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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, 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
ious prosecution or abuse of process. The court certified conflict with Wolfe; the Florida Supreme Court ultimately approved Fischer and disapproved the Third District's decision in Wolfe. In its Opinion in this case, the Fourth District held that its decision in Fischer controlled as to the litigation privilege is
HE STATE OF FLORIDA FOURTH DISTRICT Appellate Case No. 4D18-0787 LT Case No. 502009CA040800XXXXMB AG JEFFREY EPSTEIN, Petitioner/Plaintiff, v. SCOTT ROTHSTEIN, individually, and BRADLEY J. EDWARDS, individually, Respondents/Defendants.1 REPLY TO RESPONSE TO PETITION FOR WRIT OF CERTIORARI On Review of a
d Not Wait for a Favorable Disposition of Epstein's Claims Against Him Before Filing His Malicious Prosecution Counterclaim Epstein's claim against Rothstein (originally filed as a claim against both Rothstein and Edwards) in connection with the use of Epstein case materials, which were improperly utiliz
despite having been joined at the hip with Epstein's claim against Rothstein since 2009— the risk of inconsistent verdicts is real. Instructive, is the Third District's opinion in Travelers Express Inc. v. Acosta, 397 So. 2d 733 (1981), in which the court considered whether a plaintiff's malicious prosecution claim
OURT OF THE FIFTEENTH JUDICIAL CIRCUIT, IN AND FOR PALM BEACH COUNTY, FLORIDA CASE NO.: 502009CA040800XXXXMI3AG JEFFREY EPSTEIN, Plaintiffs vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually, and L.M., individually, Defendant, NOTICE OF SUPPLEMENTAL AUTHORITY IN SUPPORT OF EDWARDS' MOTI
XXXMI3AG JEFFREY EPSTEIN, Plaintiffs vs. SCOTT ROTHSTEIN, individually, BRADLEY J. EDWARDS, individually,
the course of litigation. This opinion reflects a direct conflict between the interpretation of the scope of the litigation privilege reflected in the Third District's Wolfe decision and the Fourth District's repeated and consistent recognition of the continued viability of the tort of malicious prosecution in th
Entities connected to both Scott Rothstein and the Third District's

Jeffrey Epstein
PERSON
Bradley Edwards
PERSONJack Goldberger
PERSONJack Scarola
PERSON
George W. Bush
PERSONPalm Beach Lakes Boulevard
LOCATION
Donald Trump
PERSON
Scarlett Johansson
PERSONPalm Beach County Courthouse
LOCATIONPhilip M. Burlington
PERSON
Michael Jackson
PERSONWolfe
PERSON
Tallahassee
LOCATION
the United States Supreme Court
ORGANIZATIONDade County
LOCATIONEmmy Taylor
PERSONDaphne Wallace
PERSONthe Fourth District's
LOCATION