Epstein Secrets

vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiff. AFFIDAVIT OF JEFFREY EPSTEIN The undersigned, Jeffrey E. Epstein, having first been duly sworn, hereby deposes and says: 1. I am over eighteen (18) years old and have personal knowledge of the facts stated here

or leave to file the supplemental argument contained herein on the following grounds: 1. The trial judge entered summary final judgment in favor of Epstein on the ground that the litigation privilege bars the malicious prosecution and abuse of process claims filed against Epstein by the appellant, Brad

unrelated to the underlying litigation against me, and (b) asserting my causes of action against Edwards and Rothstein in the Action. FURTHER AFFI JEFFREY EPS STATE OF NEW YORK ) ) ss.: COUNTY OF NEW YORK ) _ - Sworn and subscribed to before me, the undersigned authority, by Jeffrey Epstein, this 25t

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

. 4D14-2282 BRADLEY J. EDWARDS, Appellant, v. JEFFREY EPSTEIN, Appellee. MOTION FOR LEAVE TO FILE SUP

tioned action (the "Action") and submit this Affidavit in support of my Motion for Summary Judgment (the "Summary Judgment Motion") with respect to the Fourth Amended Counterclaim (the "Counterclaim") of Counter-Plaintiff Bradley Edwards ("Edwards"). 3. In the Counterclaim Edwards has asserted unsupported claims against me

vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiff. AFFIDAVIT OF JEFFREY EPSTEIN The undersigned, Jeffrey E. Epstein, having first been duly sworn, hereby deposes and says: 1. I am over eighteen (18) years old and have personal knowledge of the facts stated here

nderlying litigation against me, and (b) asserting my causes of action against Edwards and Rothstein in the Action. FURTHER AFFIANT SAYITH NAUGHT. JEFFREY EPS STATE OF NEW YORK ) ) ss.: COUNTY OF NEW YORK ) Sworn and subscribed to before me, the undersigned authority, by Jeffrey Epstein, this 25th day

IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No. 50 2009

CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No.

tioned action (the "Action") and submit this Affidavit in support of my Motion for Summary Judgment (the "Summary Judgment Motion") with respect to the Fourth Amended Counterclaim (the "Counterclaim") of Counter-Plaintiff Bradley Edwards ("Edwards"). 3. In the Counterclaim Edwards has asserted unsupported claims against me

vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiff. AFFIDAVIT OF JEFFREY EPSTEIN The undersigned, Jeffrey E. Epstein, having first been duly sworn, hereby deposes and says: 1. I am over eighteen (18) years old and have personal knowledge of the facts stated here

nderlying litigation against me, and (b) asserting my causes of action against Edwards and Rothstein in the Action. FURTHER AFFIANT SAYITH NAUGHT. JEFFREY EPS STATE OF NEW YORK ) ) ss.: COUNTY OF NEW YORK ) Sworn and subscribed to before me, the undersigned authority, by Jeffrey Epstein, this 25th day

IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No. 50 2009

CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No.

tioned action (the "Action") and submit this Affidavit in support of my Motion for Summary Judgment (the "Summary Judgment Motion") with respect to the Fourth Amended Counterclaim (the "Counterclaim") of Counter-Plaintiff Bradley Edwards ("Edwards"). 3. In the Counterclaim Edwards has asserted unsupported claims against me

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. BRADLEY J. EDWARDS, et al., Defendant/Counter-Plaintiffs. No. 50 2009 CA 040800XXXXMBAG JUDGE HAFELE MOTION F

unter Plaintiff Bradley J. Edwards' malicious prosecution claim fails as a matter of law on an essential element: the absence of probable cause for Epstein's underlying lawsuit. The Court has yet to hear argument from the parties on the issue of probable cause. Oral argument is therefore respectfully r

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

IRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. BRADL

tein. 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 privilege app

PLAINTIFF/COUNTER-DEFENDANT'S RESPONSE IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' MOTION TO STRIKE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT ON THE FOURTH AMENDED COUNTERCLAIM AND SUPPORTINGMEMORANDUM OF LAW Plaintiff/Counter-Defendant Jeffrey Epstein, by and

UCTION Edwards's Motion to Strike is based solely upon his erroneous argument that this Court's consideration of the probable cause issue raised in Epstein's Motion for Summary Tonga Haddad. P.A. • 315 SE 7th Street, Fon Lauderdale, FL 33301. EFTA00808559 Judgment is batted by the law of the case doc

IRCUIT OF FLORIDA IN AND FOR PALM BEACH COUNTY JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. BRADL

or judicial proceeding . . ."). Accordingly, Edwards's Motion to Strike should be denied on the grounds of both the law of the case and estoppel. B. Epstein Did Not "Actually Present" to the Fourth District Court of Appeal the Issue of Probable Cause The positions Edwards now takes in his Motion to Stri

ition to Defendant/Counter-Plaintiff Bradley Edwards' Motion to Strike Plaintiff/Counter-Defendant Jeffrey Epstein's Motion for Summary Judgment on the Fourth Amended Counterclaim, and respectfully requests that this Court deny Defendant/Counter-Plaintiff Bradley Edwards' Motion to Strike Plaintiff/Counter-Defendant Jeffrey E

vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiff AFFIDAVIT OF JEFFREY EPSTEIN The undersigned, Jeffrey E. Epstein, having first been duly sworn, hereby deposes and says: I. I am over eighteen (18) years old and have personal knowledge of the facts stated here

IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, Case No. 50 2009

f AFFIDAVIT OF JEFFREY EPSTEIN The undersigned, Jeffrey E. Epstein, having first been duly sworn, hereby de

f AFFIDAVIT OF JEFFREY EPSTEIN The undersigned, Jeffrey E. Epstein, having first been duly sworn, hereby dep

tioned action (the "Action") and submit this Affidavit in support of my Motion for Summary Judgment (the "Summary Judgment Motion") with respect to the Fourth Amended Counterclaim (the "Counterclaim") of Counter-Plaintiff Bradley Edwards ("Edwards"). 3. In the Counterclaim Edwards has asserted unsupported claims against me

IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS. individually, and individually, Defendants. RESPONSE IN OPPOSITION TO EPSTE

STEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS. individually, and individually, Defendants. RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION TO REMOVE CASE FROM TRIAL DOCKET IN ORDER TO COMPLY WITH THE MANDATE SET FORTH IN RULE 1.440 Counter-Plaintiff Edwards, by and through un

OUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, indiv

th Amended Counterclaim) 7. The second action pending is a claim for Malicious Prosecution filed by Edwards against Epstein. That claim is pled in the Fourth Amended Counterclaim, filed on January 9, 2013, after Edwards was dismissed from Action #1. Rothstein is not a party to this separate action. 8. There is no question t

S. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter- Plaintiffs. ORDER GRANTING PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT THIS CAUSE came before the court on Plaintiff/Counter-Defendant Jeffrey Epstein's Motion for Summary Judgment as to De

ing 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 Countercla

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

o the proceeding, are absolutely privileged. This absolute immunity afforded to Epstein pursuant to the litigation privilege appears on the face of the Fourth Amended Counterclaim as filed by Edwards. Further, during the hearing before this Court, Counter-Plaintiff Edwards candidly conceded that all of the allegations upon wh