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,

t was thereafter entered in favor of Epstein. Edwards appealed the judgment as it pertained to his malicious prosecution action, during which time the Fourth District issued Fischer v. Debrincat, 169 So. 3d 1204 (Fla. 4th DCA 2015), holding that the litigation privilege did not apply to a malicious prosecution act

08CF009381AXX STATE, vs. EPSTEIN, JE'FFREY INTERVENER'S E O u. 0 T i TAY AND UPPORTIN COMES NOW, Intervener,.. and files s Response endant Jeffrey Epstein's Motion to Stay, and states: In their motion, Defendant asks the Court to stay it mg on the production of the NPA agreement pending review by the

y's office that triggers as a 13 result of this plea agreement. In other 14 words, they have signed off and said they 15 will not prosecute Mr. Epstein in the 16 Southern District of Florida for any 17 offense upon his successful taking of this 18 plea today. That is a confidential 19 documen

RCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 2006CF009454AXX, 2008CF009381A)OC STATE, vs. EPSTEIN, JEFFREY E, Defendant. MOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW COMES NOW, Applicant, ■. and requests this Court, pursuant to Florida Rule of Civ

as it has been properly sealed. Furthermore, as Defendant EPSTEIN has failed to demonstrate that he is likely to s

09454AXX, 2008CF009381AXX STATE, vs. EPSTEIN, JE'FFREY INTERVENER'S E O u. 0 T i TAY AND UPPO

signed off and said they 15 will not prosecute Mr. Epstein in the 16 Southern District of Florida for any

equately ad•` s fa ;•rs in their motion. In fact, Defendant completely ignores the likelihood Likely this is because there is no likelihood that the Fourth District would reverse ling since the proper procedures for sealing the NPA were never followed. As to likelihood of harm, the only reference Defendan to

all those conditions you two have agreed to? MS. BELOHLAVEK: Yes, Your Honor. MR. GOLDBERGER: With the court's amendments, yes. THE COURT: Mr. Epstein, do you understand? THE DEFENDANT: Yes, ma'am. THE COURT: I need the defendant to 14 sign number D where I had an a added to 15 victim, and G,

Z.= TO REORDER CALL 9546/49599 EFTA00180769 PLEA IN THE CIRCUIT COURT THE FOLLOWING IS TO REFLECT ALL TERMS OF THE NEGOTIATED SETTLEMENT Name: Jeffrey E. Epstein Plea: Guilty _1S Case No. Charge Count Lesser Decree 06CF009454AMB Felony Solicitation of Prostitution 1 No 3 FEL 08CF009381AMB Procuring

tkido by them. . Instructed byt op/07.02.08 Superela& Moor pbfeackt jagt 7 of 8 Form Itovike 034 tiet EFTA00180788 11/LO/Zdtlti 333 ,a4g2 JEFFILEY EPSTEIN CASE(1302008CF009381A.XXX148 • COURT °BMW PA'YMZIff$ • • • ▪ • • • • . . l••111,AI. I •IT\olkl•ILI "Vom Wen sms • . . • ' i . .

ECT ALL TERMS OF THE NEGOTIATED SETTLEMENT Name: Jeffrey E. Epstein Plea: Guilty _1S Case No. Charge Coun

as it has been properly sealed. Furthermore, as Defendant EPSTEIN has failed to demonstrate that he is likely to s

: With the court's amendments, yes. THE COURT: Mr. Epstein, do you understand? THE DEFENDANT: Yes, ma'am.

ld a stay not be 769 So.2d 389, 391 n.4 (Fla. 3d DCA 1999). Defendants fail to adequately ad completely ignores the likelihood likelihood that the Fourth District would reverse for sealing the NPA were never followed. As to likelihood of harm, the only reference Defendan paragraph 3 of his motion. Here, Defe

4AXX, 2008CF009381AXX STATE, vs. EPSTEIN, JEFFREY INTERVENER'S AND S ON TO STAY OF LAW COMES NOW, Intervener, M. and fil 's Response ndant Jeffrey Epstein's Motion to Stay, and states: In their motion, Defendant asks the Court to stay it mg on the production of the NPA agreement pending review by the

y's office that triggers as a 13 result of this plea agreement. In other 14 words, they have signed off and said they 15 will not prosecute Mr. Epstein in the 26 Southern District of Florida for. any 17 offense upon his successful taking of this 18 plea today. That is a confidential 19 docume

signed off and said they 15 will not prosecute Mr. Epstein in the 26 Southern District of Florida for. any

