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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,
ne Doe v. Jeffrey Epstein, 08-80893-CIV Marra/Johnson; copies of subpoenas; Deposition Transcript of Jeffrey Epstein, p. 23; line 4-p. 38; line 22; Initial Complaint filed by Epstein dated December 9, 2009, pages 13-20; Razorback Amended Complaint; pp. 16-17; ¶1148, 49. The litigation practices giving rise to pr
IRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMBAG PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S ANSWER AND AFFIRMATIVE DEFENSES TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' COUNTERCLAIM Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein
STEIN'S ANSWER AND AFFIRMATIVE DEFENSES TO DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' COUNTERCLAIM Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel and pursuant to Rule 1.110 of the Florida Rules of Civil Procedure, hereby files his Answer and Affirmati
JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv
ds still utilizes his litigious association with Mr. Epstein at his new firm Farmer, Jaffe, Weissing, Edwards,
4 and demands strict proof thereof. 25. Epstein denies each and every allegation contained in Paragrapgh 25 and demands strict proof thereof. 26. Epestein denies each and every allegation contained in Paragrapgh 26 and demands strict proof thereof. 27. Epstein admits that some of the claims initially
Epstein admits that some of the claims initially filed by him against Edwards are delineated in Paragraph 11 and its subparts, but submits that the Initial Complaint speaks for itself and that to the extent that Edwards has inaccurately summarized or interpreted any provision thereof in Paragraph II of his Count
SCOVERY TO TAKE DEPOSITIONS Counter-Plaintiff, Bradley J. Edwards, by and through undersigned counsel, hereby files this Response in Oppositions to Jeffrey Epstein's Motion to Reopen Discovery to Take Depositions, and as grounds therefor states as follows: The Motion Fails to Meet the Court's Requirements to Reo
, Plaintiff, vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, RESPONSE IN OPPOSITION TO EPSTEIN'S MOTION TO REOPEN DISCOVERY TO TAKE DEPOSITIONS Counter-Plaintiff, Bradley J. Edwards, by and through undersigned counsel, hereby files this Resp
OUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv
wards who is seeking to reconfirm the deadline. Mr. Epstein is objecting to that reconfirmation. THE COURT:
rds adv. Epstein Case No.: 502009CA040800XXXXMBAG Response in Opposition to Epstein's Motion to Reopen Discovery Page 3 of 8 throughout Epstein's Initial Complaint. Any suggestion that L.M.'s deposition is needed "solely" as a result of the Court's December 5, 2017 ruling is therefore absurd. 4. Jane Doe is a
position to PlaintifUCounter-Defendant Jeffrey Epstein's Motion for Temporary Stay of Proceedings, and as grounds therefor states as follows: un 5 ana Jeffrey Epstein initiated this litigation in 2009. For three years, he carried the burden of proof to establish that Bradley Edwards had fabricated his clients' sex
n 2009. For three years, he carried the burden of proof to establish that Bradley Edwards had fabricated his clients' sexual assault claims against Epstein, in furtherance of a Ponzi scheme. Substantial discovery was taken by both parties. In 2012, Epstein voluntarily dismissed his complaint, and the so
DCA 2010) (stating that, in the context of arbitration, a party's "active participation in litigation" serves to waive the right to arbitration). b. Epstein is Estopped from Seeking a Stav/Continuance. Epstein's attempt to stay/continue this case is also barred by the doctrine of equitable estoppel, whi
UNTY, FLORIDA CASE NO.: 502009CA040800)OOOCMBAG JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv
ial complaint, Epstein emphatically stated that "[t]his lawsuit is filed and will be vigorously pursued against all these defendants." See Epstein's Initial Complaint at `Summary'. (Emphasis added). In accordance with this representation to the Court, Epstein made no attempt to stay his newly-filed civil case pen
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
ane Doe v. Jefrey Epstein, 08-80893-C1V Marra/Johnson; copies of subpoenas; Deposition Transcript of Jeffrey Epstein, p. 23; line 4-p. 38; line 22; Initial Complaint filed by Epstein dated December 9, 2009, pages 13-20; Razorback Amended Complaint; pp. 16-17; ¶¶ 48, 49. In addition, on July 24, 2009, while he wa
Entities connected to both Jeffrey Epstein and Initial Complaint

George W. Bush
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJane Doe
PERSONMaria Farmer
PERSON
Kenneth Marra
PERSON
Bill Clinton
PERSON
Scarlett Johansson
PERSONScott Rothstein
PERSONJack Scarola
PERSONTonja Haddad Coleman
PERSON
Morocco
LOCATIONAtterbury
ORGANIZATION
Weissing
PERSON
South Florida
LOCATIONJaffe
PERSON
Lauderdale
LOCATIONPalm Beach Lakes Blvd
LOCATION
David Copperfield
PERSONPalm Beach Lakes Boulevard
LOCATION