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JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv
ds still utilizes his litigious association with Mr. Epstein at his new firm Farmer, Jaffe, Weissing, Edwards,
IRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502009CA040800XxxxmBAG PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S ANSWER AND AFFIRMATIVE DEFENSES TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' COUNTERCLAIM Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein
STEIN'S ANSWER AND AFFIRMATIVE DEFENSES TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' COUNTERCLAIM Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.110 of the Florida Rules of Civil Procedure, hereby files his Answer and Affirmati
11) (citing to American Nat. Title & Escrow of Florida. Inc. v. Guarantee Title & Trust, Co., 748 So. 2d 1054, 1056 (Fla. 4th DCA 1999)); See also. Montejo v. Marlin Memorial Medical Center, Ina, 935 So. 2d 1266, 1269 (Fla. 4th DCA 2006). 8 EFTA00299006 Defendant specifically reserves the right here
-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
passim McCullough v. Kubiak, 4D13-4048 (Feb. 18, 2015) 9, 10 Microbilt Corporation v. Chex Systems, Inc., 2013 WL 6628619 (Dec. 16, 2013) 14 Montejo v. Martin Memorial Medical Center, Inc., 935 So. 2d 1266 (Fla. 4th DCA 2006) 13 ii EFTA00613588 Olson v. Johnson, 961 So. 2d 356 (Fla. 2d DCA
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
passim McCullough v. Kubiak, 4DI3-4048 (Feb. 18, 2015) 9, 10 Microbilt Corporation v. Chex Systems, Inc., 2013 WL 6628619 (Dec. 16, 2013) 14 Montejo v. Martin Memorial Medical Center, Inc., 935 So. 2d 1266 (Fla. 4th DCA 2006) 13 ii EFTA00589619 Olson v. Johnson, 961 So. 2d 356 (Fla. 2d DCA
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
(July 17, 2013); American Nat. Title & Escrow of Florida, Inc. v. Guarantee Title & Trust, Co., 748 So. 2d 1054, 1056 (Fla. 4th DCA 1999); see also Montejo v. Martin Memorial Medical Center, Inc., 935 So. 2d 1266, 1269 (Fla. 4th DCA 2006). Finally, a copy of this Motion was provided to Edwards twenty-
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
passim McCullough v. Kubiak, 4D13-4048 (Feb. 18, 2015) 9, 10 Microbilt Corporation v. Chex Systems, Inc., 2013 WL 6628619 (Dec. 16, 2013) 14 Montejo v. Martin Memorial Medical Center, Inc., 935 So. 2d 1266 (Fla. 4th DCA 2006) 13 ii EFTA00714922 Olson v. Johnson, 961 So. 2d 356 (Fla. 2d DCA
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
a. 3d DCA 2013); American Nat. Title & Escrow of Florida, Inc. v. Guarantee Title & Trust, Co., 748 So. 2d 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
Entities connected to both Jeffrey Epstein and Montejo

George Mitchell
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
JPMorgan Chase
ORGANIZATIONJack Goldberger
PERSONMaria Farmer
PERSON
Scarlett Johansson
PERSONEmmy Taylor
PERSON
Michael Jackson
PERSONScott Rothstein
PERSONJack Scarola
PERSONTonja Haddad Coleman
PERSON
Supreme Court
ORGANIZATIONAtterbury
ORGANIZATIONAce Greenberg
PERSONGoldberger & Weiss
ORGANIZATIONFISTOS & LEHRMAN
ORGANIZATION
Weissing
PERSONJaffe
PERSONPalm Beach Lakes Blvd
LOCATION