IRCUIT COURT OF THE 15TH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO: 2006CF009454AXX, 2008CF009381AXX STATE, vs. EPSTEIN, JEFFREY E, Defendant. MOTION TO INTERVENE AND SUPPORTING MEMORANDUM OF LAW COMES NOW, Applicant, M. and requests this Court, pursuant to Florida Rule of Civ

as it has been properly sealed. Furthermore, as Defendant EPSTEIN has failed to demonstrate that he is likely to s

ately ad s these fa rs in their motion. In fact, Defendant completely ignores the likelihood Likely this is because there is no likelihood that the Fourth District would reverse ling since the proper procedures for sealing the NPA were never followed. As to likelihood of harm, the only reference Defendan to

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

cted the summary judgment on probable cause and bona fide termination. We filed an appeal. That case was briefed. And prior to the oral argument, the Fourth District rejected the Wolfe case. Now, what happened in the briefing in our case is our initial brief addressed solely litigation privilege, because that

Have you over pied any allegations, Mr. Berger, that turned out to be untrue. down the lino? 1 4 S 147 Epstein? A It's patently [also that Jeffrey Epstein wan not Intel injured by anything that Brad Edwards did or if -- I don't deny that there wan a 0042l scheme that used the three cases we had as bait.

Boulevard, Suite 1001 $ 9:27 West Palm Beach, FL 33401 4 This is the videotaped deposition of 4 1561) 471-2995 5 Berger in the matter of Jeffrey 5 APPEARANCES: 6 For Plaintiff: 4 Epstein versus Scott Rothstein and Bradley 7 LINK 4 ROCKENBACH, . Edwards. 1555 Palm Beach Lakes Boulevar

, FL 33401 4 This is the videotaped deposition of 4 1561) 471-2995 5 Berger in the matter of Jeffrey 5 APPEARANCES: 6 For Plaintiff: 4 Epstein versus Scott Rothstein and Bradley 7 LINK 4 ROCKENBACH, . Edwards. 1555 Palm Beach Lakes Boulevard, Suite 301 0 9 West Palm Beach, FL 33401 B

th Florida. He had a case -- ho had cases against Mr. Epstein. Or he had clients -- I don't know if he actuall

So I served on the 12 Fourth District and served with a panel of judges 13 and heard quite a number of cafes and wrote several 14 decisions for the Fourth District. Q The jury may not be familiar with the 14 procedure, but when the appellate court reviews 17 decision➢ that are rendered and jury trial re➢ul

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

t was thereafter entered in favor of Epstein. Edwards appealed the judgment as it pertained to his malicious prosecution action, during which time the Fourth District issued Fischer v. Debrincat, 169 So. 3d 1204 (Fla. 4th DCA 2015), holding that the litigation privilege did not apply to a malicious prosecution ac

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, -VS- SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiffs. RESPONSE IN

in Opposition to Plaintiff/Counter-Defendant's Motion for Fees and Costs, and as grounds therefor would state: INTRODUCTION This case arises from Epstein's lawsuit against Edwards, when Epstein sued Edwards merely for his legal representation of people accusing Epstein of misconduct. Edwards counter-

COUNTY, FLORIDA. CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, -VS- SCOT

y to make an informed decision of acceptance or rejection. One aspect of Swartsel was disagreed with by the Supreme Court in Nichols. In Swartsel, the Fourth District held parties were required to specify all terms of a settlement (882 So.2d at 453). Then in Nichols, the Supreme Court held parties could summarize

Epstein v. Edwards Page 1 of 1 From: John Beranek > To: wcbiew ; wcbcg Subject: Epstein v. Edwards Date: Mon. Jun 16, 2014 4:06 pm Chet -- I have rev

rt has ruled on the issue and the district court really has no choice. I would be happy to discuss it further and I think my job would be to remind the Fourth District that their decision got reversed in Echevarria. Let me know if you want to talk about it on the phone or what you want to do next. Sincerely, Joh