Epstein Secrets

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

erted process; and 3) damages resulting therefrom. S & I Invs. v. Payless Flea Mkt., Inc., 36 So. 3d 909, 917 (Fla. 4th DCA 2010) (emphasis added); Della-Donna v. Nova Univ., Inc., 512 So. 2d 1051, 1055 (Fla. 4th DCA 1987). EFTA00292563 SECOND AFFIRMATIVE DEFENSE For his Second Affirmative Defense, Epst

mmary judgment in the Ponzi Scheme Action. SJ Motion at 1 (Edwards "is entitled to summary judgment for all claims brought against him in Plaintiff Jeffrey Epstein's Complaint" because "the evidence uncontrovertibly demonstrates the propriety of every aspect of Edwards' involvement in the prosecution of legitimat

alternative sources before it may be subpoenaed from any non-party in New York. In fact, Edwards concedes in his own Florida court filings that the Epstein interview is, at best, cumulative of "overwhelming evidence" he has already obtained from several alternative sources. Second, even if Edwards were

made of a confidential unpublished interview of Jeffrey Epstein. PRELIMINARY STATEMENT In this ancillar

d not, publish the information imparted to me by Mr. Epstein during the interview. Rush Supp. Aft 17 (emphasi

Church of Scientology of Calif, Inc., 444 So.2d 442 (Fla. Dist. Ct. App. 1983) 18 Damiano v. Sony Music Entm 'I, Inc., 168 M. 485 (M. 1996) 27 Della-Donna v. Nova University, Inc., 512 So.2d 1051 (FIa. Dist. Ct. App. 1987) 18 DePalma v. DePalma, 538 So.2d 1290 (FIa. Dist. Ct. App. 1989) 21 E.I. Du

eme Action and does not Indeed, Epstein's settlement of the three suits legally km him from ever making such a claim for malicious prosecution. See Della-Donna v. Nova University, Inc., 512 So.2d 1051, 1055 (Fla. Dist. Ct. App. 1987) ("a bona fide termination favorable to plaintiff does not encompass a term

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, indiv

ds still utilizes his litigious association with Mr. Epstein at his new firm Farmer, Jaffe, Weissing, Edwards,

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

verted process; and 3) damages resulting therefrom. S & I Invs. v. Payless Flea Mkt, Inc., 36 So. 3d 909, 917 (Fla. 4th DCA 2010) (emphasis added); Della-Donna v. Nova Univ., Inc., 512 So. 24 1051, 1055 (Fla. 4th DCA 1987). SECOND AFFIRMATIVE DEFENSE For his Second Affirmative Defense, Epstein states that

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,

here is no such allegation of a post-issuance 20 case first. 20 act other than service of what was issued under 21 They sued for malicious, Mr. Della-Donna 21 the circumstances. 22 sued for malicious prosecution, abuse of 22 And it goes on and describes abuse of 23 process, and liable. And at page

ired. It's part of the -- that is, it 12 fact and dispute. Furthermore Russell 13 doesn't go to the issue of the motion for 13 established that Della-Donna failed to allege 14 summary judgment. 14 and there was no evidence of any act by Russell 15 Secondly, there is no 772.11 claim in the 15 whic

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

se of process requires proof that the judicial system was misused for an ulterior 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). Acco

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

. Payless Flea Mkt, 36 So. 3d 909, 917 (Fla. 411' DCA. 2010); Valdes v. GAB Robins North America, Inc., 924 So. 2d 862, 867 n. 2 (Fla. 3d DCA 2006); Della-Donna v. Nova Univ., Inc., 512 So. 2d 1051, 1055 (Fla. 4th DCA 1987). With regard to the first element of the tort of abuse of process, it is axiomatic t

use Edwards' abuse of process claim is based on the filing of allegedly insufficient claims, it fails to state a valid claim for relief. See, e.g., Della-Donna, 512 So. 2d at 1055; McMurray, 425 So. 2d 1208 (counterclaim for abuse of process was properly dismissed with prejudice when based on filing of comp

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

. Payless Flea Mkt., 36 So. 3d 909, 917 (Fla. 4th DCA. 2010); Valdes v. GAB Robins North America, Inc., 924 So. 2d 862, 867 n. 2 (Fla. 3d DCA 2006); Della-Donna v. Nova Univ., Inc., 512 So. 2d 1051, 1055 (Fla. 4th DCA 1987). With regard to the first element of the tort of abuse of process, it is axiomatic t

et al. abuse of process.' [Citation omitted] The plaintiff must prove improper use of process after it issues." S&I Invs., 36 So. 3d at 917(quoting Della-Donna v. Nova Univ., Inc., 512 So. 2d 1051, 1055-56 (Fla. 411' DCA 1987)). See also Valdes, 924 So. 2d at 867 ("Valdes' failure to allege any improper wi