Epstein Secrets

roperly captioned them as such on his Response. EFTA00808455 INTRODUCTION Disappointingly, Bradley Edwards ("Edwards") has used his Response to Jeffrey Epstein's ("Epstein") meritorious and well-grounded Petition as yet another vehicle for false and misleading ad hominem attacks against Epstein. Edwards' ina

q. Link & Rockenbach, PA Appellate Counsel for Petitioner 1555 Palm Beach Lakes Blvd. Suite 301 West Palm Beach, Florida 33401 'As set forth in Epstein's Petition, non-parties E.W. and Jane Doe have sought to intervene below on a limited and unrelated issue. As such, they are not parties in this c

. 4D18-0787 LT Case No. 502009CA040800XXXXMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHST

s to obfuscate with his vitriolic narrative about Mr. Epstein's past: (1) that this case was not at issue when

through his last-minute bifurcation gambit was a tactical advantage in presenting his counterclaim to the jury first. 7 EFTA00808462 ARGUMENT I. EPSTEIN WILL SUFFER IRREPARABLE HARM IF FORCED TO PROCEED WITH SEPARATE TRIALS BECAUSE THE CLAIMS INVOLVE INTERRELATED FACTUAL ISSUES AND, THEREFORE,

despite having been joined at the hip with Epstein's claim against Rothstein since 2009— the risk of inconsistent verdicts is real. Instructive, is the Third District's opinion in Travelers Express Inc. v. Acosta, 397 So. 2d 733 (1981), in which the court considered whether a plaintiff's malicious prosecution claim

-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

ious prosecution or abuse of process. The court certified conflict with Wolfe; the Florida Supreme Court ultimately approved Fischer and disapproved the Third District's decision in Wolfe. In its Opinion in this case, the Fourth District held that its decision in Fischer controlled as to the litigation privilege is

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMI3AG JEFFREY EPSTEIN, Plaintiffs vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, NOTICE OF SUPPLEMENTAL AUTH

ORIDA CASE NO.: 502009CA040800XXXXMI3AG JEFFREY EPSTEIN, Plaintiffs vs. SCOTT ROTHSTEIN, individually,

UNTY, FLORIDA CASE NO.: 502009CA040800XXXXMI3AG JEFFREY EPSTEIN, Plaintiffs vs. SCOTT ROTHSTEIN, indivi

the course of litigation. This opinion reflects a direct conflict between the interpretation of the scope of the litigation privilege reflected in the Third District's Wolfe decision and the Fourth District's repeated and consistent recognition of the continued viability of the tort of malicious prosecution in th