Epstein Secrets

IN THE DISTRICT COURT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, -VS- SCOTT individually, Intervenors.' ROTHSTEIN, BRADLEY J. individually, and and JANE DOE, Respondents CASE NO. 4D18-0762 RESPONSE TO EMERGENCY PETITION FOR WRIT OF MANDAMUS SEARCY DENNY S

ember 7, 2009, while Edwards was pursuing the cases noted above on behalf of his clients, Epstein filed the original Complaint here against Edwards, Scott Rothstein ("Rothstein"), and one of Edwards' clients, designated as ".." (App. 1). The gravamen of the Complaint was that after Edwards had filed those cases

ATE OF SERVICE 29 ii EFTA00808516 TABLE OF AUTHORITIES CASES PAGE Abrams v. Paul, 453 So.2d 826 (Fla. 1st DCA 1984) 17 Alamo Rent-A-Car v. Mancusi, 24 632 So.2d 1352 (Fla. 1994) Bennett v. Continental Chemicals, Inc., 19 492 So.2d 724 (Fla. 1st DCA 1986) Campbell v. Wells Fargo Bank, N.A.

likely default by Rothstein, the identical allegations will be terminated in Epstein's favor, a directly opposite result). See Alamo Rent-A-Car v. Mancusi, 632 So.2d 1352 (Fla. 1994). Thus, Edwards's malicious prosecution claim was not a compulsory counter-claim and would at best be considered a permi

09, I also became aware that the law firm of Conrad Scherer filed a Complaint against Scott Rothstein and others, Razorback Funding, LLC, et al. v. Scott W. Rothstein, et al., Case No. 09-062943(19) (hereinafter referenced as the "Razorback Complaint"), on behalf of some of the Ponzi Scheme investors. Upon revie

Influenced and Corrupt Organization Act; (3) abuse of process; and (4) fraud. Epstein's complaint set forth details of a Pont scheme that Edwards, Rothstein, and others perpetrated through their law firm, Rothstein, Rosenfeldt, and Adler, P.A. ("RRA"). (It 1-36).' The scheme included fraudulent promises

ons of dollars and fund the RRA Ponzi scheme." Edwards ' R. 809: citing deposition testimony of Bradley Edwards dated March 23, 2010; deposition of Scott W Rothstein in In re: Rothstein Rosenfeldt Adler, PA; 09-34791-RBR and Razorback Funding, LLC, et al. v. Scott W Rothstein, et al., Case No. 09-062943. R. 809,

dant, and (6) the plaintiff suffered damage as a result of the original proceeding." Fischer, 169 So. 3d at 1206 (quoting Alamo Rent—A—Car, Inc. v. Mancusi, 632 So.2d 1352, 1355 (Fla.1994)). The holding in Fischer was restated in Rivernider v. Meyer, No. 4D14-819, 2015 WL 5244635 (Fla. 4th DCA Sept. 9,

TEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA Case No. 50-2009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff/Counter-Defendant, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants/Counter-Plaintiff. / PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S NOTICE OF P

wsuit." This case has two components. First, Plaintiff Jeffrey Epstein has a claim against Defendant Scott Rothstein for utilizing three cases that Rothstein's firm had against Epstein to fabricate other claims and continue the operation of a Ponzi scheme. Second, about whether Plaintiff Jeffrey Epstein

in's position this will allow the jury to better understand why they are being instructed on probable cause, malice, etc.; Alamo Rent-A-Car Inc. v. Mancusi, 632 So. 2d 1352 (Fla. 1994); Rivernider v. Meyer, 174 So. 3d 602 (Fla. 46 DCA 2015); Hickman v. Barclay's Intl Realty, Inc., 16 So. 3d 154, 155 (Fl

RT OF APPEAL OF THE STATE OF FLORIDA FOURTH DISTRICT JEFFREY EPSTEIN, Petitioner, -VS- SCOTT individually, EDWARDS, L.M., E.W., Intervenors. ROTHSTEIN, BRADLEY J. individually, and and JANE DOE, Respondents CASE NO. 4D18-0762 APPENDIX TO RESPONSE TO PETITION FOR WRIT OF MANDAMUS PAGE 1. Non

40800 XXXXMB HONORABLE JUDGE DAVID F. CROW JEFFREY EPSTEIN, Plaintiff, vs. SCOTT RCTHSTEIN, BRADLEY J. EDWARDS, and LM, Defendants. DEFENDANT SCOTT ROTHSTEIN'S MOTI Defendant, SCOTT ROTHSTEIN ("R undersigned counsel and pursuant to Fla. R. Default entered against Defendant, and asserts as follows: ASIDE

, the facts this Court will consider when it determines whether Defendant has proved Plaintiff lacked probable cause. See Alamo Rent-A-Car, Inc. v. Mancusi, 632 So. 2d 1352, 1357 (Fla. 1994) (jury decides disputed issues of fact, but court determines whether those facts establish probable cause) (citati

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

ion are recoverable by Edwards because there was no prior lawsuit that ended with a "bona fide termination" in his favor. Alamo Rent-A-Car, Inc. v. Mancusi, 632 So. 2d 1352 (Fla. 1994). In order to comply with the Court's order to address damages, Epstein needs to incorporate certain arguments previousl