5
Shared Docs
5
Same-Page
17 / 5
Mentions
ss you from the podium there? THE COURT: Sure. MR. MILLER: Michael Miller from Steptoe & Johnson, and as I indicated we are here on behalf of and Jeffery Epstein, and Your Honor, we respectfully submit that the amended complaint before you is legally deficient and should be dismissed for several reasons, t
MILLER: Good afternoon, your Honor. Michael Miller and Justin Chu from the law firm of Steptoe & Johnson, and Darren Indyke, who is counsel to Mr. Epstein. We represent Jeffery Epstein and , and yesterday filed a substitution of counsel with respect to , whose previously existing counsel is also he
rdered by the defendant Maxwell to have sex with defendant Epstein. Defendants Maxwell, and Epstein each fraudulen
& Johnson, and Darren Indyke, who is counsel to Mr. Epstein. We represent Jeffery Epstein and , and yesterd
y to commit fraud, or (b) by alleging facts that constitute strong circumstantial evidence of conscious misbehavior or recklessness." Id. See also U.S. Bank National Association v. BFPRU 1, LLC, 230 SOUTHERN DISTRICT REPORTERS, P.C. (212) 805-0300 EFTA00285685 I877DOEC 4 5 6 7 8 9 10 11 12 13 14 15 16 17 1
-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
ey's Title Insurance Fund, 132 So. 3d 1191 (Fla. 3d DCA 2014) 12 Jackson v. BellSouth Telecomms., 372 F.3d 1250 (11th Cir. 2004) 14 LaFrance v. U.S. Bank National Association, 141 So. 3d 754 (Fla. 4th DCA 2014) 2 LatAm Invests., LLC v. Holland & Knight, LLP, 88 So. 3d 240 (FIa. 3d DCA 2011) 3 Levin, Middlebrooks, Mov
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
ey's Title Insurance Fund, 132 So. 3d 1191 (Fla. 3d DCA 2014) 12 Jackson v. BellSouth Telecomms., 372 F.3d 1250 (11th Cir. 2004) 14 LaFrance v. U.S. Bank National Association, 141 So. 3d 754 (Fla. 4th DCA 2014) 2 LatAm Invests., LLC v. Holland & Knight, LLP, 88 So. 3d 240 (FIa. 3d DCA 2011) 3 Levin, Middlebrooks, Mov
From: ' To: "Jeffrey Epstein" Subject: Re: SPECIAL SITUATIONS - Radnet, Inc. (RDNT) Date: Tue, 22 Apr 2014 18:54:15 +0000 Importance: Normal Is he calling me. Will be in NY ne
From: ' To: "Jeffrey Epstein" Subject: Re: SPECIAL SITUATIONS - Radnet, Inc. (
From: ' To: "Jeffrey Epstein" Subject: Re: SPECIAL SITUATIONS - Radnet
received with respect to the Consent Solicitation and the Company, RadNet Management, the subsidiaries of RadNet Management that are guarantors, and U.S. Bank National Association, a national banking association, as trustee (the "Trustee") entered into a supplemental indenture on March 21, 2014 which eliminated or modified cer
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
ey's Title Insurance Fund, 132 So. 3d 1191 (Fla. 3d DCA 2014) 12 Jackson v. BellSouth Telecomms., 372 F.3d 1250 (11th Cir. 2004) 14 LaFrance v. U.S. Bank National Association, 141 So. 3d 754 (Fla. 4th DCA 2014) 2 LatAm Invests., LLC v. Holland & Knight, LLP, 88 So. 3d 240 (FIa. 3d DCA 2011) 3 Levin, Middlebrooks, Mov
Entities connected to both Jeffrey Epstein and U.S. Bank National Association

Lesley Groff
PERSON
Ghislaine Maxwell
PERSON
T-Mobile
ORGANIZATION
George Mitchell
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATION
JPMorgan Chase
ORGANIZATIONJack Goldberger
PERSONMaria Farmer
PERSONthe Southern District
LOCATION
Virginia Giuffre
PERSON
Scarlett Johansson
PERSONEmmy Taylor
PERSON
Michael Jackson
PERSONScott Rothstein
PERSONJack Scarola
PERSON
Atlanta
LOCATIONTonja Haddad Coleman
PERSON
Supreme Court
ORGANIZATION