Epstein Secrets

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

2d 733, 737 (Fla. 3d DCA 1981) (emphasis added). See also Estate of Carrillo v. Fed. Deposit Ins. Corp., No. 11-22668-CIV, 2012 WL 13013081, at *1 (M. Fla. Apr. 25, 2012) ("Bifurcation is the exception, not the rule, and the party seeking bifurcation shoulders the heavy burden of establishing that bifu

ifferent litigation in which he himself — not Jane Doc — is a party. Specifically, in January 2010 the managing partner of Edwards' former law firm, Scott Rothstein, pled guilty and was sentenced to 50 years in prison for a massive "Ponzi" scheme in which he defrauded investors of $1.2 billion by convincing the

brought a civil lawsuit against Edwards in Florida state court in which he alleges that Edwards was involved in, or knew or should have known about, Rothstein's Ponzi scheme, and pleads claims against Edwards for fraud and violation of Florida's racketeering statute as well as an abuse of process claim al

,25 29 28,29 In re Zallie, 2009 WL 2844429 (Sup. Ct. M. Co. Aug. 13, 2009) 12, 15, 21 Johnson Law Group v. limadebt USA, LLC, 2010 WL 2035284 (M. Fla. May 24, 2010) 18 Kirkland & Ellis v. Chadl e & Parke LLP, 176 Misc.2d 73, 670 .2d 753 (Sup. Ct. Co. 1998) 12 Kooper v. Kooper, 74 El3d 6, 901

UDERDALE DIVISION www.flsb.uscourts.gov IN RE: ROTHSTEIN ROSENFELDT ADLER, M., Debtor. CASE NO. 09-34791

l states in controversy. See D.E. 6432; see also, e.g., Reaves v. Wayne Automatic Fire Sprinklers, Inc., No. 2:11-cv-00049-CEH-SPC, 2011 WL 4837253 (M. Fla. Oct. 12, 2011). As such, Rule 35 entitles Epstein to the Intervenors' independent mental examinations. The Intervenors suggest that Rule 35 does no