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

Olson case, respectfully, that I 11 can gather here. So based on the Third District 12 Court's decisions in Wolfe quoting in large part 13 from the Florida Supreme Court's decision in 14 Echevarria, whereas here all of the allegations 15 made in both the abuse of process claim and the 16 malicious prosecution clai

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 RESPONSE IN

INTRODUCTION Edwards seeks to prevent Epstein from introducing any testimony and evidence regarding the criminal misconduct that occurred with the Rothstein, Rosenfeldt & Adler law firm ("RRA") during the six months that he was employed there, but that was not known to Epstein until after December 9, 20

e Crow ruling that Epstein's Second Amended Complaint properly stated a cause of action for abuse of process. It would be a tortured application of the Florida Supreme Court's Levin decision to allow Edwards to bar Epstein from presenting his defense and constitutes reversible error. CONCLUSION Epstein respectfully reque

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

e Olson case, respectfully, that 11 can gather here. So based on the Third District 12 Court's decisions in Wolfe quoting in large part 13 from the Florida Supreme Court's decision in 14 Echevarria, whereas here all of the allegations 15 made in both the abuse of process claim and the 16 malicious prosecution clai

reviewed 4:21 revisit 13:1 right 6:25 7:24 9:7,13 11:1 11:3,14 12:8,9 13:11,22 15:6,19 rights 12:16 Robert 2:6 4:5 Rosenfeldt 2:12 Rothstein 2:12 rule 5:25 6:3,4 6:24 8:13 8:18 9:17 9:18 11:21 13:10 14:5 14:5 ruled 7:15 Rules 5:21 6:1 11:22 ruling 8:7,22 8 3:1 4:7 6:2 say

e majority resolved the issue by granting a narrow role to privacy based on considerations re- lating to the legitimate expectations of privacy. In the Florida Supreme Court's well-developed pri- vacy jurisprudence, the fundamental basis of the right of privacy is a legitimate expectation of pri- vacy. Not every fact in ev

16 32:7 risk 9:6 10:6,7 18:25 38:6 40:1041:6,11 risks 21:5 Robert 2:1,8 4:2 6:3 role 25:1317:7 Room 2:23 Rosenfeldt 1:17 rose-colored 11:16 Rothstein 1:17 HPR-CM-RNIR-F... 44:21 RPR-RMR-FCRR... 2:21 rule 39:9 42:13 rules 22:3 25:1 34:24 40:15 42:13 ruling 8:25 42:7 rulings 19:21 23:8 25:2

e majority resolved the issue by granting a narrow role to privacy based on considerations re- lating to the legitimate expectations of privacy. In the Florida Supreme Court's well-developed pri- vacy jurisprudence, the fundamental basis of the right of privacy is a legitimate expectation of pri- vacy. Not every fact in ev