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

24 CERTIFICATE OF TYPE SIZE AND STYLE 24 CERTIFICATE OF SERVICE 24 EFTA00613587 TABLE OF CITATIONS Cases American Federated Title Corp. v. Greenberg Trauig, P.A., 125 So. 3d 309 (Fla. 3d DCA 2013) 12 American Nat. Title & Escrow of Florida, Inc. v. Guarantee Title & Trust, Co., 748 So. 2d 1054 (Fla.

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

4 CERTIFICATE OF TYPE SIZE AND STYLE 24 CERTIFICATE OF SERVICE 24 i EFTA00589618 TABLE OF CITATIONS Cases American Federated Title Corp. v. Greenberg Trauig, 125 So. 3d 309 (Fla. 3d DCA 2013) 12 American Nat. Title & Escrow of Florida, Inc. v. Guarantee Title & Trust, Co., 748 So. 2d 1054 (Fla. 4th DC

From: Boris Nikolic < To: "Jeffrey Epstein ([email protected])" <[email protected]> Subject: FW: Date: Wed, 23 Oct 2013 22:46:16 +0000 Attachments: carlos_serrano.pdf; g_hemandez.pd

From: Boris Nikolic < To: "Jeffrey Epstein ([email protected])" <[email protected]>

From: Boris Nikolic < To: "Jeffrey Epstein ([email protected])" <jeevacation@gma

ironment in Puerto Rico. Also attached are biographies for the following attorneys who have familiarity with the Puerto Rico issues: • Seth Entin, Greenberg Trauig • Gabriel Hernandez, BDO ( • Carlos Serrano, McConnell Valdes ( ) Additionally, I have attached biographies for William Zabel, Loretta Ippolito

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

24 CERTIFICATE OF TYPE SIZE AND STYLE 24 CERTIFICATE OF SERVICE 24 EFTA00714921 TABLE OF CITATIONS Cases American Federated Title Corp. v. Greenberg Trauig, P.A., 125 So. 3d 309 (Fla. 3d DCA 2013) 12 American Nat. Title & Escrow of Florida, Inc. v. Guarantee Title & Trust, Co., 748 So. 2d 1054 (Fla.

From: Boris Nikolic < Sent: Wednesday, October 23, 2013 10:46 PM To: Jeffrey Epstein ([email protected]) Subject: FW: Attachments: carlos serrano.pdf; g hernandez.pdf; Seth)._Entin[11.pdt Loretta-A-Ippolito.pdf; William D Zab

ednesday, October 23, 2013 10:46 PM To: Jeffrey Epstein ([email protected]) Subject: FW: Attachmen

Sent: Wednesday, October 23, 2013 10:46 PM To: Jeffrey Epstein ([email protected]) Subject: FW: A

environment in Puerto Rico. Also attached are biograph=es for the following attorneys who have familiarity with the Puerto Rico issues: Seth Entin, Greenberg Trauig ( Gabriel Hernandez, BDO Carlos Serrano, McConnell Valdes >) Additionally, I have attached biographies for Willia= Zabel, Loretta Ippolito and Lee

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

th approval and relied upon in Jackson v. Attorney's Title Insurance Fund, 132 So. 3d 1191 (Fla. 3d DCA 2014) and American Federated Title Corp. v. Greenberg Trauig, P.A., 125 So. 3d 309 (Fla. 3d DCA 2013) in matters involving the litigation privilege. In the instant case, the trial court was legally bound by t