Epstein Secrets

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

ion privilege applied to both the abuse of process and malicious prosecution claims, and also finding that Levin, Middlebrooks, Moves & Mitchell v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994), Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007), and Wolfe provided "binding prece

-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

4th DCA 2014) 2 LatAm Invests., LLC v. Holland & Knight, LLP, 88 So. 3d 240 (FIa. 3d DCA 2011) 3 Levin, Middlebrooks, Moves & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994) passim McCullough v. Kubiak, 4D13-4048 (Feb. 18, 2015) 9, 10 Microbilt Corporation v. Chex Systems, Inc., 2013 WL

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

rtaken 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 judicial proceedings or for som

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

elation to those proceedings, including for an action for abuse of process or malicious prosecution. Levin, Middlebrooks, Moves & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So.2d 606, 608 (Fla. 1994). The Florida Supreme Court explained the policy reasons for the litigation privilege and in so doing stated: In ba

-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

action against Epstein. The Court, in applying the Florida Supreme Court binding precedent as espoused in Levin, Middlebrooks, Moves & Mitchell, v. U.S. Fire Ins. Co., 639 So. 2d 606, 608 (Fla. 1994) and Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007), as well as reviewing the

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

la. R.Civ. P. 1.510(c). This court, in applying the Florida Supreme Court binding precedent as espoused in Levin, Middlebrooks, Moves & Mitchell, v. U.S. Fire Ins. Co., 639 So. 2d 606, 608 (Fla. 1994) and Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007), as well as reviewing the

-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

action against Epstein. The Court, in applying the Florida Supreme Court binding precedent as espoused in Levin, Middlebrooks, Moves & Mitchell, v. U.S. Fire Ins. Co., 639 So. 2d 606, 608 (Fla. 1994) and Echevarria, McCalla, Raymer, Barrett & Frappier v. Cole, 950 So. 2d 380 (Fla. 2007), as well as reviewing the

. Harold E. WOLFE, Jr., et al., Appellants, v. Jeffrey T. FOREMAN, et al., Appellees. No. 3D10-3055. I

occur in judicial proceedings. Myers v. Hodges, 53 Fla. 197, 44 So. 357 (1907). In Levitt, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So.2d 606, 608 (Fla.I994), the Florida Supreme Court extended the litigation privilege, already applicable to defamatory statements (slander

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

or such as the alleged misconduct at issue, so long as the act has some relation to the proceeding." Levin, Middlebrooks, Moves & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So. 2d 606, 608 (Fla. 1994). As a result, if a party seeks to bring a cause of action involving acts that neither occurred during, nor had rel