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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,
e of probable cause is measured by an objective standard, not based on an officer's underlying intent or subjective 21 EFTA00799359 motivation." Hernandez v. State, 784 So.2d at 1128 (quoting State v. T.P., 588 So. 2d 286, 287 (Fla. 3d DCA 1991)). Accordingly, "[t]he principal components of a determination of
dant, SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff, JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OMNIBUS MOTION IN LIMINE Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, herein moves for an Orde
er-Plaintiff, JUDGE: HAFELE PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S OMNIBUS MOTION IN LIMINE Plaintiff/Counter-Defendant Jeffrey Epstein ("Epstein"), by and through his undersigned counsel, herein moves for an Order in Limine precluding Defendant/Counter-Plaintiff Bradley Edwards ("Edwards") a
OUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMBAG JEFFREY EPSTEIN, vs. Plaintiff/Counter-Defendant, SCOT
laintiff has no evidence, nor can he prove, that Mr. Epstein lacked probable cause at the time he filed his l
his litigation. See Deposition Transcript of Jef•ey Epstein. When Edwards's inquiry turned to questions rega
.2d 1205, 1213-14 (Fla. 1980) (holding improper a question of a witness which sought "to elicit the individual and personal view of the witness."); Hernandez v. State, 575 So.2d 1321, 1322 (Fla. 4th DCA 1991) (holding that it was reversible error to admit testimony of police officers and teacher that sexual abuse
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
e of probable cause is measured by an objective standard, not based on an officer's underlying intent or subjective 25 EFTA00583976 motivation." Hernandez v. State, 784 So.2d at 1128 (quoting State v. T.P., 588 So. 2d 286, 287 (Fla. 3d DCA 1991)). Accordingly, "[t]he principal components of a determination of
Entities connected to both Jeffrey Epstein and Hernandez v. State

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