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econd amended complaint (the "Fisher counterclaim"), is granted in all respects. The Soffer ejectment motion is granted as against deft Ron Soffer. Defls Jeffrey E. Epstein, Ivan S. Fisher, Ellyn Bank, Debra Elisa Cohen, Dianeataga?/a The Fisher Group, Fisher & Soffer a/k/a Fisher & Sophir, D. Gerzog, Robert Heilbum,
the house to the tenant we have selected should Mr. Epstein decide not to reoccupy the premises under the ne
on of the budding pursuant to the Foreign Missions Act, 22 U.S.C. § 4301 of seq. 0FM leased the building to defen- dant Jeffrey E. Epstein in 1992. Epstein sublet the building to defendant Ivan S. Fish- er in 1996, purportedly without the Govern- ment's consent. Fisher, in turn, sublet a portion of the
n personally liable because Epstein did not sign the con- tract as an agent or as a corporate officer. Epstein signed the contract as follows: /s/ Jeffery Epstein 1AG. Under New York law, a signature in a representative capacity would have been "Jeffrey Epstein for I.A.G." or "I.A.G., by Jeffrey Epstein". 2
atters extrinsic to the complaint. we will treat defendant Epstein's motion to dismiss as a motion for summary judg
RDERED. UNITED STATES of America, Plaintiff, I Jeffrey E. EPSTEIN, Ivan S. Fisher, Ellyn Bank, Debra Elis
RDERED. UNITED STATES of America, Plaintiff, I Jeffrey E. EPSTEIN, Ivan S. Fisher, Ellyn Bank, Debra Elise
his purchase, though. Because all reasonable inferences on a summary Judgment motion are to be drawn in favor of the non-moving party. Knight US. Fire Ins. Co., 804 F.2d V. 11 12d Cir.1981), we hold that the present action is not time-barred for the pur- poses of this motion. 4. Stroll contends that § 3-4
NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff, v. SCOTT ROTHSTEIN, indivi
you put into Q-task regarding the claims against Mr. Epstein? Edwards had filed suits against Epstein on beha
rrett, 742 So. 2d 451 (Fla. 5th DCA 1999. Therefore, if the answer was evident from the complaint eventually filed by Edwards ("to seek redress from Jeffrey Epstein"), it would not be privileged. Likewise, if L.M. had initially hired Edwards to consult him about a claim she never pursued, the subject might argua
lm Beach County Courthouse, 205 North Dixie Highway, Courtroom 9C, West Palm Beach, Florida 33401 on Friday, April 1, at 9:00 a.m., the following: EPSTEIN'S AMENDED AND SUPPLEMENTAL MOTION OF PLAINTIFF TO OVERRULE OBJECTIONS AND COMPEL DEFENDANT EDWARDS TO ANSWER QUESTIONS AND APPEAR FOR FURTHER DEPOS
adverse party to show that the communication was not privileged. Leithauser v. Harrison, 168 So. 2d 95 (Fla. 2d DCA 1964); see also Nationwide Mut. Fire Ins. Co. v. Harmon, 580 So. 2d 192, 192-93 (Fla. 4th DCA 1991) ("[N]othing in the record indicates that any documents are protected by the attorney/client p
IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, -VS- SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiffs. RESPONSE IN
in Opposition to Plaintiff/Counter-Defendant's Motion for Fees and Costs, and as grounds therefor would state: INTRODUCTION This case arises from Epstein's lawsuit against Edwards, when Epstein sued Edwards merely for his legal representation of people accusing Epstein of misconduct. Edwards counter-
COUNTY, FLORIDA. CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, -VS- SCOT
ls to satisfy the particularity requirement if an ambiguity could reasonably affect the offeree's decision to accept or reject. See Nationwide Mut. Fire Ins. Co. v. Pollinger 42 So.3d 890, 891 (Fla. 4th DCA 2010). As the Supreme Court has noted State Farm Mut. Auto Ins. Co. v. Nichols, 932 So.2d 1067, 1079
