Epstein Secrets

outh Flagler Drive West Palm Beach, Florida 33401 Telephone: (561) 802-9044 Facsimile: (561) 802-9976 Attorneys for Plaintiff/Counter-Defendant Jeffrey Epstein - 6 - FOWLER WHITE BURNETT • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLER DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA00306389 Epstei

IN'S MEMORANDUM OF LAW IN OPPOSITION TO DAMAGES PLED IN BRADLEY EDWARDS' SECOND AMENDED COUNTERCLAIM Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, pursuant to this Court's Order on March 29, 2012, respectfully submits this Memorandum Of Law In Opposit

NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

ng of that lawsuit. Fifth, abuse of process is based on process used for an immediate purpose other than that for which it was designed. See, e.g., McMurray v. U-Haul Co., 425 So. 2d 1208 and n. I (Fla. 4th DCA 1983). Edwards, however, does not allege that any specific process was used by Epstein for an

tedly baseless lawsuit. Given the fact that the mere filing or service of a spurious claim is not itself actionable as abuse of process, see, e.g., McMurray v. U-Haul Co., 425 So. 2d 1208, 1209 (Fla. 4th DCA 1983); Blue v Weinstein, 381 So. 2d 308, 310 (Fla. 3d DCA 1980), it necessarily follows that Edwa

NTY, FLORIDA 2 - - - cASE No. sono9cAo4osocootxxma AG 3 THE BAILIFF: All rise. Court is now in 4 session. The Honorable David Crow presiding. Miley Epstein, 5 MR. CRITTON: Good morning. Plaintiff. 6 MR. SCAROLA: Good morning, Judge. SCOTT ROTHSTEIN, individually, 7 THE WITNESS: Were here on Epste

stein, 5 MR. CRITTON: Good morning. Plaintiff. 6 MR. SCAROLA: Good morning, Judge. SCOTT ROTHSTEIN, individually, 7 THE WITNESS: Were here on Epstein versus BRADLEY J. EDWAFtDS, individually, and L.M. individually, Defendants. / 8 9 10 Rothstein, et al. So, I've read the materials you guys

Critton on behalf of Tuesday, May II, 2010 17 Mr. Epstein. Palm Beach County Courthouse West Palm Beach,

criminal, tinder the 9 court properly found that Russell showed — and 10 Civil Theft Statute 772.11. One, we think it's 10 again this is in the McMurray case — the 11 not applicable. Two is we don't think notice 11 non-existence of a genuine issue of material 12 is required. It's part of the -- t

ling. 4 my client in the counterclaim are really 4 And they go down and they cite relying on 5 Paragraphs 9, 10, and II. And the key is the 5 McMurray versus U-Haul which is the Fourth 6 action was filed for the sole purpose to 6 District case, which holds that the mere filing 7 intimidate Edw

Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S RESPONSE IN OPPOSITION TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' MOTION FOR LEAVE TO AMEND TO ASSERT CLAIM FOR PUNITIVE DAMAGES Plaintiff/Co

NT/COUNTER-PLAINTIFF BRADLEY EDWARDS' MOTION FOR LEAVE TO AMEND TO ASSERT CLAIM FOR PUNITIVE DAMAGES Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his undersigned counsel, hereby offers the following response in opposition to Defendant/Counter- Plaintiff EDWARDS' ("Edwards") M

901 Phillips Point West 777 South Flagler Drive West Palm Beach, Florida 33401 Telephone: (561) 802-9044 Facsimile: (561) 802-9976 Attorneys for Jay Epstein, Plaintiff and - 10 - EFTA00582889 Epstein v. Rothstein, Edwards CASE NO. 50 2009 CA 040800 XXXXMB AG Epstein's Response in Opposition to Edwa

CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1

r purpose after an action was filed and process served. See,. e.g., Della-Donna v. Nova University, Inc., 512 So. 2d 1051, 1055 (Fla. 4th DCA 1987); McMurray v. U-Haul Co, Inc., 425 So. 2d 1208, 1209-10 (Fla. 4th DCA 1983). Accordingly, the filing of an action itself does not constitute abuse of process.

ter-Defendant, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LAW IN OPPOSITION TO DAMAGES PLED IN BRADLEY EDWARDS' SECOND AMENDED COUNTERCLAIM Plaintiff/Counter-Defendant Jeffrey Epstein ("Epst

IN'S MEMORANDUM OF LAW IN OPPOSITION TO DAMAGES PLED IN BRADLEY EDWARDS' SECOND AMENDED COUNTERCLAIM Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, pursuant to this Court's Order on , respectfully submits this Memorandum Of Law In Opposition To Damage

NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT

ch requires abuse of the judicial system subsequent to the filing of a complaint — not purportedly unfounded allegations in a complaint. See, e.g., McMurray v. U-Haul Co., 425 So. 2d 1208, 1209 (Fla. 4th DCA 1983); Blue v Weinstein, 381 So. 2d 308, 310 (Fla. 3d DCA 1980). Finally, to the extent that Edw

Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS AMENDED COUNTERCLAIM AND SUPPORTING MEMORANDUM OF LAW Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through hi

-DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS AMENDED COUNTERCLAIM AND SUPPORTING MEMORANDUM OF LAW Plaintiff/Counter-Defendant, JEFFREY EPSTEIN ("Epstein"), by and through his undersigned counsel, hereby moves to dismiss the Amended Counterclaim of the Defendant/Counter-Plaintiff, BRADLEY EDWARDS ("E

CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1

, 443 So. 2d 1025, 1026 (Fla. 2d DCA 1986)(counterclaim allegedly causing undue expenditure of time and money did not constitute abuse of process); McMurray v. U-Haul Co., 425 So. 2d 1208, 1209 (Fla. 4'h DCA 1983)(same); Blue v. Weinstein, 381 So. 2d 308, 311 (Fla. 3d DCA 1980)("[N]o abuse of the - 4 -

Case No. 50 2009 CA 040800XXXXMBAG VS. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION FOR SUMMARY JUDGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' COUNTERCLAIM AND SUPPORTING MEMORANDUM OF LAW Plaintiff/Counter-Defend

DGMENT ON DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' COUNTERCLAIM 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, files this Motion for Summary Judgmen

CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1

, 443 So. 2d 1025, 1026 (Fla. 2d DCA 1986)(counterclaim allegedly causing undue expenditure of time and money did not constitute abuse of process); McMurray v. U-Haul Co., 425 So. 2d 1208, 1209 (Fla. 4'h DCA 1983)(same); Blue v. Weinstein, 381 So. 2d 308, 311 (Fla. 3d DCA 1980)("[N]o abuse of the proces

epare her defense, the British socialite's lawyer Jeffrey Pagliuca said Friday in a letter to U.S. Distric

www.fox44news.corn/news/local-news/killeen-woman-sentenced-to-205-months-in-federal- prison-for-two-bank-robberies> Waco, TX (10/23) reports in June, McMurray "pleaded guilty to two counts of bank robbery and two counts of brandishing a firearm during a crime of violence.... FBI agents and Killeen Police

pare her defense, the British socialite's lawyer Jeffrey Pagliuca said Friday in a letter to U.S. District

n Antonio Division Special Agent in Charge Christopher Combs and Killeen Police Chief Charles F. Kimble." KWKT-TV Waco, TX (10/23) reports in June, McMurray "pleaded guilty to two counts of bank robbery and two counts of brandishing a firearm during a crime of violence. ... FBI agents and Killeen Police