Epstein Secrets

40800XXXXMBAG Plaintiff/Counter-Defendant, JUDGE HAFELE v. BRADLEY J. EDWARDS, et al., Defendant/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RENEWED MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S FOURTH AMENDED COUNTERCLAIM, OR, IN THE ALTERNATIVE, MOTION F

DERATION OF ORAL SUMMARY JUDGMENT RULING, REOUEST FOR ORAL ARGUMENT AND SUPPORTING MEMORANDUM OF LAW Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.510 of the Florida Rules of Civil Procedure, hereby files this Renewed Motion for

of March 23, 2010; dockets and pleadings in LM v. Jeffrey Epstein, 502008C44028051)OOCXMB AB; EW v. Jeffrey Epstein, 502008CA028058DOCAMB AB; LM v. Jay Epstein, 09-81092 Marra/Johnson and Jane Doe v. Jeffrey Epstein, 08-80893-CIV Marra/Johnson; copies of subpoenas; Deposition Transcript of Jeffrey Epstein,

e of these potentially explosive facts, putative defendant Epstein had allegedly offered $200,000,000.00 for settlem

CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY JEFFREY EPSTEIN, No. 50 2009 CA 040800XXXXMBAG Plaintif

(the "Epstein Cases"). See pleadings in LM v. Jee•ey Epstein, 502008CA028051XXXXMB AB; EW v. Jeffrey Epstein,

n. Epstein subsequently dismissed his Complaint without prejudice. The counter- claim proceeded, undergoing several amendments. As it now stands, the Fourth Amended Counterclaim has two causes of action: abuse of process and malicious prosecution. Epstein moved for summary judgment arguing that the litigation p

ter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S PROPOSAL FOR SETTLEMENT TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY J. EDWARDS, INDIVIDUALLY Plaintiff/Counter-Defendant, Jeffrey Epstein, hereby propo

sal for Settlement and Offer of Judgment ("Proposal") a. Parties: The party making this Proposal is Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"). The party to whom this Proposal is being made is Defendant/Counter- Plaintiff, Bradley J. Edwards, individually ("Edwards"). In this Proposal, Eps

ela M. Many (FBN 26680) Primary: Primary: Primary: Secondary: Secondary: Secondary: Secondary: Trial Counsel for Plaintiff/Counter-Defendant Jay Epstein SERVICE LIST Jack Scarola Nichole J. Segal Searcy, Denny, Scarola, Barnhart & Shipley, . Burlington & Rockenbach, 2139 Palm Beach Lakes Bouleva

OUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

roposal. e. Amount Proposed to Settle Claim for Punitive Damages, If Any: Edwards has asserted a claim against Epstein for punitive damages in his Fourth Amended Counterclaim. The Total Amount set forth in paragraph 2(d) above includes payment of $10,000 for Edwards' claim for punitive damages. The total amo

er-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S PROPOSAL FOR SETTLEMENT TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY J. EDWARDS. INDIVIDUALLY Plaintiff/Counter-Defendant, Jeffrey Epstein, hereby propo

sal for Settlement and Offer of Judgment ("Proposal") a. Parties: The party making this Proposal is Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"). The party to whom this Proposal is being made is Defendant/Counter-Plaintiff, Bradley J. Edwards, individually ("Edwards"). In this Proposal, E

CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Case No. 50-2009CA040800XXXXMBAG Plain

L 33301 Primary: Secondary: Co-counsel for Jef•ey Epstein Jack A. Goldberger Atterbuiy, Goldberger & Weis

roposal. e. Amount Proposed to Settle Claim for Punitive Damages, If Any: Edwards has asserted a claim against Epstein for punitive damages in his Fourth Amended Counterclaim. The Total Amount set forth in paragraph 2(d) above includes payment of $100,000 for Edwards' claim for punitive damages . The total a

rivilege is very clearly defined in Florida Rule of Civil Procedure 1.280(b)(3). And, Your Honor, that is quoted in the response in opposition to Jeffrey Epstein's motion to overrule objections and compel answers to these questions. It is quoted in its entirety at page two of our response. And it says that a

urt is aware, the only thing pending at this point in time in the case is Mr. Edwards' claim of abuse of process malicious prosecution against Mr. Epstein. The abuse of process claim has been disposed of. It was successfully won on the summary judgment and is no longer an issue. So the only operativ

H COUNTY, FLORIDA Case No. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, indiv

f abuse of process malicious prosecution against Mr. Epstein. The abuse of process claim has been disposed o

rocess claim has been disposed of. It was successfully won on the summary judgment and is no longer an issue. So the only operative portion of the Fourth Amended Counterclaim is count two, malicious prosecution. In that complaint, Judge, against Mr. Epstein, Mr. Edwards asserts in paragraph 24, "While pro

r-Defendant, vs. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter- Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR FEES AND COSTS AND INCORPORATED MEMORANDUM OF LAW Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersign

TIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR FEES AND COSTS AND INCORPORATED MEMORANDUM OF LAW Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to §768.79 of the Florida Statutes and Rule 1.442 of the Florida Rules of Civil Procedure, h

COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, vs. SCOT

n. Epstein subsequently dismissed his Complaint without prejudice. The counter- claim proceeded, undergoing several amendments. As it now stands, the Fourth Amended Counterclaim has two causes of action: abuse of process and malicious prosecution. Epstein moved for summary judgment arguing that the litigation p

er-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S PROPOSAL FOR SETTLEMENT TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY J. EDWARDS. INDIVIDUALLY Plaintiff/Counter-Defendant, Jeffrey Epstein, hereby propo

sal for Settlement and Offer of Judgment ("Proposal") a. Parties: The party making this Proposal is Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"). The party to whom this Proposal is being made is Defendant/Counter-Plaintiff, Bradley J. Edwards, individually ("Edwards"). In this Proposal, E

CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Case No. 50-2009CA040800XXXXMBAG Plain

roposal. e. Amount Proposed to Settle Claim for Punitive Damages, If Any: Edwards has asserted a claim against Epstein for punitive damages in his Fourth Amended Counterclaim. The Total Amount set forth in paragraph 2(d) above includes payment of $20,000 for Edwards' claim for punitive damages. The total amo

F THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JUDGE: CROW PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LAW IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S MOTION FOR A PROTECTIVE ORDER Plaintiff/Counter-Defendant Jeffrey

OF LAW IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS'S MOTION FOR A PROTECTIVE ORDER Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, hereby files his Memorandum of Law in Opposition to Defendant/Counter-Plaintiff Bradley Edwards's ("Edwa

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

d factually deficient Motion for Protective Order. In support thereof, Epstein states: INTRODUCTION On or about January 9, 2013, Edwards filed his Fourth Amended Counterclaim against Epstein, asserting therein that he suffered the following damages: "a) injury to his reputation; b) mental anguish, embarrassm

L CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, CASE NO.: 2009CA0408003OOOCMB CIVIL DI

APPENDIX 1. Order Granting Fees and Costs of February 3, 2015 2. Epstein's Motion for Fees and Costs with attached pleadings dated June 2, 2014. EFTA00617978 IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN A

ADLEY J. EDWARDS. Defendants/Counter-Plaintiffs. ORDER GRANTING MOTION FOR FEES AND COSTS THIS CAUSE came before the Court on Counter-Defendant's, Jeffrey Epstein's, Motion for Fees and Costs filed on June 2, 2014. A hearing was held on December 8, 2014, at which 't counsel presented argument on the Motion. On

n. Epstein subsequently dismissed his Complaint without prejudice. The counter- claim proceeded, undergoing several amendments. As it now stands, the Fourth Amended Counterclaim has two causes of action: abuse of process and malicious prosecution. Epstein moved for summary judgment arguing that the litigation p

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

me before the court on Plaintiff/Counter-Defendant Jeffrey Epstein's Motion for Summary Judgment as to Defendant/Counter-Plaintiff Bradley Edwards's Fourth Amended Counterclaim. The Court, having considered the Motion and Responses, having heard argument of counsel, and being otherwise duly advised in the prem

40800XXXXMBAG Plaintiff/Counter-Defendant, JUDGE HAFELE v. BRADLEY J. EDWARDS, et al., Defendant/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWAFtDS'S FOURTH AMENDED COUNTERCLAIM, REOUEST FOR ORAL ARGUMENT AND SUPPORTIN

EDWAFtDS'S FOURTH AMENDED COUNTERCLAIM, REOUEST FOR ORAL ARGUMENT AND SUPPORTING MEMORANDUM OF LAW Plaintiff/Counter-Defendant, Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.510 of the Florida Rules of Civil Procedure, hereby files this Motion for Summary

s Rights Act: When asked whether Epstein "pulled you closer to him in a sexual way," [LM] replied: A. I wish. No, no, never, ever, ever, no, never. Jeffrey is an awesome man, no. At the end of her interview, [LM] was asked if she had any questions for the agents or AUSA Villafana. [LM] responded: A. N

n. Epstein subsequently dismissed his Complaint without prejudice. The counter- claim proceeded, undergoing several amendments. As it now stands, the Fourth Amended Counterclaim has two causes of action: abuse of process and malicious prosecution. Epstein moved for summary judgment arguing that the litigation p