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

STYLE 28 CERTIFICATE 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

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

ngs against Defendant, i.e., 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 proba

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

ages for malicious prosecution 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 a

D FOR PALM BEACH COUNTY, FLORIDA JEFFREY EPSTEIN, Complex Litigation, Fla. R. Civ. Pro. 1201 Plaintiff, Case No. 50 2009 CA 040800XXXXMBAG vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, Defendants. PLAINTIFF/COUNTER-DEFENDANT JEFFREY EPSTEIN'S MOTION TO DISMISS AMENDED COUNTERCLAIM

FOWLER WHITE BURNETT P.A. • ESPIRITO SANTO PLAZA, 1395 BRICKELL AVENUE, 14•• FLOOR. MIAMI, FLORIDA 33131 • (305) 789-9200 EFTA00584348 Epstein v. Rothstein, et al. CASE NO. 50 2009 CA 040800 XXXXMB AG Epstein's Am MPO Prejclude O/C, etc. from Making Extrajudicial Statements, et al. Il. BACKGROUND In

oceeding; (5) there was malice on the part of the present defendant; and (6) the plaintiff suffered damage as a result of the original proceeding." Alamo Rent-A-Car v. Mancusi, 632 So. 2d 1352, 1355 (Fla. 1994).. A claim for malicious prosecution is defeated if a plaintiff fails to allege or establish any one of