-Defendant, VS. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter- Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OBJECTION AND RESPONSE TO IMPROPER FILING OF SUPPLEMENTAL AUTHORITY INTRODUCTION In December 2009, Jeffrey Epstein ("Epstein") filed suit against
-DEFENDANT JEFFREY EPSTEIN'S OBJECTION AND RESPONSE TO IMPROPER FILING OF SUPPLEMENTAL AUTHORITY INTRODUCTION 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
COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, VS. SCOT
hevarria, McCalla, Raymer, Barrett &Frappier v. Cole, 950 So. 2d 380 (Fla.2007); Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, P.A. v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994); DelMonico v. Traynor, 2013 WL 535451 (Fla.2013); Am. Nat'l Title & Escrow of Fla. v. Guarantee Title & Trust Co., 748 S
SE NO. 502009CA040800XXXXMB Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT
Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. / PLAINTIFF JEFFREY EPSTEIN'S MOTION TO COMPEL PRODUCTION OF DOCUMENTS BY DEFENDANT BRADLEY EDWARDS AND FOR SANCTIONS Plaintiff, Jeffrey Epstein, by and through his undersigned
onse to several orders entered by Judge Raymond Ray in the Bankruptcy Court, filed a one hundred and fifty-nine (159) page privilege EFTA00582857 Epstein v. Rothstein and Edwards DRAFT 2/3/12 4:26 PM Case No. 502009CA040800XXXXMB/Div. AG log, claiming that over two thousand (2000) documents are pri
work-product privilege extends only to "materials in question [which]were prepared in anticipation of litigation with respondents." Nationwide Mut. Fire Ins. Co. v. Harmon, 580 So. 2d 192, (Fla. 4th DCA 1991). Forty years ago, the Florida Supreme Court, in Sof Drugs, Inc. v. Vermette, 236 So. 2d 108, 112 (F
-Defendant, VS. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter- Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFFS' MOTION FOR RECONSIDERATION INTRODUCTION In December 2009, Jeffrey Epstein ("Epstein") filed suit against Sc
TER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO PLAINTIFFS' MOTION FOR RECONSIDERATION INTRODUCTION 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
OUNTY, FLORIDA CASE NO. 502009CA0408003OOOCMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, VS. SCOT
Echevarria, McCalla, Raymer, Barrett &Frappier v. Cole, 950 So. 2d 380 (Fla.2007); Levin, Middlebrooks, Mabie, Thomas, Mayes & Mitchell, M. v. U.S. Fire Ins. Co., 639 So. 2d 606 (Fla. 1994); DelMonico v. Traynor, 2013 WL 535451 (Fla.2013); Am. Nat'l Title & Escrow of Fla. v. Guarantee Title & Trust Co., 748 S
da, October 16, 1987. 24. Kalt JP, Dietz PE, Cox JE Jr.: Economics and the Environment: New Challeng
torney, Milwaukee County, Wisconsin, in State v. Jeffrey L. Dahmer (serial murders of men) Consultant to
Jerner v. Allstate (Orlando, Florida) Testified at evidentiary hearing, 9/1/95 EFTA00072971 Park Dietz, M.D., M.P.H., Ph.D. Page 26 Am. Natl. Fire Ins. Co. v. Birmingham Fire Ins. Co. (Houston, Texas) Testified at deposition, 10/4/95 People of CA v. Erik Menendez (Los Angeles, California) Testified at
Entities connected to both Jeffrey Epstein and Fire Ins. Co.

Marc Rich
PERSONLeon Black
PERSON
Prince Andrew
PERSON
Ghislaine Maxwell
PERSON
George Mitchell
PERSON
George W. Bush
PERSON
Bradley Edwards
PERSON
United States
LOCATION
Stephen Hawking
PERSONJack Goldberger
PERSON
Prince Charles
PERSONJane Doe
PERSON
Martha Stewart
PERSON
Michael Cohen
PERSON
Barry Diller
PERSON
Department of Justice
ORGANIZATIONMaria Farmer
PERSON
Julie K. Brown
PERSONthe Southern District
LOCATION
New York
LOCATION