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PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LAW IN OPPOSITION TO
LER WHITE BURNETT P.A. • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLF.R DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA00306384 Epstein v Rothstein, Edwards Case No. 502009CA0408003OOOCMBAG First, Edwards seeks "damages including but not limited to..." various elements of damages. (See Second
ted from his professional responsibilities" (¶17) or "interfere[d] in his professional relationships" (id.). The court stated in Miami Nat? Bank v. Nunez, 541 So. 2d 1259, 1260 (Fla. 3d DCA 1989) that "[w]e find no precedent for awarding a litigant compensatory damages for her own...participation in t
JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J, EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH C
any actions allegedly taken by Epstein. In fact, this litigation with Epstein catapulted Edwards from an unknown solo practitioner to a partner at Rothstein. Rosenfeldt, Adler. Moreover, Edwards still utilizes his litigious association with Mr. Epstein at his new firm Farmer, Jaffe, Weissing, Edwards, Fi
ds' Counterclaim fails to properly plead his damages as required as required under the Florida Rules of Civil Procedure. See Miami National Bank v. Nunez, 541 So. 2d 1259, 1260 (Fla. 3d DCA 1989) (stating that a litigant cannot recover as damages his own time for participating in a litigation when co
PALM BEACH COUNTY, FLORIDA CIVIL DIVISION CASE NO. 502009CA040800XXXXMBAG Judge David F. Crow JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiffs. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MEMORANDUM OF LA
FOWLER WHITE BURNETT • 901 PHILLIPS POINT WEST, 777 SOUTH FLAGLF.R DRIVE, WEST PALM BEACH, FLORIDA 33401 • (561) 802-9044 EFTA00582686 Epstein v Rothstein, Edwards Case No. 502009CA040800XXXXMBAG First, under Florida law, Edwards cannot recover compensatory damages for the alleged loss or use of his
ted from his professional responsibilities" (¶17) or "interfere[d] in his professional relationships" (id.). The court stated in Miami Nat'l Bank v. Nunez, 541 So. 2d 1259, 1260 (Fla. 3d DCA 1989) that "[w]e find no precedent for awarding a litigant compensatory damages for her own...participation in
JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J, EDWARDS, individually. Defendants. IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH C
any actions allegedly taken by Epstein. In fact, this litigation with Epstein catapulted Edwards from an unknown solo practitioner to a partner at Rothstein, Rosenfeldt, Adler. Moreover, Edwards still utilizes his litigious association with Mr. Epstein at his new firm Farmer, Jaffe, Weissing, Edwards, Fi
ds' Counterclaim fails to properly plead his damages as required as required under the Florida Rules of Civil Procedure. See Miami National Bank v. Nunez, 541 So. 2d 1259, 1260 (Fla. 3d DCA 1989) (stating that a litigant cannot recover as damages his own time for participating in a litigation when co
Entities connected to both Scott Rothstein and Nunez

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJack Scarola
PERSON
George W. Bush
PERSONMaria Farmer
PERSON
Alan Dershowitz
PERSON
Donald Trump
PERSON
Searcy Denney Scarola Barnhart & Shipley
ORGANIZATIONAtterbury Goldberger & Weiss
ORGANIZATIONMarc S. Nurik
PERSON
Salt Lake City
LOCATION
Prince Andrew
PERSON
Weissing
PERSON
Ghislaine Maxwell
PERSONAtterbury
ORGANIZATION
United States
LOCATIONLeon Black
PERSON
Bill Clinton
PERSONJaffe
PERSON