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EENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA. CASE NO. 502009CA040800XXXXMB JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, -VS- SCOTT ROTHSTEIN, individually and BRADLEY J. EDWARDS, individually, Defendant/Counter-Plaintiffs. RESPONSE IN OPPOSITION TO PLAINTIFF/COUNTER-DEFENDANT'S MOTION
0400 Attorneys for Bradle J. Edwards By: /s/ Andrew A. Harris ANDREW A. HARRIS Florida Bar No. 10061 11 EFTA00597564 SERVICE LIST Epstein v. Rothstein/Edwards Case No. 502009CA040800XXXXMB W. Chester Brewer, Jr., Esq. W. CHESTER BREWER, JR., P.A. 250 S. Australian Ave., Ste. 1400 West Palm Beac
ct's reasoning was that the condition had a value which could not be known, thereby making the proposal invalid. 7 EFTA00597560 Similarly, Judge Griffin noted in Dryden v. Pedemonti, 910 So.2d 854, 857 (Fla. 5th DCA 2005) (specially concurring), that the inclusion of such non-monetary terms with mone
Rothstein. For example, Epstein alleges generally that "Edwards's... actions constitute a fraud upon Epstein as [Rothstein, Rosenfeldt, and Adler], [Scott] Rothstein and the Litigation Team represented themselves to be acting in good faith and with the best interests of their clients in mind at all times when in
the Rothstein Rosenfeldt Adler law firm ("RRA") where Edwards worked for a short period of time). Epstein appears to allege that Edwards joined and Rothstein in fabricating sexual assault cases against Epstein to "pump" the cases to Ponzi scheme investors. As described by Epstein, investor victims were t
entitled to both his silence and his lawsuit." Boys & Girls Clubs of Marion County, Inc. v. J.A., 22 So.3d 855, 856 (Fla. 5th Dist. Ct. App. 2009) (Griffin, J., concurring specially). Thus, "a person may not seek affirmative relief in a civil action and then invoke the fifth amendment to avoid giving di
ifferent litigation in which he himself — not Jane Doc — is a party. Specifically, in January 2010 the managing partner of Edwards' former law firm, Scott Rothstein, pled guilty and was sentenced to 50 years in prison for a massive "Ponzi" scheme in which he defrauded investors of $1.2 billion by convincing the
brought a civil lawsuit against Edwards in Florida state court in which he alleges that Edwards was involved in, or knew or should have known about, Rothstein's Ponzi scheme, and pleads claims against Edwards for fraud and violation of Florida's racketeering statute as well as an abuse of process claim al
1 (1988) 1, 2, 22 People ex reL Scott v. Silverstein, 412 II2d 692 (III. App. Ct. 1980), rev d on other rounds, 429 M2d 483 (1981) 29 People v. Griffin, 1992 WL 474518 (Sup. Ct. ig Co. Nov. 12, 1992) 24, 26 People v. Royster, 43 .U1758, 842 ad 12 (1st Dep't 2007) 26 Pugh v. Avis Rent A 1997 W
1350 Avenue of the Americas New York NY 10019 Rothstein Kass USA DB Intermediaries and Other Contacts
N/- A Dupe John Griffin 0033000000ER74wAAD Pros•ect John T. Griffin Primary Residence (1,111,,r Inactive N/A No-diff [NULL] United States Griffin, John Griffin 0033000000ERb7lAAD Intermediaries John Griffin Business 959 E. Walnut, Suite 208 Pasadena CA 91106 [NULL] United States DB
Entities connected to both Scott Rothstein and Griffin

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJack Scarola
PERSONJane Doe
PERSON
George W. Bush
PERSONMaria Farmer
PERSON
Alan Dershowitz
PERSON
Paul Cassell
PERSON
Donald Trump
PERSON
Kenneth Marra
PERSON
Prince Andrew
PERSON
Salt Lake City
LOCATIONLeon Black
PERSON
United States
LOCATION
Ghislaine Maxwell
PERSON
Weissing
PERSON
Bill Clinton
PERSON
Sarah Kellen
PERSON
Scarlett Johansson
PERSON