Epstein Secrets

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

16 So. 3d 1205 (Fla. 2013) 2, 10, 18, 19 Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007) passim Fridovich v. Fridovich, 598 So. 2d 65 (FIa. 1992) 13, 17, 22 Graham-Eckes Palm Beach Academy v. Johnson, 573 So. 2d 1007 (Fla. 4th DCA 1991) 21 Jackson v. Attorney's

ion is reviewable on appeal' and the availability of other remedies through which the trial court could mitigate the harm. . ." Id. at 1215 (citing Fridovich, 598 So. 2d at 69). Accordingly, the DelMonico decision affirmatively recognized a litigation privilege where, as in the instant case, there is jud

njoys the same immunity. We agree." Id. at 427. Appellant's reliance on Fridovich v. Fridovich, 598 So. 2d 65 (Fla. 1992) is also erroneous, as in Fridovich the Florida Supreme Court specifically concluded that only a qualified privilege is applicable when private individuals voluntarily make defamatory

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

n of stalking. And 8 the court distinguished that claim privilege from 9 a defamation case that was addressed in a case 10 called Fridovich vs. Fridovich, 598 Sold. 65, 11 Florida Supreme Court case 1992, in which the 12 Supreme Court was presented with a certified 13 question of whether a person

accusing Olson of stalking. And 8 the court distinguished that claim privilege from 9 a defamation case that was addressed in a case 10 called Fridovich vs. Fridovich, 598 Sold. 65, 11 Florida Supreme Court case 1992, in which the 12 Supreme Court was presented with a certified 13 question of wh

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

ion is reviewable on appeal' and the availability of other remedies through which the trial court could mitigate the harm. . ." Id. at 1215 (citing Fridovich, 598 So. 2d at 69). Accordingly, the DelMonico decision affirmatively recognized a litigation privilege where, as in the instant case, there is jud

116 So. 3d 1205 (Fla. 2013) 2, 10, 18, 19 Echevarria, McCalla, Raymer, Barren & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007) passim Fridovich v. Fridovich, 598 So. 2d 65 (FIa. 1992) 13, 17, 22 Graham-Eckes Palm Beach Academy v. Johnson, 573 So. 2d 1007 (Fla. 4th DCA 1991) 21 Jackson v. Attorney's

njoys the same immunity. We agree." Id. at 427. Appellant's reliance on Fridovich v. Fridovich, 598 So. 2d 65 (Fla. 1992) is also erroneous, as in Fridovich the Florida Supreme Court specifically concluded that only a qualified privilege is applicable when private individuals voluntarily make defamatory

-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

accusing Olson of stalking. And 8 the court distinguished that claim privilege from 9 a defamation case that was addressed in a case 10 called Fridovich vs. Fridovich, 598 So2d. 65, 11 Florida Supreme Court case 1992, in which the 12 Supreme Court was presented with a certified 13 question of wh

n of stalking. And 8 the court distinguished that claim privilege from 9 a defamation case that was addressed in a case 10 called Fridovich vs. Fridovich, 598 So2d. 65, 11 Florida Supreme Court case 1992, in which the 12 Supreme Court was presented with a certified 13 question of whether a person

UNITED STATES DISTRICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 09-CV-80802-MARRA-JOHNSON JANE DOE NO. 8 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO MOTION TO DISMISS PLAINTIFFS COMPLAINT, dated 08/12/09 De

ICT COURT SOUTHERN DISTRICT OF FLORIDA CASE NO.: 09-CV-80802-MARRA-JOHNSON JANE DOE NO. 8 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S MEMORANDUM OF LAW IN OPPOSITION TO MOTION TO DISMISS PLAINTIFFS COMPLAINT, dated 08/12/09 Defendant EPSTEIN, by and through

8 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S REPLY TO PLAINTIFF'S MEMORANDUM OF LAW IN OPPO

02-MARRA-JOHNSON JANE DOE NO. 8 Plaintiff, v. JEFFREY EPSTEIN, Defendant. DEFENDANT EPSTEIN'S REPLY T

nding tort" because it "realleges the same facts mentioned in appellant's sexual abuse claims and fails to provide any additional facts." Citing to Fridovich v. Fridovich, 598 So.2d 65, 69-70 (Fla. 1992)(holding that no separate cause of action for intentional infliction of emotional distress existed wher

outh Flagler Drive West Palm Beach, Florida 33401 Telephone: (561) 802-9044 Facsimile: (561) 802-9976 Attorneys for Plaintiff/Counter-Defendant Jeffrey Epstein - 6 - FOWLER WHITE BURNETT • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA00306389 Epstei

IN'S MEMORANDUM OF LAW IN OPPOSITION TO DAMAGES PLED IN BRADLEY EDWARDS' SECOND AMENDED COUNTERCLAIM Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, pursuant to this Court's Order on March 29, 2012, respectfully submits this Memorandum Of Law In Opposit

NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

nts made in the course of litigation, are subject to an absolute privilege, and thus, will not support a claim for injury to reputation. See, e.g., Fridovich v. Fridovich, 598 So. 2d 65 (Fla. I 992)(defamatory statements made in the course of judicial proceedings are absolutely privileged). Accordingly, a

adings and discovery responses, and as conceded by Edwards's counsel at oral argument, the events giving rise to Edwards's purported claims against Epstein occurred solely in the course of, and were related to, the litigation, just as occurred in the Wolfe case, mandating Summary Judgment. Wolfe v. For

d 1054, 1056 (Fla. 4th DCA 1999). See also Montejo v. Martin Memorial Medical Center, Inc., 935 So. 2d 1266, 1269 (Fla. 4th DCA 2006); Fridovich v. Fridovich, 598 So. 2d 65 (Ha. 1992) (stating that the litigation privilege "arises immediately upon the doing of any act required or permitted by law in the

ion is reviewable on appeal' and the availability of other remedies through which the trial court could mitigate the harm. . ." Id. at 1215 (citing Fridovich, 598 So. 2d at 69). Accordingly, the DelMonico decision affirmatively recognized a litigation privilege where, as in the instant case, there is jud

njoys the same immunity. We agree." Id. at 427. Appellant's reliance on Fridovich v. Fridovich, 598 So. 2d 65 (Fla. 1992) is also erroneous, as in Fridovich the Florida Supreme Court specifically concluded that only a qualified privilege is applicable when private individuals voluntarily make defamatory