Epstein Secrets

-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

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

s of the seminal cases upon which Appellee relies in support of his assertion that the trial court's ruling was proper; Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, P.A. v. United States Fire Ins. Co., 639 So. 2d 606, 608 (Fla. 1994) and Echevarria, McCalla, Raymer, Barrett & 9 EFTA00613598 Frappier v. Cole

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

ases upon which Appellee relies in support of his assertion that the trial court's ruling was proper; Levin, 9 EFTA00589629 Middlebrooks, Mabie, Thomas, Mayes & Mitchell, M. v. United States Fire Ins. Co., 639 So. 2d 606, 608 (Fla. 1994) and Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380, 38

UIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CIVIL DIVISION AG CASE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF'

aintiffs. PLAINTIFF'S RESPONSE IN OPPOSITION TO DEFENDANT EDWARDS' RENEWED MOTION FOR SUMMARY JUDGMENT Plaintiff, Jeffrey Epstein ("Plaintiff" or "Epstein"), hereby files the following Response in Opposition to Defendant Bradley J. Edwards' ("Edwards") Renewed Motion for Summary Judgment ("Motion") an

SE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

there is no immunity for acts undertaken in judicial proceedings that bear no relation to those proceedings. See, e.g., Levin, Middlebrooks, Mahie, Thomas, Mayes & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So. 2d 616, 608 (1994). It is for a fact finder to determine whether Edwards' acts were in furtherance of the judi

OUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

efendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY J. EDWARDS' SECOND SUPPLEMENT TO MOTION IN LIMINE ADDRESSING SCOPE OF ADMISSIBLE EVI

FF BRADLEY J. EDWARDS' SECOND SUPPLEMENT TO MOTION IN LIMINE ADDRESSING SCOPE OF ADMISSIBLE EVIDENCE Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), opposes Defendant/Counter- Plaintiff Bradley J. Edwards' ("Edwards") December 11, 2017, Second Supplement to Motion in Limine Addressing Scope of

it would not be covered by the litigation privilege and it could serve as a basis for probable cause to bring a claim. Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, P.A. v. United States Fire Ins. Co., 639 So. 2d 606, 608 (Fla. 1994). Epstein's Complaints identified numerous instances of conduct by Edwards tha

ly, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. Case No. 50 2009 CA 040800XXXXMBAG Judge: CROW PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR ATTORNEYS' FEES PURSUANT TO §57.105 OF THE FLORIDA STATUTES Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his

R-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR ATTORNEYS' FEES PURSUANT TO §57.105 OF THE FLORIDA STATUTES Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to §57.105 of the Florida Statutes, hereby moves this Court for an award of attorneys' fees

CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff, Counter-Defendant, vs. SCO

rred. Id (emphasis added).; see also Echevarria, McCalla, Rayner, Barrett &Frappier v. Cole, 950 So. 2d 380 (Fla.2007); Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994); DelMonico v. Traynor, 2013 WL 535451 (Fla.2013); Am. Nat'l Title & Escrow of Fla. v. Guara

-Defendant, VS. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter- Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OBJECTION AND RESPONSE TO IMPROPER FILING OF SUPPLEMENTAL AUTHORITY INTRODUCTION In December 2009, Jeffrey Epstein ("Epstein") filed suit against

-DEFENDANT JEFFREY EPSTEIN'S OBJECTION AND RESPONSE TO IMPROPER FILING OF SUPPLEMENTAL AUTHORITY INTRODUCTION In December 2009, Jeffrey Epstein ("Epstein") filed suit against Scott Rothstein ("Rothstein") and Bradley J. Edwards ("Edwards"). In response to Epstein's lawsuit, Edwards filed a Countercla

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

rred. Id. (emphasis added); see also Echevarria, McCalla, Raymer, Barrett &Frappier v. Cole, 950 So. 2d 380 (Fla.2007); Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994); DelMonico v. Traynor, 2013 WL 535451 (Fla.2013); Am. Nat'l Title & Escrow of Fla. v. Guara

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

s of the seminal cases upon which Appellee relies in support of his assertion that the trial court's ruling was proper; Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, M. v. United States Fire Ins. Co., 639 So. 2d 606, 608 (Fla. 1994) and Echevarria, McCalla, Raymer, Barrett & 9 EFTA00714932 Frappier v. Cole,

S. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter- Plaintiffs. ORDER GRANTING PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT THIS CAUSE came before the court on Plaintiff/Counter-Defendant Jeffrey Epstein's Motion for Summary Judgment as to De

ing heard argument of counsel, and being otherwise duly advised in the premises, finds and decides as follows: In December 2009, Jeffrey Epstein ("Epstein") filed suit against Scott Rothstein ("Rothstein") and Bradley J. Edwards ("Edwards"). In response to Epstein's lawsuit, Edwards filed a Countercla

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

rred. Id. (emphasis added); see also Echevarria, McCalla, Rayner, Barrett &Frappier v. Cole, 950 So. 2d 380 (Fla.2007); Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, M. v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994); DelMonico v. Traynor, 2013 WL 535451 (Fla.2013); Am. Nat'l Title & Escrow of Fla. v. Guarant

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

S. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter- Plaintiffs. ORDER GRANTING PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JU DGMENT THIS CAUSE came before the court on Plaintiff/Counter-Defendant Jeffrey Epstein's Motion for Summary Judgment as to D

ving heard argument of counsel, and being otherwise duly advised in the premises, finds and decides as follows: In December 2009, Jeffrey Epstein ("Epstein") filed suit against Scott Rothstein ("Rothstein") and Bradley J. Edwards ("Edwards"). In response to Epstein's lawsuit, Edwards filed a Counterclai

arred. Id. (emphasis added); see also Echevarria, McCalla, Raymer, Barrett &Frappier v. Cole, 950 So. 2d 380 (F1a.2007); Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, M. v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994); DelMonico v. Traynor, 2013 WL 535451 (Fla.2013); Am. Nat'l Title & Escrow of Fla. v. Guarant

-Defendant, VS. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter- Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFFS' MOTION FOR RECONSIDERATION INTRODUCTION In December 2009, Jeffrey Epstein ("Epstein") filed suit against Sc

TER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFFS' MOTION FOR RECONSIDERATION INTRODUCTION In December 2009, Jeffrey Epstein ("Epstein") filed suit against Scott Rothstein ("Rothstein") and Bradley J. Edwards ("Edwards"). In response to Epstein's lawsuit, Edwards filed a Countercla

OUNTY, FLORIDA CASE NO. 502009CA0408003OOOCMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, VS. SCOT

rred. Id. (emphasis added); see also Echevarria, McCalla, Raymer, Barrett &Frappier v. Cole, 950 So. 2d 380 (Fla.2007); Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, M. v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994); DelMonico v. Traynor, 2013 WL 535451 (Fla.2013); Am. Nat'l Title & Escrow of Fla. v. Guarant