Epstein Secrets

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, Defendants/Counter-Plaintiffs. DEFENDANT/COUNTER-PLAINTIFF BRADLEY EDWARDS' MOTION TO STRIKE

URLINGTON Florida Bar No. 285862 By:/s/ Nichole J. Segal NICHOLE J. SEGAL Florida Bar No. 41232 /kbt 6 EFTA00613506 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

dismiss), rev. denied, 81 So. 3d 414 (Fla. 2012). STATEMENT OF THE CASE AND FACTS In December 2009, Appellee, Jeffrey Epstein, filed suit against Scott Rothstein ("Rothstein") and Appellant, Bradley J. Edwards, based upon Epstein's justifiable belief at the time of filing his Complaint that these two individu

t, everything that he did 12 thereafter was an abuse of process. 13 We would put it to Your Honor that's not 14 the standard as espoused by the Third District 15 Court Of Appeal, the Fourth District Court Of 16 Appeal, or the Florida Supreme Court. The :7 standard is: Did the action have some relation

ied, 81 So. 3d 414 (Fla. 2012). STATEMENT OF THE CASE AND FACTS In December 2009, Appellee, Jeffrey Epstein, filed suit against Scott Rothstein ("Rothstein") and Appellant, Bradley J. Edwards, based upon Epstein's justifiable belief at the time of filing his Complaint that these two individuals, and ot

dismiss), rev. denied, 81 So. 3d 414 (Fla. 2012). STATEMENT OF THE CASE AND FACTS In December 2009, Appellee, Jeffrey Epstein, filed suit against Scott Rothstein ("Rothstein") and Appellant, Bradley J. Edwards, based upon Epstein's justifiable belief at the time of filing his Complaint that these two individu

law presented in the case at hand, and conducts a detailed analysis of the seminal Florida Supreme Court cases germane to the issues. In Wolfe, the Third District Court of Appeal affirmed the trial court's order granting a motion for judgment on the pleadings in an abuse of process and malicious prosecution a

THE CIRCUIT COURT OF THE 15th JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO. 502009CA040800XXXXMBAG JEFFREY EPSTEIN, Plaintiff, SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Defendants. TRANSCRIPT OF HEARING PROCEEDINGS DATE TAKEN: Monday, January 27, 2014 TIME:

row 3 involving this case, I had no knowledge whatsoever 4 that a separate and independent action had been 5 brought by Mr. Epstein against the Rothstein 6 entities and Mr. Edwards. So to that extent, I 7 just to want let you know, as you probably already 8 did already know, that I handled those

t, everything that he did 12 thereafter was an abuse of process. 13 We would put it to Your Honor that's not 14 the standard as espoused by the Third District 15 Court Of Appeal, the Fourth District Court Of 16 Appeal, or the Florida Supreme Court. The 17 standard is: Did the action have some relation

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

JEFFREY EPSTEIN, Plaintiff, VS. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individu

renders its Opinion on the certified conflict between the Fourth District Court of Appeal's decision in this matter and the decision rendered by the Third District Court of Appeal in Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013). Alternatively, should this Court not enter an Order staying these proceeding

dismiss), rev. denied, 81 So. 3d 414 (Fla. 2012). STATEMENT OF THE CASE AND FACTS In December 2009, Appellee, Jeffrey Epstein, filed suit against Scott Rothstein ("Rothstein") and Appellant, Bradley J. Edwards, based upon Epstein's justifiable belief at the time of filing his Complaint that these two individu

ied, 81 So. 3d 414 (Fla. 2012). STATEMENT OF THE CASE AND FACTS In December 2009, Appellee, Jeffrey Epstein, filed suit against Scott Rothstein ("Rothstein") and Appellant, Bradley J. Edwards, based upon Epstein's justifiable belief at the time of filing his Complaint that these two individuals, and ot

al to this Court and is set for Oral Argument on April 28, 2015. 10 EFTA00714933 Florida Supreme Court cases germane to the issues. In Wolfe, the Third District Court of Appeal affirmed the trial court's order granting a motion for judgment on the pleadings in an abuse of process and malicious prosecution a

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, IN THE CIRCUIT COURT OF THE FIFTEENTH JUDICIAL CIRCUIT IN AND FOR PALM BEACH COUNTY, FLORI

JEFFREY EPSTEIN, Plaintiff, vs. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individu

renders its Opinion on the certified conflict between the Fourth District Court of Appeal's decision in this matter and the decision rendered by the Third District Court of Appeal in Wolfe v. Foreman, 128 So. 3d 67 (Fla. 3d DCA 2013). Alternatively, should this Court not enter an Order staying these proceeding

01 19 20 21 22 Jennifer DiLorenzo, court reporter 23 24 25 EFTA00776366 2 1 APPEARANCES OF COUNSEL 2 3 On behalf of the Plaintiff: 4 ROTHSTEIN, ROSENFELDT & ADLER BY: WILLIAM J. BERGER, ESQ., 5 Mizner Park Office Tower Suite 675 6 225 NE Mizner Boulevard Boca Raton, FL 33432 7 8 RO

om the essential requirement of law in granting this discovery," and it refers to a case called Smith vs. TIB Bank of the Keys, 687 So.2d. 895, a Third District case, 1997, and that quotation then from that case by the Fifth in the Ballast case says "by alleging fraud as well as breach EFTA00776412 48 1

. • . .1.. - . ! I bi . .. .c. 111 . Palm )jeach,PL 33401:(fax: 561-835.8691); and Bradley ,T• Edwitd;,• q. and WIlliatu J. • s. Berger Esq. Rothstein Rosenfeldt•Adler 401 East Las O. ;sit' 131i vl cit‘#41 1; )650, lion Lauderdale, • - • i• • ,,-. t . : • 1. • ., ' • ' 1 ' i• • - I . ! i

80827 Page 2 of I I Westlaw 769 So.2d 389 769 So.2d 389, 24 Ha. L. Weekly D2439 (Cite as: 769 So.2d 389) District Court of Appeal of Florida, Third District. Deborah PEREZ, Appellant, v. Jorge M. PEREZ, Appellee. No. 99.2182. Oct. 27, 1999. Rehearing Denied Dec. 7, 1999. Following divorce, parties

st Palm Beach, FL 33401, William J Berger, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas Blvd., Suite

EFTA00231327 Page 2 of I I Wdstlaw. 76912d 389 769 2d 389 Fla. L. Weekly D2439 (Cite as: 769 ..241 389) District Court of Appeal of Florida, Third District. Deborah PEREZ, Appellant, v. Jorge M. PEREZ, Appel lee. No. 99.2182. Oct. 27, 1999. Rehearing Denied Dec. 7, 1999. Following divorce, parties

st Palm Beach, FL 33401, William J Berger, Esq., ROTHSTEIN ROSENFELDT ADLER, 401 East Las Olas Blvd., Suite

00232447 Page 2 of Wdstlaw. 769 So.2d 389 769 So.2d 389.24 Fla. L. Weekly D2439 (Cite as: 769 So.2d 389) District Court of Appeal of Florida, Third District. Deborah PEREZ, Appellant. v. Jorge M. PEREZ, Appel lee. No. 99-2182. Oct. 27, 1999. Rehearing Denied Dec. 7, 1999. Following divorce, parties