 880 (1931). The fourth element is at issue here. In Goldstein v. Sabella, 88 So. 2d 910 (Fla. 1956), the Supre

40800XXXXMBAG Plaintiff/Counter-Defendant, JUDGE HAFELE v. BRADLEY J. EDWARDS, et al., Defendant/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWAFtDS'S FOURTH AMENDED COUNTERCLAIM, REOUEST FOR ORAL ARGUMENT AND SUPPORTIN

EDWAFtDS'S FOURTH AMENDED COUNTERCLAIM, REOUEST FOR ORAL ARGUMENT 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, hereby files this Motion for Summary

s Rights Act: When asked whether Epstein "pulled you closer to him in a sexual way," [LM] replied: A. I wish. No, no, never, ever, ever, no, never. Jeffrey is an awesome man, no. At the end of her interview, [LM] was asked if she had any questions for the agents or AUSA Villafana. [LM] responded: A. N

the plaintiff; 3) its bona fide termination in favor of the plaintiff; 4) the absence of probable cause for the prosecution; 5) malice; 6) damages. Duval Jewelry Co. v. Smith, 102 Fla. 717, 136 So. 878, 880 (1931). The fourth element, the absence of probable cause, is at issue here. In Goldstein v. Sabella, 88 S